ECCO Sko A/S with its registered address at Industrivej 5, 6261 Bredebro, Denmark (hereinafter referred to as ECCO, “we”, “us” and “our”) and the companies within ECCO (“ECCO Affiliates”) respect your privacy and take our responsibility seriously.
This Privacy Policy describes how we collect, use, share and process personal data in connection with the use of this website, eccoshoeshine.com. Please take the time to read this Privacy Policy.
With this Privacy Policy we want to ensure that you receive adequate information about our collecting and processing of your personal data, including such information we are obliged to inform you about according to applicable personal data protection regulation incl. the EU Regulation No. 2016/679 the General Data Protection Regulation (“GDPR”).
In this privacy policy we use the term “personal data” synonymously with “personal information” or similar expressions as defined in applicable privacy regulation, which is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
We will update this Privacy Policy periodically and will post updates on the website.
This Website, eccoshoeshine.com, is provided and controlled by us. Unless otherwise specified elsewhere, the legal entity being responsible for the collection and processing of your personal data under this Privacy Policy (the “Controller”) is:
ECCO Sko A/S
Industrivej 5,
6261 Bredebro,
Denmark
If you have any questions or need to get in contact with us we urge you to contact us either by the following e-mail: eccoshoeshine@ecco.com
Our appointed Group Privacy Officer can be contacted either by:
E-mail:
legal@ecco.com
Letter:
ECCO Holding A/S, Legal Department, Industrivej 5, 6261 Bredebro, Denmark attn.: Group Privacy Officer
When you interact with us we might collect personal data about you, and use it for various purposes, such as operating this Website, enabling you to make use of our various services and getting in contact with us etc. We might also use your personal data to analyze and improve the website experience and performance.
If you are asked to provide information, then it is optional for you to disclose such information. The information might, however, be needed for statutory, contractual or practical reasons. We will always clearly indicate whether the information is mandatory. If you refrain from disclosing information which we deem as mandatory, as a consequence it may be that we will not be able to provide you with the services you have requested.
We, like all other ECCO Affiliates, strongly believe in and are committed to the protection of the personal data in our custody and control, and we have therefore implemented what we believe are appropriate technical and organizational security measures to protect this personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.
Below you can read more about how we might collect and process your personal data in different situations in relation to the use of this website, including the general categories of personal data being processed; the source of the personal data that we do not directly obtain from you; the purposes for which personal data is being processed; and the legal basis for the processing.
We may collect the personal data described herein directly from you, from third parties we partner with, or through cookies or other automated means. These sources may include:
- You: We collect information directly from you, whenever you log in to our Website with a personal email account; contact us with questions or comments; upload content to our Website; enter our contests; respond to a survey; or fill out any forms on our Website.
- Your colleagues: We might collect personal data about you, if you participate in or are mentioned in videos, pictures or other content uploaded to the Website.
- Your Device or Browser: Certain information is automatically collected from your device or browser and analyzed when you visit our Website.
- Cookies: We use cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded on a website), web beacons, and other similar technologies to automatically collect information when you visit our Website. Through the use of cookies, we may link information about your interactions with our Website, apps, or emails over time, for example, which pages you visit, which links you use, and how long you stay on each page. Any information collected by us or by third parties through the use of cookies or similar technologies may be linked with other information we collect about you.
This Website uses 1st and 3rd party cookies for features strictly necessary for you to use this Website for functional features used to optimize your user experience, and for statistical and analytical purposes. Read more about the cookies used on this Website and how you can administer and reject these in our Cookie Policy.
The personal data we process for this include IP address, data on your behaviour on our website, and compilation of visited pages.
The legal basis for this processing is GDPR art. 6(1) a), namely the consent you have granted, when accepting our placement of functional, statistical and/or marketing cookies.
In order to access the content of this Website, you are required to log in to the Website. You can either log in by using the general email account for your ECCO Store (the “ECCO Store Account”), or if you have such, you individual ecco.com or ecco.ru email account (the “Personal ECCO Account”).
We log the access to the Website and the behaviour on the Website for operational purposes, and to optimize the user experience, and for statistical and analytical purposes.
