TABLE OF CONTENTS
1. Scope of Privacy Policy
This Privacy Policy applies to information that Foot Locker Inc. d/b/a Foot Locker (referred to herein as “Foot Locker,” “Company,” “we,” “us” or “our”) collects, uses, shares or otherwise processes that identifies, describes, relates to, or can otherwise be associated with individuals (individually and collectively referred to herein as “you”, “your and “yours”) (“Personal Information”) in connection with the following customer facing operations in the United States and Canada (individually, “Service” and collectively, “Services”):
This Privacy Notice provides you details about the Personal Information we collect, use, share or otherwise process, the purposes for which we use that Personal Information to whom and for what purposes we may disclose that Personal Information, how we protect that Personal Information, the rights and choices you have with respect to that Personal Information, and how you can reach us to get answers to your questions
The Website and/or Services may contain links to other websites, applications and services maintained by third parties. The privacy and data protection practices of such third parties are governed by the privacy policies of those organizations. Please review the privacy policies of those organizations to better understand their privacy practices.
2. Collection of Personal Information
A. Personal Information That You Provide
When you use the Services, you may provide us with Personal Information about you. This may include your name, email address telephone number, mailing address and other personal information. When you use the Services, we may also collect information related to your use of the Services and aggregate this with information about other users. This helps us improve the Services and your experience with them. In addition, when you use the Services, we may also collect the Personal Information.
Depending upon our relationship with you, we may collect the following categories and types of Personal Information from and about you:
Categories of Personal Information We Collect
Examples of Personal Information Collected
Categories of Sources of Personal Information
Business Purpose for Collection of Personal Information
Identifiers
Name, profile data, social media account, IP address
Directly from You or Your use of the Services; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
Contact/Registered User Account Information
Email Address, Home Address, Billing Address, Phone Number
Directly from You or Your use of the Services; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communicating with You, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
Commercial Information
Transaction data including products and/or services offered, considered, or purchased
Directly from You or Your use of the Services; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
Financial Data/Payment Information
Credit card or other financial account information
Directly from You or Your use of the Services; Third Parties (such as affiliates, agents, service providers and other users)
Improving and Providing the Service, Identification, Communications, Security, Legal, Compliance and Regulatory Obligations
Internet or Other Network or Device Activities Including Information from Cookies
Unique device and app identifiers, browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to the service, the search terms you entered into a search engine that led you to the service, areas within the service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites
Directly from You or Your use of the Services; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
Approximate Geolocation Information
Your approximate location
Directly from You or Your use of the Services; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
Platform Communications
Communication Information (e.g., your name, contact information, and the contents of any messages you send)
Directly from You, Your use of the Services, and users with whom you communicate
Providing the Service, Security, Legal, Compliance and Regulatory Obligations
With your consent, the contents of any messages you send may be used to Develop and Improve the Service
Other information that identifies or can be reasonably associated with you
User-generated content, (e.g., feedback, ratings and job postings), information on work previously performed via the service and outside the service
Directly from You or Your use of the Services; Service Providers; Third Parties (such as affiliates, agents, and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations
B. Non-Identifying and De-Identified Information
C. Personal Information We Collect From Other Sources
We also collect Personal Information about you from other sources including third parties from whom we have purchased business contact information and from public databases, publicly accessible websites, such a, social media platforms, which we may combine with Personal Information that you have provided to Foot Locker. Such Personal Information may include, without limitation, phone numbers, mailing addresses, email addresses and Personal Information available at public facing websites and/or social media profiles. Please note that publicly available information is not considered Personal Information in some jurisdictions.
In addition, in connection with your use of the Services, you may be interacting with third party artificial intelligence and large language model tools including, without limitation, ChatGPT. ChatGPT is an artificial intelligence program that generates dialogue by using machine learning algorithms to process and analyze large amounts of data to generate responses to user inquiries. We are not responsible for any information that you provide and/or otherwise disclose to ChatGPT, and we have no control over the manner in which ChatGPT uses or shares information. Prior to disclosing or communicating any personal information utilizing the Services, in addition to reviewing the policies set forth herein, you should also review ChatGPT’s privacy policy at https://openai.com/policies/privacy-policy/.
D. Personal Information Collected Automatically
E. Children.
The Services are general audience and intended for users thirteen (13) years and older. We do not knowingly collect Personal Information from anyone younger than age thirteen (13). If we become aware that a child younger than thirteen (13) has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age thirteen (13) and believe that Foot Locker has collected Personal Information from your child, please contact us at: [email protected].
