PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE
In AT.KOLLEKTIVE we respect your privacy.
This website, atkollektive.com, is provided and controlled by AT.KOLLEKTIVE, a part of ECCO Sko A/S, with its registered address at Industrivej 5, 6261 Bredebro, Denmark (hereinafter referred to as “we”, “us” and “our”).
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”).
This Privacy Policy may be supplemented by other information received from us or other companies within the ECCO group of companies (“ECCO Affiliates”) 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.
Your comments and feedback are always welcome.
1. OUR CONTACT DETAILS
1.1. Identity of the Controller(s)
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
1.2. Our Contact Details
If you have any questions or need to get in contact with us we urge you to contact us either by;
E-mail: customer-service@atkollektive.com
Letter: ECCO Sko A/S, Industrivej 5, 6261 Bredebro, Denmark attn.: AT.KOLLEKTIVE
1.3. Contact details for the Group Privacy Officer
Our appointed Group Privacy Officer can be contacted either by;
E-mail: legal@ecco.com
Phone: +45 7491 1733
Letter: ECCO Holding A/S, Legal Department, Industrivej 5, 6261 Bredebro, Denmark attn.: Group Privacy Officer
2. HOW WE USE YOUR PERSONAL DATA
When you interact with us we will 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, including our online shop, signing up for Newsletters, creating accounts with us, contacting us etc. We also use your personal data to evaluate and assess your personal interests and preferences in order to personalize your website experiences and improve our services and offer you services better customized to your interests and preferences.
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 (e.g. signing up for a newsletter, creating an account or making a purchase through our online shop etc.).
To help personalise and continuously improve our services and communication with you, for instance through our newsletters, we may upon occasion ask you for information on your personal interests, demographic data or your experience of our products and services. This supplementary information is always voluntary, but we appreciate your support in providing it.
How we collect and use your personal data depends on how you interact with us, and which services you make use of.
We, like all other ECCO Affiliates, strongly believe in the protection of the personal data in our custody and control, and thus we have implemented what we believe are appropriate technical and organisational 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 collect and process your personal data in different situations, 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.
2.1. Cookie Information
This website uses 1st and 3rd party cookies and similar technologies to optimize your user experience, and for statistical and marketing purposes. Read more about the cookies and how you can administer and reject these in our Cookie Information on the website.
2.2. When signed up for newsletters.
You have the opportunity to sign up to receive information by e-mail about AT.KOLLEKTIVE’s products (leather, shoes, bags, clothing, leather goods and related accessories) services, events, collaborators, contests and promotions (“Newsletters”).
We will only send you newsletters and other marketing material if you have specifically consented to receive newsletters from us.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data for when you are signed up for a newsletter:
Registration, checking the validity of the e-mail and providing you with relevant Newsletter
- The personal data we process for this is the information that you have provided to us when signing up for the newsletter:
• First name
• Last name
• E-mail address
- The legal basis for this processing is GDPR art. 6(1) a), namely the consent you have granted, when signing up to receive Newsletters.
Tracking of newsletters to perform general marketing research and to optimize the distribution and use of newsletters
- The personal data we process for this is:
• Tracking pixels* (included in the newsletter)
*A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, we may see if and when an e-mail was opened by the recipient, and which links in the e-mail were called up by the recipient.
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
General marketing research and to tailor or improve our websites and our service offerings
- The personal data we process for this is the information listed above in this section. We may also link this data to other personal data we have about you for profiling purposes in order to be able to personalize your website experiences, adapt the content of future Newsletters to better suit to your interests and to provide you with personalized offerings. Please also refer to SECTION 2.6 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
2.3. When using our online AT.KOLLEKTIVE shop
We offer you the opportunity to make purchases of AT.KOLLEKTIVE products through our online shop.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you make or take steps to make a purchase on this website or any of our other websites:
Completing the purchase and delivery of the purchased items to you
- The mandatory personal data you provide to us when making a purchase is:
• First name
• Last name
• E-mail address
• Shipping address
• Billing address
• Details of the purchased items
• Other information necessary for the purpose of completing the purchase and delivery of the purchased items to you
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Managing payments on this website
- The personal data we process for this is:
• First name
• Last name
• Shipping address
• Billing address
• Transactional data
• E-mail address
• IP address
• Phone number
• Mobile phone number
• Other data necessary for payment processing
- For the purpose of managing payments on this website, we have integrated components of the following online payment service providers:
• Mollie B.V., The Netherlands (Please read more about their processing of your personal data here: https://www.mollie.com/privacy)
• PayPal (Europe) S.à r.l. et Cie, S.C.A, Luxemburg (Please read more about their processing of your personal data here: https://www.paypal.com/myaccount/privacy/privacyhub)
(Hereinafter referred to as the “Online Payment Service Providers”).
When having selected the relevant payment method, we automatically transfer personal data to the relevant Online Payment Service Provider, which is necessary for payment processing.
- You will provide your credit card details directly to the Online Payment Service Provider, who will then further transfer necessary data to the relevant credit card agencies for identity and creditworthiness checks and payment clearance.