Only if you use your Personal ECCO Account we might be able to link your Website usage to you as an individual.
The legal basis for this is GDPR art. 6(1) f), namely our legitimate interests in restricting access to the content of the Website to authorized users.
When using the Website you may be able to upload and download content, if you have used your Personal ECCO Account we will be keep a log of the content you might upload to or download from the Website.
The legal basis for this is GDPR art. 6(1) f), namely our legitimate interests in monitoring and controlling that content is uploaded and downloaded in accordance with the Terms of Use for this Website.
Occasionally we organize competitions and similar events. Such events will not be open for individuals, but only for our ECCO stores, and we will not be processing any personal data in order to be part of the competition.
However, in case the ECCO Store you are working in takes part of the competition, and uploads videos, pictures or other material to the Website, where you or your name etc. appears, then we will be processing such information.
You always have a right not to be part of such content, and we require that the Store Manager of the ECCO Store always ensures that individuals appearing in the content has volunteered to it.
If you come across content, which you do not want to be part of, please report it to your Store Manager. You may also make use of your rights as explained in SECTION 5 (YOUR RIGHTS).
The legal basis for this is GDPR art. 6(1) f), namely our legitimate interests in engaging our employees across the ECCO Stores.
In order to make the Website available and the services available, provide you with requested services and support and in general to operate our business, we will have to disclose and transfer your personal data to other ECCO Affiliates and third parties, such as IT service providers etc.
When using service providers and contractors to process your personal data on our behalf (also referred to as “data processors”) we require, that they only process your personal data in accordance with our instructions. We also require that the data processors signs relevant contracts providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the data processing will meet the requirements of the applicable data protection regulation and ensures an appropriate protection of your rights.
In case we disclose your personal data to third parties, who will not be acting as a data processor under our instructions, but as independent data controllers, then we do our best to ensure that they are trustworthy and have implemented appropriate technical and organisational measure to protect your data.
Unfold below sections to read more about how we share your personal data.
The main categories of potential recipients of your personal data are:
A. Service Providers acting as processors
We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our Website, perform statistical analysis, and perform other important services for us.
B. Service Providers acting as independent controllers
We may also share your personal data with our trusted third party service providers, who will use your personal data for their own purpose and thus will act as independent data controllers. These third party service providers include our external auditors, etc.
D. Other ECCO Affiliates
We may disclose your personal data to ECCO Holding A/S with its registered address at Industrivej 5, 6261 Bredebro, Denmark and other companies, which are owned or controlled by ECCO Holding A/S (“ECCO Affiliates”) in order for them to provide us with relevant services.
F. Legal Successors
A transfer of your personal data to another legal entity may occur as part of a transfer of our business or parts thereof in form of a reorganization, sale of assets, consolidation, merger or similar.
G. Other disclosures
In addition to where you have consented to a disclosure of the personal data or where disclosure is necessary to achieve the purpose(s) for which, it was collected, personal data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defense of legal claims.
The use of service providers and disclosure of your personal data to other ECCO Affiliates and other recipients might imply a transfer of your personal data to countries, which might not have data protection regulation as protective as in your jurisdiction and might not be considered ensuring an adequate level of protection of personal data by the EU Commission or a national data protection authority (so called “unsafe Third Countries”).
Such countries include, but is not limited to, the United Kingdom, the United States, Canada, China, Hong Kong, Macau, Taiwan, Vietnam, Singapore, Thailand, Malaysia, Japan, South Korea, Russia, UAE, Turkey, Indonesia, Australia and New Zealand.
We require that all recipients of your personal data provide appropriate safeguards to protect your personal data, when it is transferred to “unsafe Third Countries”. This is among other lawful means ensured through the adherence to standard data protection clauses as applicable under the EU GDPR article 46(2) or the EU-U.S Data Protection Framework if data is transferred to the USA. Please refer to the following link to obtain more information about the standard data protection clauses we generally use http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
We may also share your personal data with other third parties in other countries if you have given your consent to do so, if we are required to do so by law, if it is necessary for an association dissolution or a merger with another association or another similar event, or if it is necessary in connection with legal proceedings or to assert or defend claims.