3. How We Use the Personal Information
A. How We Use the Personal Information
We use information including Personal Information collected through the Services to provide and improve the Services, develop new services and products, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent. We use the information we collect for the following purposes:
4. Sharing and Disclosing Personal Information
We do not sell your Personal Information for monetary consideration, and we do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. However, we may use technologies on the Services for the purposes of advertising or marketing to you and understanding how you interact with our ads. This may be considered a “sale” or “sharing” of personal information for targeted advertising under applicable data protection laws. We may also share information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or for the following business or commercial purposes:
A. Disclosure of Personal Information
Foot Locker may disclose Personal Information and other information as follows:
B. Disclosure of Personal Information As Required by Law, Acquisition or Merger
We may disclose your Personal Information if we are required to do so by law or we, in good faith, believe that such action is necessary to: (i) comply with the law or with legal processes; (ii) protect and defend our rights and property; (iii) protect against misuse or unauthorized use of the Websites and/or Services; or (iv) protect the safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions).
If Foot Locker goes through a business transition, such as a merger, acquisition, or sale of all or a portion of its assets, your Personal Information may be among the assets transferred.
C. Aggregate or De-Identified Information
We may disclose aggregate, or de-identified information about users for marketing, advertising, research, compliance, or other purposes.
5. Your Privacy Choices and Rights; Accessing and Managing Your Personal Information
You may have certain choices and rights associated with your personal information, including opting out of targeted advertising or other disclosures to third parties. Residents of certain locations may have the right to have an authorized agent submit requests on your behalf. You or your authorized agent may request that Foot Locker honor these rights by contacting us as outlined in the “Contact Us” section below, or submitting a request here. Depending on your location, you may also opt out of targeted advertising here.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights.
Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.
A. California Residents
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their personal information. This section does not apply to our handling of information that is exempt under the CCPA such as publicly available information, de-identified or aggregated information or information that is covered under another law such as the Health Insurance Portability and Accountability Act (HIPAA) or the Fair Credit Reporting Act (FCRA). Where we have committed to maintaining and using Personal Information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.
Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:
Our business or commercial purpose for collecting or “selling” your personal information as defined by the CCPA.
The categories of third parties to whom we have sold or shared your personal information, if any, and the categories of personal information that we have shared with each third-party recipient.
Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the “sale” or “sharing” of their personal information as defined by the CCPA by clicking here or by contacting us using the information in the “Contact Us” section below.
Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18.
Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below.
Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA.
Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.
Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
B. Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Texas, Utah and Virginia Residents
If you are a resident of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Texas, Utah or Virginia, you have certain rights related to your Personal Information. If you or an authorized agent wish to exercise these rights, you can submit a request using the methods listed below. There may be situations where the Company cannot grant a request, for example to complete a transaction to you or comply with law. These options do not apply to publicly available information from government records nor to deidentified or aggregated information.
Depending on your state of residence, you may have additional rights related to opt-out of the “Sale” of Personal Information to unaffiliated third parties and the right to opt-out of Targeted Advertising (as those rights are defined in the applicable state laws).
Process to Submit an Opt-Out of “Sale” or “Targeted Advertising”: There are two separate processes to follow in order to request to be opted out of “Sale” or Targeted Advertising:
For opting-out of Sale or Targeted Advertising Tracking Technologies, you can update your preferences at any time by either (a) updating your preferences by clicking the Your Privacy Choices at the footer of the Website, at any time, or (b) broadcasting a legally recognized opt-out preference signal, such as the Global Privacy Control (GPC) (when accessing the Website via the browsers and/or browser extensions that support such signals).
For opting-out of “Sale” or Targeted Advertising activities based on Personal Information collected by us (e.g. activity related to shopping in store or on the Website, participating in promotional or marketing activities, creating an account on the Website, registering to receive email communications from us, etc.), please submit a request using the Opt-Out of Sale/Targeted Advertising Request Form.
E. For Residents Located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland
If you are a resident located in the EEA, United Kingdom or Switzerland, you have a number of rights under applicable data protection laws in relation to your Personal Information including the following rights under certain circumstances:
You can make a request to exercise any of these rights in relation to your personal data by contacting us as indicated below at “Contact Foot Locker “.
You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click the following link for a list of local data protection authorities in the EEA countries: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. In the UK, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO) about the processing of your Personal Information.
