Privacy Policy 

Important Information

This Privacy Policy aims to give you information about how we collect and process your personal data when you use the website or app this Privacy Policy is linked to. This Privacy Policy 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 Policy.

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 Policy 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 Policy in conjunction with our Cookie Policy.

This Privacy Policy covers the following topics:

  • Important information
  • Who we are
  • How to contact us about this Privacy Policy
  • 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 Policy

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 163 Penang Road, #07-01/05 Winsland House II, Singapore 238463.

When we mention “Clarks”, “we”, “us” or “our” in this Privacy Policy, 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 Policy

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any comments, questions or requests in relation to this Privacy Policy 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 call 01458 899 904 or email us at: privacy@clarks.com.

The personal information we collect and use

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 you voluntarily submit the personal data to us. 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 Policy 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

So that you can book a fitting appointment

Fraud prevention and detection

To register you with a Clarks account

Data or market analyses

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 information by email or post 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

Data or market analyses

Date of birth information

Fraud prevention and detection

To send you treats on your birthday

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 entering a competition or prize draw, playing games and completing surveys (including contact details and your actual entry)

To facilitate your participation in the 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

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

Make decisions about the adverts you see on websites and apps that are not owned by Clarks

Associate different devices you use with each other so that the pages, images and offers you see across devices are consistent.

 

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:

  1. You have given us your consent
  2. 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
  3. We need to comply with legal obligations
  4. We need to protect your vital interests
  5. Your data is necessary for the public interest, or
  6. 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
  • 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

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 Policy, 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
  • 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 Policy 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

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, call or write to us at Privacy, Box No. 87, C. & J. Clark International Limited, 40 High Street, Street, Somerset, BA16 0EQ or email privacy@clarks.com, phone 01458 899 904
  • 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 Policy

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

Updated 16 September, 2019