Last Updated: May 21, 2018
PART I. General information
PART II. What we collect and how we use it
1. Information you give us
You may give us information, including information that can identify you ("personal information"), when you use our Websites, correspond with us, or enter into any of our competitions, promotions, sweepstakes or surveys. Where we request information from you, we will collect the information set out in the relevant forms or pages. You may choose to provide additional information to us when you contact us or otherwise interact with us.
If you purchase any products through the Websites you may be required to create an online account (your "Account"). You are also able to create an Account with us without placing any orders. You may also be able to place orders without creating an Account via the "Guest Checkout" feature.
The information that you provide when setting up your Account may include your name, email address and telephone number. If you register to hold an Account with us, you will also have a unique username and password which enables you to access your Account.
Please note that we will not be storing your payment information, which will be processed and stored by a third-party payments company, although we may store certain information like your invoicing address and the last 4 digits of your card number.
If you subscribe to receive our newsletter, then you will provide us with your name and email address (and possibly even your relevant interests!) although you may optionally also provide your gender and date of birth.
If you contact us via email then we will collect your email address.
You may also submit personal information in connection with photos/stories/videos for our potential use and/or publication (for example, as part of competitions) or via reviews or our message boards. We may use some of these in marketing campaigns but if we do we will ensure that you are made aware of such use prior to the campaign going live and given an opportunity to understand the intended use and, if you choose, object to the use.
The personal information that you provide to us will be used for the purposes made clear to you at the time you submit your information, for example for enabling you to use our Websites and placing orders online and/or for administrative and troubleshooting purposes, and, as explained in section titled "Information we receive from other sources,” We may also use this information for further purposes when combined with other data we collect about you.
We and our third party marketing partners may also use the information you send to us for our marketing purposes (e.g. emails, newsletters, postal mailings, etc.), if this is in accordance with your marketing preferences. However, you will always be able to opt-out of our marketing at any time (see the "How to opt in or opt out of direct marketing" section below).Information we collect automatically via the Websites
When you visit our Websites, we may automatically collect the following information: your IP address, log-in information, location information, browser type and version, browser plug-in types and versions, operating system and platform, information about your visit including the URL clickstream to, through and from our Websites, download errors, length of visits to certain pages and page interaction. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws. We collect information automatically through the use of various technologies, including through "cookies", and this is explained further in the "Cookies and other technologies" section below.
We use the information we collect automatically: (i) to administer our Websites for internal operations including troubleshooting purposes; (ii) to ensure that content from our Websites is presented in the most effective manner for you and your devices; (iii) as part of our effort to keep our Websites and the order process; (iv) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and (v) to make suggestions and recommendations to you and other users of our Websites about goods or services that may interest you or them.Information we receive from other sources
We may receive and collect information about you if you access the Websites via social media (or vice versa) or if you use our forums, enter competitions with us or one of our partners or upload any content to the Websites. We use this information to provide technical support, validate your identity and enable your participation in any competitions you enter.
We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them (including information that is publicly available).
Where permitted by law, we may combine this information we receive from other sources, including from social media websites, with information you give to us and information we collect about you, including cookie information. We may use this information and the combined information for learning more about your preferences as our customer, for enhancing your user experience on our Websites and for providing you with information, content and offerings tailored to your needs.Pro Site users
In addition to the above collection and use, if you wish to access and make use of our Pro Sites we may require certain other information from you to validate your identity and employment status at an eligible partnering brand. We may require certain information from you or photographs of your paystubs/payslips or your work email address that you use at our partner. We will make you aware of what is required when you access our Pro Sites.
