This Privacy Policy covers the interactions we have with our customers and potential customers. We interact with our customers and potential customers via our website, via marketing tools, our stores and social media. The data controller (who determines the purpose and way your Personal Data is used) is F J Benjamin Pte Ltd (referred to in this Privacy Policy as “we” or “us”). We use third parties to process data on our behalf (referred to in this Privacy Policy as “Data Processors”). Further details of the parties with whom we share your data are set out below.

We are committed to doing the right thing when it comes to how we collect, use and protect your Personal Data. That’s why we’ve developed this Privacy Policy and a Cookie Declaration, which:

• sets out the different ways you interact with us and the types of Personal Data that we collect;
• explains the reasons why we use the data we collect;
• explains when and why we will share Personal Data within Cole Haan and with other organizations; and
• explains the rights and choices you have when it comes to your Personal Data.

This Privacy Policy applies to you when you interact with us. The different ways you interact with us are further described in this Privacy Policy. Our website may contain links to other websites operated by other organizations that have their own privacy policies. Please make sure you read the terms and conditions and privacy policy carefully before providing any Personal Data on a website as we do not accept any responsibility or liability for websites of other organizations.

"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Types of personal data

In this section we have defined the different types of personal data:

Contact data: This is information that details how we can contact you, so your address, email or telephone number.

Feedback data: This is information collected about you as a user of our stores, products and services more generally (compared to other types of data that relate to you directly for us to deliver our products to you). This may include where you engage with Cole Haan in a survey, via social media, provide feedback on your shopping experience or our products and services.

Financial data: This is information about your bank account and payment card details or other payment account details such as details regarding your ApplePay or PayPal account.

Identity data: This is information that helps us identify who you are, so your name, title, gender, certain preferences, or Order Number.

Pseudonymized data: Data that is gathered in a form whereby data that identifies an individual is removed or replaced by non-identifying information such as an ID number or reference number.

Special category data

This is special information that applicable privacy laws determine to be more sensitive (sometimes it is referred to as sensitive Personal Data) and it needs more protection. For example, racial or ethnic origin, health related information, or religious beliefs or union membership. Cole Haan does not collect such data. Should we collect sensitive Personal Data in our interactions with you, this will be done with your consent and its use made clear to you.

Technical data: This is information about your device used to access our website and how you interact with our products and services. This could be information that identifies your device, its operating system, internet address, your login data; browser and plug- ins; geo-location; or behavioral data such as browsing history, time spend on website and conversion rates. This allows us to create an analysis of you as a consumer to better judge what products and services to offer. If you use our in-store WIFI we will collect information about where and when you accessed our network; This is done via the use of Cookies and other techniques which is covered elsewhere in this Privacy Policy and our Cookie Declaration

Transaction data: This is information about your purchase of a product or service from us. This includes when, where, what and how you purchased that item or service. It will also include where we sent that product or service and any other benefits collected as part of the transaction.

As mentioned above we use third parties to process Personal Data on our behalf (“Data Recipients”). In this section we have defined the categories of Data Recipients who receive the Personal Data from us in order to provide their services. Separate data privacy policies and cookie notices might apply, and these Data Recipients might provide your Personal Data to other parties, but these other parties are required to protect the data in accordance with applicable data protection laws and they may only use it for specified purposes and in accordance with our instructions.

Types of Data Recipients

IT Providers: We use several third parties who provide IT solutions and/or services who enable us to operate our IT infrastructure. We need our IT infrastructure to operate our business.

Logistic Providers: We use several third parties who provide logistical solutions and/or services who enable us to provide customer contact services, to deliver or take back products you purchased via our website via our stores.

Marketing Providers: We use several third parties who provide us solutions and/or services to help us market and promote our products and services.

Analytic Providers: We use several third parties who provide us solutions and/or services to better understand our customers and visitors of our website, to better understand our competition and to better market our products and services, but also to help us prevent misuse of the website.

Payment Providers (PP): If you purchase our products via our website in our stores your payment is processed via a PP. A PP company that offers us services for accepting electronic payments by a variety of payment methods including credit card, bank-based payments such as direct debit, bank transfer, and real-time bank transfer based on online banking. A PP allows us to accept a wide variety of payments through a single channel. The PP works with acquiring banks (payment processors) to manage the entire transaction process from start to finish and as such they are an independent Data Controller.