F. For Residents Located in Canada
The following apply to residents located in Canada:
Other exceptions may apply. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker. Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify us that you do not wish your Personal Information collected/used/disclosed for various purposes after you have received notice of those purposes) or otherwise. You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to us. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include the inability of us to provide portions of the Website or other services for which that information is necessary.
G. For Residents of Australia and New Zealand
Storing and disclosing your Personal Information
Residents of Australia and New Zealand accessing and using the Website are notified that your Personal Information may be held and processed overseas. Overseas countries where your data may be stored include the United States and other locations where the Company has operations. When we pass on or share your Personal Information in this way, we take steps to ensure it is treated in the same way that we would treat it and we comply with applicable law. Where reasonably possible, we seek to work with information and records from which Personal Information has been removed.
Your Personal Information – Your Rights
For example, when you place an order on our Website, we use Secure Socket Layer (SSL) technology, an encryption tool that provides security while transmitting information over the Internet. We also use firewall technology, password controls, and other technological and procedural safeguards in respect of your online interactions with the Company.
We evaluate our privacy safeguards on an ongoing basis to help minimize risks from new security threats as they become known. Although we have implemented the above security measures, we note that 100% guaranteed security is not possible for any company.
Requests for access to your Personal Information and complaints about privacy
You may wish to contact us to request access to your Personal Information, to seek to correct it or to make a complaint about privacy. Our contact details are set out below.
We will respond to your request for access to Personal Information we hold about you as soon as we reasonably can, including if we are unable to provide you with access (such as when we no longer hold the information).
We do not impose any charge for a request for access, but we may charge you a reasonable fee for our costs associated with providing you with access and retrieval costs.
For complaints about privacy, we will establish in consultation with you a reasonable process, including timeframes, for seeking to resolve your complaint.
Complaints
Australian Residents: If you believe that we have violated any of the Australian Privacy Principles, you can contact us at the addresses listed above. We will investigate your complaint and try to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Australian Information Commissioner, https://www.oaic.gov.au/.
New Zealand residents: If you believe that we have violated the Privacy Act 2020, you can contact us at the addresses listed above. We will investigate your complaint and try to resolve any issue to your satisfaction. If we do not adequately answer your concerns, you will have the right to make a complaint in writing to the Office of the Privacy Commissioner, https://www.privacy.org.nz/
6. Additional Privacy Info
A. Security
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any Personal Information we process. However, despite our safeguards and efforts to secure your Personal Information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your Personal Information. Although we will do our best to protect your Personal Information, transmission of Personal Information in connection with the Services is at your own risk. You should only access the the Services within a secure environment.
You should take steps to protect against unauthorized access to your password, mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust and unique password for each account that nobody else knows or can easily guess, and keeping your log-in and password private. You are responsible for maintaining the security of your password or other form of authentication involved in accessing password-protected or secured resources. In order to protect you and your information, Foot Locker may suspend your use of the Services without notice, pending an investigation, if any suspicious activity or security breach is suspected. We are not responsible for any lost, stolen, or compromised passwords or for any unauthorized account activity that may result.
B. Changes to This Privacy Statement
We reserve the right to change or update this Privacy Policy at any time. Changes to the Privacy Policy will be posted at this URL. We encourage you to periodically review this Privacy Policy for any changes.
C. Data Retention
We will retain your Personal Information as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, subject to certain exceptions as described to you and/or allowed by law. Other third parties may have different practices, and you should refer to their privacy policies.
We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or other lawful basis.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, compliance or other requirements.
We may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes and use this information indefinitely without further notice to you.
D. Information Processing in the U.S. and Other Countries
Your Personal Information and other information may be stored, transferred and processed by us in the United States and in other countries by our affiliates or our service providers. By providing Personal Information to us, you consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, pursuant to the laws of the United States or such other jurisdictions, which may provide lesser privacy protections than the laws of other countries, and you acknowledge that your information may thus be subject to U.S. and foreign laws and accessible to U.S. and foreign governments, courts, law enforcement and regulatory agencies.
7. Contact Foot Locker
A. Updating Your Choices
If you have any questions regarding this Privacy Policy, or if at any time after providing your Personal Information to Foot Locker, you want to change your Personal Information, or if you would like to assert any of the rights listed above, please direct your request to [email protected].
B. Foot Locker Contact Information
You may reach our Data Privacy Officer at [email protected].