WOLVERINE WORLD WIDE, INC. PRIVACY POLICY

LAST UPDATED: 15 MAY 2018

Introduction

Wolverine World Wide, Inc. respects your privacy, and knows that you care how information about you is gathered and used. This privacy policy ("Privacy Policy" or the “Policy”) of Wolverine World Wide, Inc. and its subsidiaries (collectively, "Wolverine World Wide" or "Group", "Wolverine", "us," "we," and including Wolverine World Wide Europe Limited, Wolverine Europe Limited, Wolverine Europe B.V., Krause Global B.V. and Wolverine Europe Retail Limited) describes the types of personal information we gather from those persons visiting certain Internet web sites owned or operated by Wolverine World Wide (the "Site") and how we use that information.

If you do not agree to the terms of this Privacy Policy, please do not use this Site. Each time you use the Site, the current version of the Privacy Policy will apply. We reserve the right to change this Privacy Policy at any time. Accordingly, when you use the Site, you should check the date of this Privacy Policy (which appears at the top) and review any changes since the last version. If you do not agree to the changes which have been made to the Privacy Policy, please do not use this Site; however rest assured that data which we have previously collected from you will only be used in the ways notified to you under the Privacy Policy in force at the time the relevant Personal Information was collected. You may withdraw your consent to use your personal information at any time by visiting here.

What Information We Collect

Wolverine collects personal data that you provide to us on our Site, which may include but is not limited to:

  • Transaction information – your contact information, the products you are interested in, your purchasing requirements, your financial information including credit card or other payment information;

  • Responses to surveys – information you provide in responding to a survey on the website, via an app or email, on the telephone or otherwise;

  • Personal information – your name, job title, company name, department, email address, physical mailing address, telephone number(s), registration name and number, passwords, date of birth;

  • Professional information – such as your employment background, job description and related information;

  • In this Privacy Policy "Personal Information" means any information about you from which you can be personally identified including, but not limited to, your name, e-mail address, postal or other address, financial details, telephone or mobile telephone numbers, registration name and number, passwords, date of birth, and your purchase history.

    Except with respect to applications for employment or employees, of Wolverine and only to the extent required by law, we do not require you to provide sensitive personal information (such as information about your health, political or religious beliefs, criminal offences alleged or committed, or sexual orientation).

    Any Personal Information you do provide to us will be used only in accordance with this Privacy Policy.

    Please do not submit information that you do not want Wolverine to have.

    How We Collect Your Personal Information

    (a) From you

    We receive and store any Personal Information you enter on the Site or give us in any other way, including but not limited to registering with us, purchasing something from us, receiving a service provided by us, or participating in a competition, prize draw or promotion sponsored by us or providing a product review.

    (b) By using cookies

    In addition, we may use "cookies" to collect data relating to your general internet usage and specific usage of the Site. A summary of cookies used on this Site, including detailed information, is available here.

    Cookies are small text files that websites transfer to your computer’s web browser for storage on your computer’s hard drive. Cookies also allow us to count the number of unique and return visitors to the Site. We may use cookies to measure activity on the Site, which allows us to improve navigation throughout our Site. In addition, cookies on the Site may contain information (such as a unique user ID), which tracks the pages of the Site you have visited and the products you viewed or searched for. This information allows us to make updates to enhance your experience. Finally, we may use cookies to identify your IP address, browser version, number of visits, and similar data relating to your navigation of the internet and the Site.

    Parts of the Site will not function if you do not have cookies enabled. You can set your browser to refuse certain or all cookies, or to alert you when cookies are being sent. If you turn off cookies or refuse them, you will not be able to use every portion of the Site.

    There is a notice on our home page which describes how we use cookies and which also provides a link to the Policy. If you use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in the Policy. If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go for example to the UK Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

    (c) By using pixel tags

    A pixel tag, also known as a clear GIF or web beacon, is an invisible tag placed on certain pages of the Site but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies the pixel tag will simply detect an anonymous website visit.

    How We Use Your Personal Information

    We may use your Personal Information for any of the performance of our contract with you for the provision of Wolverine services and products which may include the following purposes:

    We may ask third-party service providers to use cookies and pixel tags on our behalf to collect certain information.

      1. to process the registration of your on-line account and maintain your on-line account
      2. to process and complete any orders you place with us
      3. to provide and personalise our service
      4. to monitor, develop and improve the Site and your experience of it
      5. where consented to by you, to send you information by email/post/sms/telephone about existing and new Group products, offers or services that you have requested from us, or that we feel may interest you
      6. to analyse and monitor consumer and customer activity and conduct other research
      7. to process and deal with any enquiries or complaints you may have
      8. to make available product reviews on the Site
      9. to publish the results of competitions, prize draws or other promotions
      10. to comply with our legal and regulatory obligations
      11. for the prevention or detection of crime or breaches of our Terms of Use or Terms of Sale
      12. to develop a knowledge base regarding our website users and customers
      13. to notify you about changes to our service or provide you with information about the products or services purchased from us
      14. to provide the information, services or support you request and related after-sales services
      15. to identify you, and to contact you from time to time with product or service updates*
      16. to send other messages that are useful to the service we provide
      17. to manage our relationship with you and to carry out any related administration
      18. to promote our services, or the services of our partners, including by email, social media platforms, and other advertising platforms
      19. to compare information for accuracy, and verify it with third parties*
      20. to protect the security of our IT systems and services against unauthorized or unlawful access and misuse*
      21. to detect, investigate and prevent activity we think may be potentially illegal, unlawful or harmful and to enforce our Privacy Policy and/or our Terms of Use or Terms of Sale or any other purpose referenced herein or therein*
      22. to carry out research, including market research, statistical research on Site traffic, sales and other commercial information to assist us in improving the services we provide to you and tailor the Site