Fraud Detecting Companies: In order to prevent fraud, we use third parties who have their own data bases and as such they are an independent Data Controller containing Personal Data.

Social Media: We use social media networks who provide us solutions and/or services to help us market and promote our products and services.

All Data Recipients with whom we share your Personal Data are required to protect it in accordance with applicable data protection laws and they may only use it for specified purposes and in accordance with our instructions.

When you sign-up for our emails

In order to receive our e-mails, you will provide us your name and email address. You can sign-up at any time, for example while purchasing online or in our stores, while using the website or during other interactions with us.

We collect: Contact data and Identity data. For which purpose you have given your consent by signing up. You can withdraw your consent at any time by following the process set out in section 13 below.

Purpose and legal basis: We collect and process the Personal Data to market our products and services.

Data sharing: We use IT Providers, Marketing Providers and Analytic Providers.

When you become a member via our website

In order to become a member (creating an account), you will provide us your name, email address and you create a password. You can also opt in to receive our e-mails. To further complete your profile, you can provide additional personal information and certain preferences.

We collect: Contact data and Identity data.

Purpose and legal basis: We collect and process the Personal Data to market our products and services, for customer analysis and personalization of website and marketing. For which purpose you have given your consent by signing up. You can withdraw your consent at any time by following the process set out in section 13 below.

Data sharing: We use IT Providers, Marketing Providers and Analytic Providers.

When you browse our website

If you browse our website, we wish to learn more about your preferences.

We may collect: Identity data, Technical data, Feedback Data and Pseudonymized data.

Purpose and legal basis: We collect Technical data, Feedback Data and Pseudonymized data in order to market our products and services; and to understand who is visiting our website to understand the browse behavior of our customers and visitors. This is necessary for our legitimate interest of growing our business and marketing our products or for which you have given your consent by using our website or for which you have given your consent via CookieBot if you are visiting our website out of Europe.

Data sharing: We use IT Providers, Marketing Providers and Analytic Providers.

When you shop with us online or place an order via customer service

If you place an order, we will need to have personal information in order to process your order and payment.

We will collect: Identity data, Contact data, Financial data, Transaction data, Technical data, Feedback Data and Pseudonymized data.

Purpose and legal basis: We collect and process the Identity data, Contact data, Financial data and Transaction data in order to process your order and payment. Our legal basis for doing this is that it is necessary for the performance of our contract with you.

If you have given consent to receive our marketing emails, we will also use your Contact data to send you marketing communications. Our legal basis for doing this is your consent. You can withdraw your consent at any time by following the process set out in section 13 below.

Data sharing: We use IT Providers, Marketing Providers, Analytic Providers, Payment Providers, Fraud Detecting Companies and Logistic Providers.

When you contact us regarding your order or products or services in general or when you have a complaint or wish to return a product.

In order to help you with your order inquiries or if you wish to return a product we will need to have Personal Data in order to help you in the best possible way.

We may collect: Identity data, Contact data, Transaction data.

Purpose and legal basis: If you have contacted us about returning a product, we will use the Personal Data to process (return) orders and payments. Our legal basis for doing this is that it is necessary for the performance of our contract with you.

If you have contacted us about any other query or inquiry, we will use the Personal Data you provide in order to respond to that query or inquiry. Our legal basis for doing this is that it is necessary for our legitimate interest of assisting our customers and responding to their complaints.

Data sharing: We use IT Providers, Payment Providers and Logistic Providers.

When you take part in promotions, competitions, surveys or reviews about our products

We may collect: Identity Data, Contact Data, Technical Data and Feedback Data.

Purpose and legal basis: We collect and process the Personal Data in order to process your participation in the competition. Our legal basis for doing this is that it is necessary for the performance of our contract with you. We collect and process the Personal Data to market our products and services, for customer analysis and personalization of website and marketing. For which purpose you have given your consent by signing up for the competition.

Data sharing: We use IT Providers, Marketing Provider, Analytic Providers.

When you follow us on social media

If you follow us on social media, like our posts, share our posts, post on our pages you will leave Personal Data.

We may collect: Identity Data, Contact Data and Technical Data and Feedback Data.

Purpose and legal basis: We collect and process the Personal Data to market our products and services, for customer analysis and personalization of website and marketing. These social media companies may share data in accordance with their terms and conditions. For which purpose you have given your consent via your social media account and we have a legitimate interest.