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
Managing return request and returning money
- If you return any purchased items to us, then we process the following personal data:
• First name
• Last name
• E-mail address
• Shipping address
• Billing address
• Details of the purchased items
• Reason for return of purchased item
- The Legal basis for this processing is GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party and GDPR art. 6(1) f), namely our legitimate interest in providing customer services.
General marketing research and to tailor or improve our websites and our service offerings
- The personal data we process for this is the information listed above in this section. We may also link this data to other personal data we have about you for profiling purposes in order to be able to personalize your website experiences, adapt the content of future Newsletters to better suit to your interests and to provide you with personalized offerings. Please also refer to SECTION 2.6 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
2.4. When contacting us
You may always contact us or e-mail us with comments, or questions or in case you have a complaint.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you decide to contact us:
Managing your request
- When you contact us with comments or questions we will retain and use the following information in order to respond to your request:
• First name
• Last name
• E-mail address
• Phone number
• Country of residence
• Other information, which might be needed to reply to your request
- It is always optional for you what information you chose to provide us with. However, please note that in case we do not have sufficient information to process your request, then it may have as a consequence, that we will not be able to accommodate your request.
- The Legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interests in providing customer services, understanding customer behaviour and interests and establishing, exercising and/or defending legal claims.
Managing complaints
- When you contact us with a claim we will retain and use the following information in order to respond to your claim:
• First name
• Last name
• E-mail address
• Phone number
• Country of residence
• Information about the claim
- The legal basis for this is GDPR art. 6(1) f), namely our legitimate interest in handling claims and provide customer service.
- If needed for establishing, exercising or defending the claim we may also request other information, including:
• Health data
• Biometric data
• Other special categories of data, if relevant for the claim.
- The legal basis for this is GDPR art. 6(1) f), namely our legitimate interest in establishing, exercising or defending legal claims. The exception that applies to our processing of special categories of data is GDPR art. 9(2) f), namely that the processing is necessary for the establishment, exercise or defence of legal claims.
2.5. When participating in competitions, product reviews and surveys etc.
Occasionally we may give you the opportunity to participate in competitions, make product reviews or surveys etc. If you choose to participate, then we will be asking you to provide us with certain data.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data if you decide to participate in a competition, product review or survey:
Running competitions and surveys
- The personal data we collect, and process depends on the specific competition or survey etc., but it might include:
• First name
• Last name
• E-mail address
• Age
• Gender
• Family information
• Shoe size
• Other demographic information
• Information about your interests and purchasing preferences
- It is always optional for you if you want to participate in a competition or answering a survey and thus it is always optional what information you chose to provide us with. But please be aware that providing specific data may be mandatory and to the extent you will not provide such data you cannot participate in the competition or survey.
- The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when choosing to participate in the competition or survey and/or GDPR art. 6(1) b), namely that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Conducting product reviews
- We may from time to time ask you to provide your feedback about products you have acquired from us. If you participate in a product review, we collect and process the following personal data:
• First name
• Last name
• E-mail address
• Age
• Gender
• Nationality
• Shoe size
• Other demographic information
• Data collected through the use of our websites
• Transactional data
• Information about your interests and purchasing preferences
• Image and video recording of you
• Your opinion about our products
- It is always optional for you if you want to participate in a product review and thus it is always optional what information you chose to provide us with. But please be aware that providing specific data may be mandatory and to the extent you will not provide such data you cannot participate in the product review.
- The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when choosing to participate in the product review.
General marketing research and to tailor or improve our websites and our service offerings
- The personal data we process for this is the information listed above in this section. We may also link this data to other personal data we have about you for profiling purposes in order to be able to personalize your website experiences, adapt the content of future Newsletters to better suit to your interests and to provide you with personalized offerings. Please also refer to SECTION 2.6 (PROFILING FOR MARKETING PURPOSES).
- The legal basis for this processing is GDPR art. 6(1) f), namely our legitimate interest in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
2.6. Profiling for marketing purposes
In ECCO we want to better understand our customers to ensure we provide an experience that is relevant to the customer and to ensure effective marketing and advertisement of ECCO product and services. To better understand our customers and to personalise the experience of our newsletter recipients and website visitors we perform general marketing research incl. customer analysis and customer segmentation and statistics.
If you have identified yourself to us, for example by making a purchase, creating an account or by giving us your name, e-mail address or phone number, then we may link the personal data we have collected about you as per above sections.
If you disagree and want to object to this, please contact us in accordance with the SECTION 1 “OUR CONTACT DETAILS”, and we will then cease to use your personal data for profiling for marketing purposes.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use data for when profiling our customers:
General marketing research incl. customer analysis and customer segmentation and statistics
- The personal data we process for this is:
• First name
• Last name
• E-mail address
• Phone number
• data collected through the use of our websites
• Newsletter-Tracking Data
• addresses
• information from you concerning demographics, interests and preferences (e.g. product preferences etc.)