We will only ever ask you for a proportionate and justified amount of personal information to allow us to carry out the above checks and will not store this information for an unreasonable length of time.Legal basis for processing personal information (EEA visitors only)
If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests (such as the prevention of fraud or provision of direct marketing) and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at the address found in the "Contact Us" section below.Cookies and other technologies
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not been adopted, our websites do not process or respond to “Do Not Track” signals. To learn more about “Do Not Track”, please visit All About Do Not Track.Links to other websites and social media
On some pages of our Websites, third parties that provide content, applications or plug-ins through our Websites may track your use of content, applications and plug-ins or customise content, applications and plug-ins for you. For more information, please refer to our Cookie Statement.Data retention
We may retain some information about you and your purchases after they have been placed or your account has been closed where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.Disclosure of information to third parties
In the event that we or substantially all of our assets is purchased by or transferred to another company, some personal information may be an asset that is reviewed and transferred by or to a third party. This means that if a third party buys us, a corporate group member or its assets, then we may disclose information to that third party in connection with the sale. We will make clear to the relevant third party purchaser that it should only use personal information it receives from us for the purposes for which it was originally obtained.
PART III. Your rights in relation to your data
Right to access All users:
If you have chosen to have an account then you can access the personal information we hold about you via your account to obtain a copy of it and to correct, amend, or delete information that is inaccurate. You can also close your Account at any time.
It is your responsibility to ensure that you submit true, accurate and complete information to your account and keep it up to date.
Residents of the EEA and Canada: If you are a resident of the European Economic Area or Canada and wish to obtain a copy of personal information that we hold about you or request that the personal information that we hold about you be corrected, please contact us at the address found in the "Contact Us" section below. This may include information like transaction information (e.g., dates on which you made purchases, amounts and types of purchases) or contact information (e.g., name, address, phone number) that we maintain about you. Before responding to your request, we may ask you to verify your identity and to provide further details about your request.
Residents of the EEA: In addition, if you are a resident of the European Economic Area you can also object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Again, you can exercise these rights by contacting us at the address found in the "Contact Us" section below.
We will endeavour to respond to requests we receive from individuals wishing to exercise their data protection rights within an appropriate timeframe and, in any event, in accordance with applicable data protection laws. Please note that if you make a request to access your personal information we may charge you a fee where permitted and subject to a maximum specified by applicable law.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority (contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available on the European Commission website here.)How to opt in or opt out of direct marketing
We, and selected third parties, may use the information you give us on our Websites for direct marketing purposes to provide updates, newsletters, events or other communications that we think may interest you. Where required by law, your prior consent will be obtained before sending direct marketing. In any event, we will offer you the option to unsubscribe in every communication sent.
Alternatively, you may at any time ask us to remove you from any mailing list on which you previously asked us to include you by sending us an email at firstname.lastname@example.org. To opt out of having information about you shared with third parties for direct marketing purposes, please send us an email at email@example.com.
PART IV. Data transfers and security
Given that the Internet is a global environment, using the Internet to collect and process personal information necessarily involves the transmission of data on an international basis. While we generally try to store the personal information that we collect about you through our Websites in your region (for example for European visitors, in the European Economic Area), it is likely that your personal information will be transmitted to parties outside your region (where data protection laws may be different).
Please also note that your personal information may be processed in the country in which it was collected and in other countries, including the United States, whose data protection laws may be different to the laws in your country. In any event, we will ensure your personal information remains adequately protected in accordance with the standards described in this Policy, wherever it is processed.
These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. Our Standard Contractual Clauses can be provided on request. We will also ensure that any transfers described in this section take place in compliance with contractual or other measures to protect the information.Security
We use appropriate technical, organisational and administrative measures to protect any personal information we process about our visitors, our customers and their end users.
However, please note that no Internet transmission can ever be guaranteed 100% secure, and so we encourage you to take care when disclosing personal information online and to use readily available tools, such as Internet firewalls, anti-virus and anti-spyware software, and similar technologies to protect yourself online.
Where you have a password, which enables you to access our Websites, you are responsible for keeping this password secure and confidential.
PART V. About us and this policy
Changes to this Policy
The Websites are maintained by KEEN, Inc. If you have a question, concern or complaint about this Policy or our handling of your information, you can contact us by email at firstname.lastname@example.org.
For visitors from a country in the European Economic Area, please contact KEEN Europe Outdoor B.V. (Netherlands) (the data controller) using the following details: +31 10 22 14 038.
Copyright © 2018 KEEN, Inc. All rights reserved. KEEN and the KEEN logo are registered trademarks of KEEN, Inc.