    In short, we process your personal data where we have your consent to do so or otherwise where this is necessary for:

  • the performance of our contract with you for the provision of Wolverine services and products or to take preliminary steps at your request;
  • us to fulfil our legal obligations; or,
  • the purposes of the legitimate interests pursued by us or by a third party on our behalf.
  • A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests are those indicated with a “*” above, and we consider that we have implemented sufficient checks and protections to ensure that your rights and interests are not unreasonably intruded on.

    You may object to processing on any of these bases at any time and, if you do so, we will stop processing the personal data unless we can show compelling legitimate grounds which override your rights and interests, or we need the data to establish, exercise or defend legal claims – see Disclosure of Your Personal Information below.

    Disclosure of Your Personal Information

    Information about our customers and website visitors is an important part of our business and we are not in the business of selling it to others. We will share Personal Information only as described below:

      1. Amongst the Wolverine family of companies including subsidiaries and affiliates, as well as with their agents and employees, and across our brands.
      2. To our business partners. For example, if you purchase goods through the Site, like any other retailer we will have to provide credit card information to our credit card processor and authenticator for payment purposes, and your name and address to the company that ships our merchandise. Similarly, to improve the products and services offered, we may share Personal Information with designers, manufacturers, distributors, licensees, marketing and advertising partners, and parties that provide support services for the Site. In all cases, we limit the information shared with partners and vendors to that which is necessary to carry out those functions, but they may not use that data for any other purpose.
      3. With any third party you have asked us to share your personal data with – such as Facebook or any other social media site if you have asked us to connect with your account
      4. Where we are required to disclose Personal Information in response to law. enforcement activity or other governmental or regulatory request, or when otherwise required or permitted by law, in any countries where we have subsidiaries
      5. To enforce our contract or property rights, or in connection with actual or proposed litigation, or when otherwise necessary to protect our property, security, people and other rights or interests.
      6. Due to a sale or merger of one or more of our assets or any division or business line. Your personal information, as a valuable asset, may be transferred to the acquirer, even if they are not in the same line of business as us. Our customer database could be transferred separately from the rest of the business, in whole or in a number of parts. Potential acquirers and their advisors may have limited access to data as part of the sale process. However, use of your personal information will remain subject to this Privacy Policy. Similarly, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration.

    We may also use and disclose information in aggregate (so that no individual customers are identified) for marketing, strategic development, and other purposes. Please remember that when you share information publicly on the Site, for example a comment on a blog post or a product review, it may be indexable by search engines, including Google, which may mean that the information is made public.

    You may have accessed our website through a hyperlink from the website of one of our trading partners. If so, you consent to your personal details and purchase information, including behavioural patterns, being shared with that trading partner in accordance with our contractual relationship with them.

    Where Is Your Data and Where Is It Processed?

    The Personal Information you provide through the Site is processed by Wolverine World Wide, Inc. in the United States of America and may be transferred to other members of the Group or other third parties as described in the previous paragraph. For example, if you make a purchase through our Site, your Personal Information will be transferred to members of the Group and our vendors in the Netherlands and the United Kingdom in order to fulfil your order and help you with any enquiries you may have about that order. Some of the companies or other third parties to whom your Personal Information will be disclosed, including members of Wolverine World Wide and our vendors or service providers, are located outside the European Economic Area, in countries which do not provide the same level of protection to personal information. This includes the United States of America. Whether the Personal Information you provide to us is processed by Wolverine or our vendors within the EEA or outside of it, we will take steps to ensure that your Personal Information will be afforded the level of protection required of us under applicable data protection legislation and this Policy. If you have asked us to share data with third party websites (such as social media sites), their servers may not be secure. Note also that, despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data.

    Security and Retention Of Your Personal Information

    The security of your Personal Information is important to us, and we are committed to handling your customer information carefully. We take all reasonable technical and organisational measures to guard against unauthorized or unlawful processing of your Personal Information and against accidental loss or destruction of, or damage to your Personal Information. We make reasonable efforts to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented technology (such as encryption software, secure servers and firewalls) intended to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such Personal Information, appropriate to the nature of the data concerned. No method of transmission over the Internet, or method of electronic storage, however, is completely secure. Therefore, whilst we believe the measures implemented by the website reduce our vulnerability to security problems to a level appropriate to the type of data involved, we cannot guarantee the security of any data you disclose to us online, and in accepting the terms of this Privacy Policy by using the Site you accept the inherent risks of disclosing data online and agree that in no event will Wolverine be liable for any breach of security or unauthorised third party intrusion, unless this is due to our negligence or willful default.

