Privacy Policy

Important Information

This Privacy Notice aims to give you information about how we collect and process your personal data when you use the website or app this Privacy Notice is linked to. This Privacy Notice covers any personal data you provide when you create an account, purchase a product or otherwise interact with us, you have agreed to the collection and processing of your personal data as prescribed by the terms of this Policy Notice.

We want to make sure you know who we are, how you can contact us, the personal data we process, how we use it, who we share it with, how long we keep it for and the choices you have to exercise your legal rights.

It is important that you read this Privacy Notice together with any other privacy notice we may provide when we collect or process your personal data so that you are fully aware of how and why we are using your data. In particular, please read this Privacy Notice in conjunction with our Cookie Policy.

This Privacy Notice covers the following topics:

Important information
Who we are
How to contact us about this Privacy Notice
The personal data we collect and use
Who we share your personal data with
How long your personal data will be kept for
Transfer of your personal data out of Singapore
Control over your information
Keeping your personal information secure
How to complain
Changes to this Privacy Notice

Who we are

This website is owned and operated by C & J Clark (S) Pte Ltd, which is part of the Clarks group of companies.

C & J Clark (S) Pte Ltd is a company registered in Singapore (company registration number 200312963Z) with a registered office at 238A Thomson Road, #13-08/09, Novena Square Tower A, Singapore 307684.

When we mention “Clarks”, “we”, “us” or “our” in this Privacy Notice, we are referring to C & J Clark (S) Pte Ltd.

For the purposes of data protection legislation, we are the data controller of your personal data.

How to contact us about this Privacy Notice

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Notice. If you have any comments, questions or requests in relation to this Privacy Notice or how we handle your personal data, please address them to Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ or email us at: privacy@clarks.com.

The personal information we collect and use

“Personal data” is defined as information about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.

If you have created an account with us, or ordered items from us, or took part in our marketing or promotional events, or otherwise interact with our website or app, we will use your personal data in several different ways. We will only be able to collect your personal data if (a) it is provided by you voluntarily or via a third party authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you or your authorised representative have been notified of the purposes for which the data is collected, and (ii) you or your authorised representative have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted by the Personal Data Protection Act 2012 or by other laws. Unfortunately, if you choose not to submit your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with our products or services, or access to the website or app this Privacy Notice is linked to.

The table below sets out how we use your personal data, which you would have voluntarily provided, showing what personal data we collect and why.

Category of personal data	Purpose for processing
Name and contact details (such as email address, telephone number and postal address)	Deliver your purchase to you Send you service messages by email or text, such as order updates Send you information by email or post about our new products or services Fraud prevention and detection To register you with a Clarks account, to register you as a Clarks Loyalty Program member which enables you to fully participate in the Clarks Loyalty Program activities or to register you as a subscriber to receive our marketing material. Data or market analyses Undertake website personalisation to develop products, services, applications Send you an email when you have left items in your basket
Purchase information/history	Maintain records of your purchases with us Deliver your purchase to you Send you service messages by email or text, such as order updates Send you relevant information by email or post or social media about our new products or services Fraud prevention and detection Make decisions about what Clarks adverts are shown to you as you browse the web or apps We use this information to help us improve and monitor the quality of our products and services provided to you. To better understand your preferences and make decisions about what Clarks adverts are shown to you as you browse the web or apps Data or market analyses
Date of birth information	Fraud prevention and detection To send you treats on your birthday To register you as a Clarks Loyalty Program member which enables you to fully participate in the Clarks Loyalty Program activities
Payment information (we don’t store this information)	Take payment and give refunds Fraud prevention and detection
Contact history with Clarks e.g. over the phone, email or on social media	Provide customer service and support Train our staff
Information you provide when signing up for a loyalty program or entering a competition or prize draw, playing games and completing surveys (including contact details and your actual entry)	To facilitate your participation in the loyalty program or competition or prize draw Data or market analyses
Device information: information about your computer, phone or other device you use to view the website or app such as device type, operating system, hardware version, browser type, unique device identifier, IP address and advertising ID Log information: information about how you use our website or app such as the types of content you view or engage with, the frequency and duration of your activities, access times, language, your IP address and pages you visit before or after navigating away from the website Device and log information will not be associated with you as a named individual unless you are logged into your account or you have given consent to receive email communications from Clarks by subscribing to Clarks emails.	Improve our website and set default options for you (such as language and currency) Showing you Clarks adverts as you browse the web Fraud prevention and detection Make sure the website or app display and function correctly on your device (e.g. make sure pages load correctly on your device and that the displayed language and currency are correct for the country you are in) Provide us with analytical information about the use of the website or app Make the website or app secure Make decisions about the pages, images and adverts to display to you on Clarks’ websites and apps To better understand your preferences and make decisions about the content we send you in Clarks marketing emails Make decisions about the adverts you see on websites and apps that are not owned by Clarks When you sign up to our emails you consent to the use of email tracking technology (pixels) through third parties to collect data such as whether an email has been delivered to you and if you have opened it. This data is only visible at an anonymous level to our teams to enable them to review and take actions based on the effectiveness of an online campaign. You can opt out of receiving emails at any time Associate different devices you use with each other so that the pages, images and offers you see across devices are consistent.
CCTV images captured in our stores	The use of CCTV recording equipment in and around our stores for monitoring and security purposes. We may share where necessary CCTV footage to the Police in particular. This is very strictly controlled
Social media comments and photos you post on social media pages where you have mentioned and tagged Clarks	We may want to respond to you or react, particularly if you are happy, or unhappy with something. It is important for us to know what you think about us and the products we provide to you.

