Throughout our website we may link to other websites owned and operated by us and certain trusted third parties to make additional products and services available to you. Those other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.
To help guide you through this policy, we have set out the relevant information in the chapters below:
Article 1 – Contact details Steve Madden Europe B.V. (Data Controller)
Article 2 – Processing of personal data
Article 3 – Purposes and legal bases for processing of personal data
Article 4 – Retention of personal data
Article 5 – Security of personal data
Article 6 – Disclosure of personal data
Article 7 – International Transfers of Personal Data
Article 8 – Data subject rights
1. CONTACT DETAILS STEVE MADDEN EUROPE B.V. (DATA CONTROLLER)
Steve Madden Europe B.V. is the Data Controller. You can contact us via our postal or email address.
Steve Madden Europe B.V.
5253 RK Nieuwkuijk
Email address: firstname.lastname@example.org
Dutch Chamber of Commerce number: 66152925
Dutch VAT identification number: NL856417580.B.01
Steve Madden Europe B.V. is part of the multinational Steve Madden group.
2. PROCESSING OF PERSONAL DATA
Steve Madden Europe processes several types of personal data.
Personal data is any information that relates to an identified or identifiable individual, for example, a name, an email address, a phone number and an IP address.
The types of personal data collected and processed can differ, depending on the services you use and the purposes for which processing of your personal data is required.
We directly collect the below types of personal data directly from you when you use our services, including when buying our products:
a. Identifiers and Contact data: for example, your name, contact details (such as postal, mailing, billing and/or shipping address, postal code, email address, phone number), date of birth, gender;
b. Preferences: for example, historical product purchases (including returns or orders cancelled), shoe and/or apparel size, preferred language, interests, feedback and survey data;
c. Marketing data: for example, your consent for the use of our marketing and retargeting cookies and similar technologies;
d. Financial data: for example, your bank account and payment card details;
e. Order information: for example, order (tracking) number, order status and history, sales order information, invoice and shipping address, bank account information, purchase history; and
f. Communications data: for example, (transcripts of) phone calls and electronic communications with Steve Madden Europe’s customer service department.
a. Identifiers: for example IP-addresses, geolocation data and cookie ID;
b. Preferences: for example, your preferred language, your order as you shop on Steve Madden Europe’s website(s), list of friends, interests and likes;
c. Online or other electronic network activity data: for example, your online interaction with Steve Madden Europe’s website(s), browsing history and search history, online behavior patterns, preferences and location, IP address, geolocation data, data concerning your computer or other electronic device, operating system and internet service provider;
d. CCTV footage (images) when you visit Steve Madden Europe’s premises at Touwslager 12, 5253 RK in Nieuwkuijk, the Netherlands.
We can also indirectly collect personal data about you which we receive from other sources, depending on the channels (for example, social media networks) you use for our services:
a. Identifiers and Contact data: for example, your name, contact details, date of birth, gender, place of residence;
b. Preferences: for example, your preferred language, list of friends, interests and likes;
c. Marketing data: your consent for the use of third party marketing and retargeting cookies and similar technologies. For more information, please read the Cookies Policy.
For information on the collection and processing of personal data by the third party providers of the channels you use, please consult their respective privacy policies.
3. PURPOSES AND LEGAL BASES FOR PROCESSING OF PERSONAL DATA
We collect, use, store and transfer your personal data for specific purposes. Also, we have to ensure there is a lawful basis for such processing. The purposes for processing and the individual lawful bases for processing your personal data are set out below:
- To process and fulfil your order: this includes processing and delivering your order, contacting you concerning the status of your order or any other information related to your order which ought to be communicated with you. Processing of Identifiers, Contact and Financial data for this purpose is necessary for the performance of the contract you have with Steve Madden Europe. Without the personal data required we cannot be fulfil the contract which may include delivering your order.
- To provide you with customer service: in order to answer your questions and/or requests, to communicate with you with regard to your purchase(s) and to solve any possible issues that could arise or have arisen with regard to your purchase(s). We have a legitimate interest to ensure that we can handle your request in a way that meets your expectations. The processing of your Identifiers and Contact data, Order Information and Communications data is necessary for this purpose.
- To allow you to create a personal account: when you shop at Steve Madden Europe, you can register your personal data (including but not limited to Identifiers and Contact data) and create a personal account. Such registration is not required. It does, however, provide you with a quick and simple checkout experience. Steve Madden Europe processes your personal data for this purpose based on your consent. Please note that you can always withdraw your consent by deleting your personal account. You can do so via the settings of your account upon logging in to the account.