• Transactional Data incl. abandoned shopping baskets, returns and other personal data derived from the interactions you have with us.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests, namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
Personalize your shopping and website experiences and optimizing the service you receive
Furthermore, we may use the information listed above in this sections to evaluate and assess your individual interests and preferences in order to personalize your shopping and website experiences and optimizing the service you receive from us and our affiliates.
- The legal basis for this is GDPR art. 6(1) f) our legitimate interests namely in understanding customer behaviour and interests and ensuring effective marketing and advertisement of ECCO product and services.
Customizing newsletter content and special offers
If you have signed up to receive Newsletters, then we will also use your personal data in order to adapt the content of Newsletters to better suit your interests and to provide you with personalized offerings. The Legal basis for this is GDPR art. 6(1) a) namely the consent you have granted, when signing up to receive Newsletters.
2.7. Online Marketing and re-targeting
When entering our website and to the extent you have given us your consent to place cookies on your device, we will be using cookies and similar technologies to track your activities on our website and use your information to target advertising to you across different channels and devices.
If you have identified yourself to us, for example by making a purchase, creating an account or by giving us your name, e-mail address or phone number, then we may also use the personal data we have collected about you as per above sections.
If you disagree and want to object to this, please contact us in accordance with the SECTION 1 “OUR CONTACT DETAILS”, and we will then cease to use your personal data for profiling for marketing purposes.
Below you can read more about the types of personal data and the legal basis for the different purposes that we use for online marketing and re-targeting:
Online marketing and re-targeting
- The personal data we process for this is:
• E-mail address
• Data collected through the use of our websites,
• Newsletter-Tracking Data,
• information from you concerning demographics, interests and preferences (e.g. gender, birth date, shoe size, family situation, product preferences etc.),
• Transactional Data incl. abandoned shopping baskets, returns and other personal data derived from the interactions you have with us.
- The legal basis for this is GDPR art. 6(1) a) namely the consent you provide when you accept our use of cookies.
3. HOW WE SHARE YOUR PERSONAL DATA WITH OTHERS
In order to make our services available to you, 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 suppliers, marketing agencies, logistics service providers, payment service providers etc.
When using data processors to process your personal data on our behalf 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 organisational 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.
3.1. Categories of Recipients
The main categories of potential recipients of your personal data are:
A. Service Providers acting as data 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 websites, manage our payment solutions, perform statistical analysis, sending newsletters, provide customer support 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 logistic service providers, payment service providers and our external auditors.
C. Third party advertising partners like Facebook, Google and TikTok
We use third party advertising partners to collect information about your use of our website in order to serve targeted advertising and to measure the performance of our advertising campaigns. The third party partners we use may collect this information using tracking technologies, such as pixels, cookies, APIs and SDKs.
Facebook (Meta): You can read more about how Facebook Ireland processes your personal data in their Data Policy at https://www.facebook.com/about/privacy.
Google: You can read more about how Google uses information shared with them here: https://policies.google.com/technologies/partner-sites
TikTok: You can read more about how TikTok uses information shared with them here: https://www.tiktok.com/legal/privacy-policy-eea?lang=en.
D. Other ECCO Affiliates
We may disclose your personal data to other companies, which are owned or controlled by ECCO Sko A/S or owns or controls ECCO Sko A/S or under common control with ECCO Sko A/S (“ECCO Affiliates”) in order for them to provide us with relevant services.
E. 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.
F. 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 defence of legal claims.
3.2. Transfer of data to third countries
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 States, Canada, China, 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”, through the adherence to standard data protection clauses adopted by the EU Commission cf. the GDPR article 46(2). Please refer to the following link to obtain more information about the standard data protection clauses we use here.
If you have any questions, please contact our Customer Care representatives in accordance with SECTION 1 (OUR CONTACT DETAILS).
4. HOW WE RETAIN AND DELETE YOUR DATA
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 anonymise 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 AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE).
5. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE
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. However, you can find a summary of your rights, if you unfold below sections.
5.1. The right to access
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.
5.2. The right to rectification
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.
5.3. The right to erasure
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.
5.4. The right to restriction of processing
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 defence of legal claims; iii) for the protection of the rights of another natural or legal person; or iv) for reasons of important public interest.
5.5. The right to data portability
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.
5.6. The right to object
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 defence 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.
5.7. The right to withdraw consent
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.
5.8. The right to complaint to data protection supervisory authority
You may always lodge a complaint with your local data protection supervisory authority. The data protection supervisory authority in Denmark is
Datatilsynet
Carl Jacobsens Vej 35
2500 Valby
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.
You can always withdraw from a consent to receive newsletters etc. and unsubscribe from an e-mail list by following the instructions in any e-mail or other communication you receive from us.
If you have created an account with us, then you can also manage and delete your account by logging into the account and administer your account.
6. LINKS TO OTHER WEBSITES
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.
7. CHANGES TO THIS PRIVACY POLICY
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 Affiliates 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.
You can always find the updated version of our Privacy Policy at atkollektive.com
If you have consented to receive newsletters and other information from us, we will also inform you directly about any updates to this Privacy Policy through e-mail.