    We have security measures in place to protect our user database and access to this database is restricted. However, it remains your responsibility:

  • Where you have a user account for the Site:
    • - to log off or exit from the Site when not using it
      - ensure no-one else uses the Site while your device is logged on to the Site (including by logging on to your device through a mobile, Wi-Fi or shared access connection you are using)
      - to keep your password or other access information secret. Your password and log in details are personal to you and should not be given to anyone else or used to provide shared access for example over a network. You should use a password which is unique to your use of the Site – do not use the same password as you use for another website or email account;

  • To maintain good internet security. For example if your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. You should keep all of your account details secure. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. You should also tell us as soon as you can so that we can try to help you keep your account secure and if necessary warn anyone else who could be affected.
  • We will retain your Personal Information for as long as is necessary for the processing purposes for which they were collected, processed and/or used and any other associated purpose (for example certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So if information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. We restrict access to your Personal Information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your Personal Information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

    Other Websites

    The Site may contain links to websites of retailers or other third parties ("Third Party Websites") who (1) are not affiliated with Wolverine, (2) are outside our control, and (3) are not covered by this Privacy Policy. Links provided to Third Party Websites on the Site are provided to you only as a convenience and the inclusion of any link does not imply reliability and endorsement by us of the content of any such Third Party Websites. Wolverine is not responsible for either the content of those Third Party Websites or the privacy practices of Third Party Websites, which may collect and use information from you in a manner different to how we do so and accordingly the use of such Third Party Websites is entirely at your own risk. For relevant information, you should review the privacy statements or policies of any Third Party Websites before either agreeing to their terms or before using them and direct any questions or comments about their contents to the relevant website provider. We may also use third parties to gather statistics on usage of the Site. This may involve the use of cookies, the purpose of which we have explained above. If you have asked us to share data with third party websites (such as social media sites), their servers may not be secure. Please also be aware that despite the measures taken by us and the third parties we engage, the internet is not secure. As a result others may nevertheless unlawfully intercept or access private transmissions or data.

    Applying to work with us

    If you apply to work with us, we will use the information you supply to process your application and to monitor recruitment statistics. As a global business we may transfer your details outside of your home country and to other companies in our Group. We will ask you to sign up to additional privacy terms if you apply for a job with us. Once a person has taken up employment with us, we will compile a file relating to their employment. At that stage we will give more details about how we hold employee data and we will expect the employee to sign up to additional privacy terms as part of their employment. If you apply to work with us through a third party, such as a recruitment consultant, please also check their privacy policy before proceeding. We do not encourage unsolicited approaches either directly or from third parties – please do not send personal data to us unless the data subject has read and agrees to this Policy. We may retain details of candidates who may be of interest to us, either now or in the future, in accordance with our records retention guidelines. If you would not like us to do that please let us know. Additionally, if your circumstances change – for example you no longer wish to be considered by us for employment – please let us know that too. We may use third parties to help us to consider potential hires. For example, we may use recruiting software from a third party, subject to that third party’s privacy policy, to help us manage the recruitment process.

    Personal Information and Children

    Without a parent's or guardian's consent, no Personal Information should be submitted to our website by children. Wolverine will not knowingly collect or use Personal Information from children.

    Your Rights, How To Change Your Data & Marketing Communications

    To the extent permitted by the laws of your country, you may have certain rights with respect to your Personal Information including without limitation the right to access, correct, delete, restrict, be forgotten, or object to processing of, or request data portability of the personal data collected about you subject to some conditions and exceptions. You may make a request pursuant to these data subject rights by going visiting here and submitting your request.

    If you have given permission, we may contact you by mail, telephone, SMS, text/picture/video message, fax, and/or email about products, services, promotions, special offers, charitable causes that may be of interest to you. If you prefer not to receive any direct marketing communications from us, you can opt out at any time. In addition, to the extent permitted by the laws of your country, you may have the right to object to the processing of your personal data for direct marketing purposes. If you prefer to be removed from our mailing list, please let us know by: (a) updating your account details online, (b) sending us an e-mail to the email address DataProtectionOfficer@wwwinc.com with the word "remove" in the subject line, (c) following the unsubscribe instructions located at the end of any marketing e-mail you receive from us. Please be sure to include in any communication your full name, e-mail address, postal address, and any message. Please note that such requests may take up to five business (5) days to become effective.

    You also have the right to lodge a complaint with a data protection regulator.

    How To Contact Us

    If you have any questions or comments about this Privacy Policy or the data we hold about you please contact us at:

    Data Protection Officer
    Address: Wolverine Europe Limited,
    King’s Place
    90 York Way
    London
    N1 9AG

    Telephone: 020-780-0191

    Email: DataProtectionOfficer@wwwinc.com