If you have any questions, please contact our Customer Care representatives in accordance with SECTION 1 (OUR CONTACT DETAILS).
Your personal data will be held by us and kept in a form, which permits identification of you for no longer than is necessary for the purposes for which the personal data is collected and legitimately processed.
This implies that we will keep and process your personal data as long as we are providing services to you and also keep it afterwards for as long as would be needed for the settlement of any potential disputes that may be raised afterwards or as long as the law otherwise provides for. Thereafter, we will either delete your personal data or anonymize it so that it no longer can be used to identify you. We will delete any information, which according to our reasonable assessment seems to be inaccurate or out of date by reason of the time elapsed since it was collected or by reason of any other information in our possession.
If you provide us with a written request, we will also erase or anonymize your personal data without undue delay, unless we have a valid legal ground to continue to keep your personal data. Please also refer to SECTION 5 (YOUR RIGHTS).
You have certain rights according to the applicable data protection regulation. Some of the rights are rather complex and include exemptions, accordingly you are recommended to read relevant laws and guidance from the regulatory authorities for full explanation of these rights. Immediately below you can find a summary of your rights.
You have a right to obtain the confirmation as to whether or not your personal data are being processed by us. In addition, you have a right to obtain more detailed information about the personal data kept and the processing undertaken by us and under certain circumstances the right to receive a copy of this personal data.
You have the right to have inaccurate personal data about you rectified, and, taking into account the purpose of the processing, to have incomplete personal data completed.
In some cases, you have the right to erasure of your personal data without undue delay. Those circumstances include; i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; ii) you withdraw consent to consent-based processing; iii) the processing is for direct marketing purposes and/or iv) the personal data has been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary; i) for the exercising the right of freedom of expression and information; ii) for compliance with legal obligation; or iii) for the establishment, exercise or defence of legal claims.
In some cases, you have the right to restrict the processing of your personal data. Where processing has been restricted, we may continue to store your personal data. However, we will only otherwise process it i) with your consent; ii) for the establishment, exercise or defense of legal claims; iii) for the protection of the rights of another natural or legal person; or iv) for reasons of important public interest.
To the extent the legal basis for the processing is your consent, and such processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for i) the performance of a task carried out in the public interest or in the exercise of any official authority vested in ECCO; or ii) the purpose of legitimate interests pursued by us or a third party. In such case we will cease processing the personal data, unless we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of legal claims.
You also have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for the processing is your consent, you have the right to withdraw from that consent at any time.
In case you withdraw from a consent given, then we will cease to process your personal data, unless and to the extent the continued processing is permitted or required according to the applicable personal data regulation or other applicable laws and regulations. The withdrawal from your consent will in no event effect the lawfulness of processing based on consent before its withdrawal.
If you refrain from providing required consents, or later on withdraw from the consents, it might have as a consequence that you may not be able to benefit from some of the service offerings provided by us.
You may always lodge a complaint with your local data protection supervisory authority. The data protection supervisory authority in Denmark is the Danish Data Protection Agency, Carl Jacobsens Vej 35, 2500 Valby, Denmark, www.datatilsynet.dk.
We do our best to ensure that we protect your personal data, keep you informed about how we process your personal data and comply with the applicable data protection regulation. In case you are not satisfied with the processing and protection of your personal data or the information you have received from us, then we urge you to inform us in order for us to improve. Please also do not hesitate to contact us, if you want to make use of your rights.
Please contact us through the points of contact listed in SECTION 1 (OUR CONTACT DETAILS). Please also provide us with relevant information to take care of your request, including your full name and email address so that we can identify you. We will respond to your request without undue delay.
We may provide links to third party websites. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites. Before disclosing your personal data on any other website, we advise you to examine the terms and conditions of using that website and its privacy policies.
We reserve the right, at our discretion, to add, modify or remove portions of this Privacy Policy in the future to ensure that the information herein provides relevant and adequate information about our collecting and processing of your personal data.
This Privacy Policy may be supplemented by other information received from us or another ECCO Affiliate and other terms and conditions applicable to this Website or which you have agreed to as part of interacting with us or another ECCO Affiliate.
Version 02/2025