Data sharing: We use Marketing Service Provider, Analytic Service Providers.

When you visit our stores

If you visit our stores you may provide your Personal Data by paying for a product, returning a product, or signing up for receiving e-mails. You may have certain inquiries we need to follow-up on.

We may collect: Identity Data, Contact Data Financial data and Transaction data.

Purpose and legal basis: We collect and process the Personal Data in order to process your order and payment. Our legal basis for doing this is that it is necessary for the performance of our contract with you. If you have contacted us about any other query or inquiry, we will use the Personal Data in order to respond to that query or inquiry. Our legal basis for doing this is that it is necessary for our legitimate interest of assisting our customers. We collect and process the Personal Data to market our products and services, for customer analysis and personalization of website and marketing. For which purpose you have given your consent by signing up. You can withdraw your consent at any time by following the process set out in section 13 below.

Data sharing: We use IT Providers, Marketing Providers, Payment Providers and Fraud Detecting Companies

We may also use Personal Data from other sources, such as specialist companies that supply information, such as data brokers or data intelligence companies, and from third parties for whom we act as data processer. Examples of information we receive from other sources include Personal Data you have provided to third parties and for which you have given permission to transfer to third parties. For example, this other Personal Data helps us to:

• Review and improve the accuracy of the data we hold;
• Improve and measure the effectiveness of our marketing communications, including online advertising.

Apart from sharing Personal Data with the Data Recipients specified above, we might also share Personal Data with other organizations in the following circumstances:

• Within the Cole Haan Group (Cole Haan LLC, Cole Haan Company Store LLC and Cole Haan International B.V.) where this is necessary for our internal processing purposes;
• In the event of a merger, sale, change in control, or reorganization of all or part of our business;
• When we are required to disclose Personal Data to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;
• Where we have a good-faith belief sharing is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Website Terms of Use or as otherwise required to comply with our legal obligations; or
• As you may otherwise consent from time to time.

We know how important it is to protect and manage your Personal Data. This section sets out some of the measures we have in place.

• We apply physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of Personal Data;
• We protect the security of your information while it is being transmitted by encrypting it;
• We use computer safeguards such as firewalls and data encryption to keep data safe;
• We only authorize access to employees and trusted partners who need it to carry out their responsibilities;
• We regularly monitor our systems for vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security;
• We will ask for proof of identity before we share your Personal Data with you; and
• We will reveal only the last four digits of your payment card number when confirming an order.

While we take appropriate technical and organizational measures to safeguard your Personal Data, it is important that you keep your login details and devices protected from unauthorized access.

Your personal information is stored by us and/or our service providers for as long as necessary to fulfill the specific purposes described herein and to the extent permitted by applicable laws. When we no longer have a legitimate business purpose for your personal information, or when you request that we delete your personal information (except where we need to retain it in order to comply with a legal obligation or to establish, exercise or defend legal claims), we will remove such information from our systems and records, which includes taking steps to anonymize it so that you can no longer be identified from it.

We and our partners use cookies and similar technologies, such as tags and pixels (“Cookies”), to personalize and improve your customer experience as you use our website and to provide you with relevant online advertising. We use Cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use Cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. Please see our Cookie Declaration. If you’re residing in Europe please see section 14.

Your browser settings

You can use your browser settings to delete existing Cookies. You can also set your browser to notify you each time new Cookies are placed on your computer or other device. You can find more detailed information about how you can manage Cookies through your browser’s help function.

If you choose to disable some or all Cookies, you may not be able to make full use of our Websites. For example, you may not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to sign in.

To provide increased value to you while visiting our website, we may choose various third-party websites to link to from our own website. Once you are visiting a third-party website, separate data privacy policies and cookie notices might apply, and these Data Controllers might collect and process your Personal Data and provide it to other parties for reasons other than those set out in the Privacy Policy. We have no responsibility or liability for these independent policies or actions, and we are not responsible for the privacy practices or the content of such websites. Nonetheless, we seek to protect the integrity of our website and the links placed upon it and therefore we request feedback on not only our own website, but for websites we link to as well (including if a specific link does not work).

If you have any queries regarding this Privacy Policy or complaints about our use of Your Data, please contact us at customerservice@colehaan.sg