- To be able to provide you with newsletters and customized content (for example in advertisements): in order to send you future emails and/or text messages about your orders, abandoned checkouts, new releases, exclusive offers, promotions, news, surveys, initiatives and events and to provide you with specific content based on your preferences and interests via advertisements we process Identifiers and Contact data, Preferences, Marketing and Online or other electronic network activity data. If you have opted in to receive such messages and customized content, Steve Madden Europe processes your personal data for this purpose based on your consent. Steve Madden Europe may also process your personal data for this purpose based on its legitimate interest to provide its customers with direct marketing when applicable.
How to stop newsletters and customized content being sent to you? You can always withdraw your consent or object to receiving any direct marketing by using the unsubscribe link at the bottom of every Steve Madden Europe newsletter or sending a STOP message in reply to our text messages. You can also contact us at email@example.com and provide us with your specific request. Your request will be actioned and we will ensure that you will receive no further marketing emails or text messages from that email or text message going forward. You can also change your communication and/or cookies and other technologies preferences in the settings in your personal account or browser. We may ask you to confirm or update your marketing preferences if you ask us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
- To enable you to take part in the competitions we host (among others, via our social media accounts): in order for you to be able to take part in a competition hosted by Steve Madden Europe and in order to provide you with any relevant information with respect to such competitions. Steve Madden Europe processes Identifiers and Contact Data for this purpose based on your consent.
How to stop taking part in competitions? Typically, you can take part in competitions we host by reposting one of the posts we did on our social media account announcing a competition on your own social media account and providing any requested (additional) information. You can withdraw your consent and thus stop taking part in competitions by deleting your repost.
- To effect a significant corporate transaction or restructuring: we may need to share your Identifiers or Contact data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency to ensure compliance with laws or for our legitimate interest or those of a third party to protect, realise or grow the value in our business and assets. Information will be anonymised where possible and only shared where necessary.
- To comply with requests from regulators or other official bodies of authority, and for litigation case management and evidentiary purposes: Steve Madden Europe may process all of the above types of personal data if necessary to comply with a valid request from a regulator or other official body of authority, or where it is relevant to any ongoing or prospective legal proceedings. Steve Madden Europe processes your personal data for this purpose to ensure compliance with laws, and based on its legitimate interest to manage legal proceedings and to defend Steve Madden Europe against any possible civil claims or regulatory enforcement action.
- To ensure the safety and security of our employees and third parties, our property, the property of our employees and that of third parties through the use of CCTV-footage: We process CCTV-footage (which may contain your images) based on our legitimate interest to protect our employees and visitors, our property and the property of our employees and visitors, to ensure safe and secure access to the premises and record incidents.
- To protect the security of systems and data: we have a legitimate interest to comply with our legal and regulatory obligations. We may use your Online or other network activity data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, and to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us.
4. RETENTION OF PERSONAL DATA
Steve Madden Europe does not retain your personal data longer than necessary for the purposes for which your personal data were collected. The retention period may differ for each (category of) personal data. Taking into consideration all our legal obligations to retain information for contract, audit and tax purposes, we will also regularly review the length of time we retain your personal data and consider the purpose or purposes for which we hold it.
Generally speaking, Steve Madden Europe does not retain your personal data for longer than 7 years after having collected it.
Among others, due to applicable tax laws, Steve Madden Europe retains any (personal) data required for financial administration for seven years.
Personal data necessary for the processing and fulfilment of your order and for providing you with customer service in connection with a purchase are also retained by Steve Madden Europe for the duration of seven years after the purchase is made.
Any personal data processed of individuals acting in their professional capacity as representatives and/or contact persons of a vendor or other relevant third party company are retained by Steve Madden Europe for as long as necessary for the performance of the respective contract between Steve Madden Europe and this third party and until seven years after the termination of the contract or collaboration.
Any CCTV footage is retained for the duration of four weeks. If an incident is captured with this footage, the footage will be retained until the incident is resolved but in any event this retention will not exceed any period of retention required by law.
5. SECURITY OF PERSONAL DATA
Steve Madden Europe has implemented the necessary and appropriate physical, organizational, administrative and technical security measures to protect your personal data against unlawful access, loss, misuse or alteration. Steve Madden Europe has taken a variety of security measures in this respect, including the use of secured servers and firewalls. In order to safeguard your transactions, Steve Madden Europe uses a secure (SSL) connection for encrypting, sending and receiving critical information such as your Financial data. Steve Madden Europe is committed to keeping its security technology continuously updated.
Additionally, Steve Madden Europe has an internal privacy and security policy and our staff is aware and ensures that your personal data is handled securely and confidentially. Steve Madden Europe’s systems are only accessed by authorized staff who require access for the performance of their work using (building) access controls and passwords. Personal data is only made available internally as required in connection with the relevant purpose.