We ensure that the collection and use of your personal data is lawful. Therefore, for the purposes listed above, we only use your personal data if one of the following conditions apply:

You have given us your consent
We need your personal data for the performance of a contract you enter into with us, such as when you purchase a product through the website or app
We need to comply with legal obligations
We need to protect your vital interests
Your data is necessary for the public interest, or
We have a legitimate interest in processing the personal data.

Who we share your personal information with

We share your personal data with the following categories of companies as part of being able to provide our services to you:

Members of the Clarks group of companies, where they assist us in providing our services to you
Service providers, contractors and companies which help us with our (i) Loyalty and Referrals Program; and (ii) Customer Data Platform, which helps us to collect and analyse customer data, providing customer identity and customer insight for marketing and customer experiences.
Companies that help us provide our products or services to you, such as payment service providers, warehouses operators and delivery companies
Marketing service providers, such as marketing agencies and advertising partners who help us market our business
Technology service providers, such as companies that support our IT, help us analyse the data we hold, send communications to our customers and help us develop and host our websites and apps
Professional advisors, such as companies that provide us with legal or financial advice
Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud and other unlawful activities
Companies approved by you, such as social media sites or other platforms/apps (whether online or otherwise) through which you obtain our products or services or take part in our marketing or promotional events, or otherwise interact with us
applicable third-party hosting providers for events and ticketing companies. Where your consent if provided, photographs and videos of these events may be shared on our social media and our website; and
If any part of our business is outsourced, sold, or merged, where permitted by law, we will share your data with the new provider so that we may continue to sell products to you and they may use your personal data in the same way as set out in this policy. We will of course inform you of any such change and give you an opportunity to opt out of your data being shared with a new provider.

How long your personal data will be kept

We will hold on to your information for as long as you have your account, or as long as is needed to be able to provide products or services to you, or (in the case of any contact you may have with us) for as long as is necessary to provide support-related reporting and trend analysis only.

If reasonably necessary or required to meet legal or financial or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also keep hold of some of your information as required, even after you have closed your account or it is no longer needed to provide products or services to you.

Transfer of your personal data out of Singapore

In order to process your personal data for the purposes set out in this Privacy Notice, we may transfer your personal data to third parties and other companies in our group that are based outside of Singapore in order to provide the products or services to you or as consented by you.

Whenever we transfer your personal data out of Singapore, we attach a similar degree of protection to it (as it would receive in Singapore) by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries, territories or sectors within a country that have been deemed to provide an adequate level of protection for personal data by the personal data protection law in Singapore
The transfer is subject to a legally binding and enforceable commitment on the recipient to protect the personal data
The transfer is made subject to binding corporate rules.
The transfer is based on a derogation from restrictions on transferring personal data outside of Singapore (such as where you give your consent, the transfer is necessary for the performance of contract with you, or the transfer is necessary for the establishment, exercise or defence of legal claims)
Where you give your consent, the transfer is necessary for the performance of contract with you, or the transfer is necessary for the establishment, exercise or defence of legal claims etc.

Control over your information

Under the personal data protection law of Singapore, you have several important rights available to you, which may in summary, include:

Be informed about how your personal information is being used (hopefully this Privacy Notice explains it all)
Access the personal information we hold about you
Request that we transfer elements of your data to another service provider
Request us to correct any mistakes in your information which we hold
Request the erasure of personal information concerning you in certain situations
Receive the personal information concerning you which you have provided to us, in a structured format or to ask us to transfer that information to another service provider
Stop any direct marketing
Object to processing of your personal data
You can ask us to restrict or suspend processing of your personal data under certain circumstances, for example if you want us to restrict processing while the accuracy of personal data is being established
Right not to be subjected to automated decision-making that significantly affects you, however, we will only use automated decision making in limited circumstances
Right to withdraw your consent, where processing of your personal data is based on consent, you can remove it at any time

Withdrawing your consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email at onlineenquiries.sg@clarks.com.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services, program or products to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

For further information on your rights, including the circumstances in which they apply, see https://www.pdpc.gov.sg/Individuals/Individuals-Overview.

If you would like to exercise your rights, please:

email or write to us at Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, England BA16 0EQ or email Privacy@Clarks.com
let us have enough information to identify you
let us know the information to which your request relates

We try to respond to all legitimate requests in accordance with the personal data protection law of Singapore and in any event, within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made many requests. In this case, we will notify you and keep you updated.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this Privacy Notice

This privacy notice was published on 2 November 2020 and last updated on 1 February 2024.

Any changes we make to this Privacy Notice will be posted on this page.