List of Topics
Who we are
For the purposes of applicable data protection laws, the responsible data controller is Gaynor Minden, Inc., 140 West 16th Street New York, NY 10011, United States (“Gaynor Minden”, “we”, “us” or “our”). Our EU Representative is Gaynor Minden B.V., Palmgracht 19HS, 1015 HJ Amsterdam, The Netherlands (please note that this address is an office and not a retail space).
Information We Collect
We may collect personal data and other information about you from the following sources:
Information we collect directly from you
We collect the information you provide directly to us, such as when you open an account, place an order, ask to receive emails, or interact with us on social media. The types of personal data we may collect directly from you include:
- Contact information, such as your name, email address, mailing address, and phone number;
- Account information, such as your username and password;
- Billing information, such as credit card or banking details and billing address;
- Optional information you may choose to provide, such as your date of birth, gender, social handles, shoe and clothing sizes and preferences, and
- Any other information you choose to provide.
The provision of personal data requested when placing an order or registering an account is a requirement necessary to enter into a contract. The provision of all personal data is voluntary. However, if you do not provide your personal data you will not be able to place an order, register an account or use certain features of our websites.
Information about your use of our websites
We collect information about your use of our websites, such as the products you buy or express interest in.
Information we collect from other sources
When you access our websites through a social network, we collect information from the social network in accordance with your settings on the social network. If you interact with us on social media, we will collect information about those interactions. The information we may collect includes your name, picture, and email address. We may also collect information about you from third parties, including mailing list providers and publicly available sources.
Information we collect by automated means
- URLs that refer visitors to our websites;
- Search terms used to reach our websites;
- Details about the devices that are used to access our websites (such as IP address, browser information, device information, and operating system information);
- Details about your interaction with our websites (such as the date, time, length of stay, and specific pages accessed during your visits to our websites, and which emails you may have opened); and
- Usage information (such as the number and frequency of visitors to our websites).
We may associate this information with your Gaynor Minden account if you have one, the device you use to connect to our websites, or email or social media accounts that you use to engage with Gaynor Minden.
Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we partner with third-party analytics providers, like Google, which set cookies when you visit our websites. This helps us understand how you are using our Services so that we can improve them.
Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies.
Local storage allows data to be stored locally on your browser or device and includes HTML5 local storage and browser cache.
- Technical: These are essential for our services to function properly. Like other cookies we use, technical cookies may be either first-party cookies or third-party cookies.
- Preferences: We use these cookies to remember your settings and preferences.
- Security: We use these cookies to help identify and prevent security risks.
- Performance: We use these cookies to collect information about how you interact with our website and to help us improve it.
- Analytics: We use these cookies to help us understand and improve our website.
- Advertising: We and our advertising partners use these cookies to deliver advertisements, to make them more relevant and meaningful to visitors on our website, and to track the efficiency of our campaigns.
Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the functions of our website may not function properly.
To prevent your data being used by GoogleAnalytics, you can install Google’s opt-out browser add-on.
For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/. European users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance.
Advertising and Analytics Services Provided by Others
How We Use Your Information
We may use or otherwise process your personal data for the following purposes, in particular to
- Carry out the ordering process and to deliver the products you request;
- Provide, maintain, and improve our services;
- Maintain and administrate your account;
- Communicate with you about our products and services;
- Respond to your requests, inquiries, comments, and suggestions;
- Facilitate your engagement with websites, including to enable you to post comments and reviews on any public forums we may make available;
- Offer contests, sweepstakes, or other promotions;
- Conduct or administer surveys and other market research; and
- Protect against, identify, investigate, and respond to fraud or other illegal activity.
How We Share Your Information
We may share your information:
- With service providers that perform services on our behalf, such as those that provide shipment and payment services, customer service, and marketing support;
- With selected partners as a part of co-sponsored promotions;
- With third parties such as enforcement agencies, governmental authorities, legal counsel and external consultants to comply with a legal or regulatory obligation, protect and defend Gaynor Minden’s rights or property, protect the safety of our customers and website users or the public, and protect against legal liability;
- In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
- Between and among Gaynor Minden’s current and future parents, subsidiaries, affiliates, and other companies under common control and ownership; and
- In any other way with your consent and at your direction.
When you post information in any public form, such as submitting a product review or other user content for posting in a public area on our websites, that content will be publicly visible. Accordingly, please do not submit any information in those areas you don’t want the public to see. We may also share aggregate or de-identified data that does not identify you personally.
Your Rights and Choices
Managing or deleting your Gaynor Minden account
You may review, update, or modify your account information, including profile and contact information, at any time by logging into your Gaynor Minden account.
Opting out of email marketing
You may unsubscribe from our promotional emails at any time by following the instructions included in those emails. If you opt out of receiving such communications, note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).
Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our websites.
Opting Out of Co-Sponsored Promotions with Marketing Partners
If you would like us to stop sharing your information with our marketing partners for co-sponsored promotions, you may opt-out from future sharing by emailing us at [email protected]
Our Services are not designed for children and do not knowingly collect personal data from individuals under the age of sixteen (16) years without first obtaining verifiable parental consent. If you are under the age of 16, you should not provide personal data to us. If you have reason to believe that a child under the age of 16 has provided personal data to us without proper parental consent, please contact us, and we will endeavor to delete that information from our databases.
International Data Transfers
Gaynor Minden is headquartered in the United States, and we have operations and entities in the United States and other countries. As such, we may transfer your personal data to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. Whenever we transfer personal data of residents from the European Economic Area (“EEA”) to countries outside the EEA that do not provide an adequate level of data protection according to an adequacy decision of the European Commission and which data transfer is not subject to any derogation for a specific situation as defined in the EU General Data Protection Regulation (“GDPR”), we will ensure that at least one of the following appropriate safeguards is implemented:
- EU standard contractual clauses, as adopted by the European Commission, are concluded with the data recipient;
- Data Recipient is certified under the EU-U.S.-“Privacy Shield”; or
- Data Recipient has adopted internal binding corporate rules that are in line with the level of data protection granted by the EU.
EEA residents may ask for a copy of the appropriate safeguards by contacting us as set out below.
Residents of the European Economic Area
If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Data Processing
If you are a resident of the EEA, the processing of your personal data will be based on the following:
- If you have given us your consent to process your personal data, we will process your data on basis of your consent in accordance with Article 6 para. 1 lit. a) GDPR;
- The processing of any sensitive personal data concerning your health that you voluntarily submit (e.g., relating to injuries or conditions affecting recommendations for proper shoes) will be based on your consent pursuant to Article 9 para. 2 lit a) in conjunction with Article 6 para. 1 lit. a) GDPR;
- The processing of your personal data may be necessary
- For the performance of a contract with or as request by you, or for the implementation of pre-contractual measures (Article 6 para. 1 lit. b) GDPR);
- To fulfill statutory obligations to which we are subject (Article 6 para. 1 lit. c) GDPR);
- For the protection of our legitimate interests or the legitimate interests of a third party, unless your interests or fundamental rights and freedoms prevail (Article 6 para. 1 lit. f) GDPR); this may in particular apply to marketing and CRM, physical security, IT and network security, internal investigations, prevention of fraud, misuse of IT systems, anti-money laundering, and potential merger and acquisition activities.
Data subject requests
If you are a resident of the EEA, or the issue in connection with the processing of your data occurs within the EEA, you may have under certain circumstances the right to:
- Obtain from us the information whether or not personal data concerning you is processed, and, where this is the case, to access the personal data (right of access);
- Request that your personal data is rectified or completed where such data is inaccurate or incomplete (right to rectification);
- Request that your personal data is erased in which case we might be obliged to erase such personal data or inform others about your request (right to be forgotten);
- Request the restriction of processing of your personal data (right to restriction of processing);
- Request to receive your personal data in a structured, commonly used and machine-readable format in order to transfer such data without hindrance to another entity (right to data portability).
In addition, under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data, including profiling activities that are made in connection with the direct marketing activities.
If you would like to exercise any of these rights, you may contact us as indicated below. If you have a Gaynor Minden account, you may also review, update, and delete certain personal data by logging into your account.
If you are a resident of the EEA, you have the right to lodge a complaint with the local data protection authority should you have a concern about our practices concerning the processing of your personal data. For contact details of the relevant local data protection authority, please see https://edpb.europa.eu/about-edpb/board/members_en.
Social Networking Access
We collect your public profile data only from your consent that you grant before initiating Social Login, from the social network used to login at our website. This data includes your first name, last name, email address, link to your social media profile, unique identifier, link to social profile avatar. This data is used to create your user profile at our website. You can revoke this consent at any time by sending us an email.
Links to Other Websites and Third-Party Content
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the services requested or the other respective processing purpose(s) for which the data was collected, and any other permissible, compatible purpose. When your personal data is no longer needed for the processing purposes, we will remove it from our systems and records or take steps to properly anonymize the data so that you can no longer be identified from it, unless we need to keep the data to comply with our legal or regulatory obligations, in particular, statutory retention duties, or if we need the data to preserve legal evidence within the applicable statutes of limitation. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired.
California Privacy Rights
California law permits residents of California to request notice of how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: Gaynor Minden, 140 West 16th Street, New York, NY Attn: Legal.
Contacting Gaynor Minden
140 West 16th Street
New York, NY 10011