6. DISCLOSURE OF PERSONAL DATA
Where permitted or required by law, Steve Madden Europe may – for example if necessary within the context of conducting its business or in order to comply with legal obligations – disclose your personal data to third parties. If your personal data is disclosed to third parties, this is limited to the personal data that is strictly required for the purpose, and done safely and securely.
Steve Madden Europe may disclose your personal data, for example, to other Steve Madden entities (both those established and located in as well as outside the EEA), to vendors or to payment processors, to the extent that this is necessary for the performance of a contract with you. We may do so when this is required for Steve Madden Europe’s legitimate interests to improve its services, disclose your personal data to other Steve Madden entities and vendors, and we may disclose your personal data to advertising partners for marketing purposes based on your consent or our legitimate interests to provide you with customized content, targeted offers and advertising. If Steve Madden Europe, or substantially all of its assets, were acquired, or in the unlikely event that Steve Madden Europe goes out of business or enters into bankruptcy, your personal data would be one of the assets that can be shared with a prospective buyer, and transferred to that third party buyer upon sale.
Furthermore, Steve Madden Europe may disclose your personal data with the aim of preventing fraud or for litigation purposes. In case of a valid request from a regulator or other official body of authority, Steve Madden Europe will disclose your personal data if necessary in order to comply with the law or in order to protect its rights, and to protect your safety and the safety of others.
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
Among others, depending on the computer systems utilised or the third party providers supporting a processing activity, your personal data may be transferred to organizations and stored in countries outside of the United Kingdom (UK) or European Economic Area (EEA). Such transfers of personal data to organizations in countries outside the UK or EEA take place in accordance with the Data Protection Laws and are necessary, among others, in order to perform the contract with you, for transaction processing, fraud prevention, to operate Steve Madden Europe’s business and analyze, develop and improve its services as well as for marketing purposes, in order to provide you with customized content, targeted offers and advertising.
As we are based in the EEA we will transfer your personal data from the UK to the EEA.
Under the Data Protection Laws, we can only transfer your personal data to a country outside the UK/EEA where:
the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the UK GDPR. A list of the countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to, among others, The Netherlands,
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
a specific exception applies under relevant data protection law.
Steve Madden Europe has appropriate contractual arrangements in place with relevant third party providers and other third parties to ensure that in the case of such transfers of your personal data to countries outside of the UK or EEA, your personal data is protected to the same high standard as required under the UK GDPR and Data Protection Act 2018.
8. DATA SUBJECT RIGHTS
You have several rights regarding the processing of your personal data. You have the right:
- To withdraw consent: If you have consented to receive any marketing material from us or have engaged in any other activity with us for which we have asked you for your consent, you have the right to withdraw your consent at any time. You can withdraw your consent for receiving any direct marketing by using the unsubscribe link at the bottom of every Steve Madden Europe newsletter or sending a STOP message in reply to our text messages (please note you are advised to reply to the latest text message received). You can also change your communication and/or cookies and other technologies preferences or withdraw your consent for any other activity in the settings in your personal account or browser.
- Of access to your personal data: you have the right to see a copy of the personal data that we keep about you, subject to certain exemptions.
- To rectify inaccurate or incomplete personal data: you can ask us to correct any data which is inaccurate or incomplete.
- Of erasure of your personal data: you can ask us to delete your personal information (with the exception of us being required to keep it to comply with a legal obligation).
- To restrict processing of your personal data: we will retain enough information to enable the restriction but will not process any further personal data, until and unless we lift the restriction (of which you will be informed).
- To object to processing of your personal data: you can stop or prevent us from using your data (in cases where we are using it with your consent or for our legitimate interests).
- To move, copy or transfer your personal data (data portability): please contact us if you would like us to transfer your personal data electronically to another organisation.
Please note that the above mentioned rights, with the exception of the right to withdraw your consent (in general) and to object to processing of your personal data (for the purpose of direct marketing), are not absolute. Under certain conditions, we may refuse to comply with your request to exercise the above mentioned rights. If we refuse to honor your request, you will be informed of the reasons for refusal.
If you have any questions or complaints about the way we have handled your personal data, or if you wish to exercise any of the abovementioned rights, please contact: firstname.lastname@example.org. For further information on how to contact us, please see Article 1.
In addition to the above mentioned rights, you always have the right to submit a complaint about the processing of your personal data by Steve Madden Europe to the Information Commissioner’s Office (ICO) which regulates the processing of personal data in the United Kingdom. Their contact details can be found on their website www.ico.org.uk.