Privacy Policy
PRIVACY POLICY FOR VERNON POWELL SHOES
Last Updated October 26, 2023 This Privacy Policy describes the policies and practices of Vernon Powell Shoe Company, DBA Vernon Powell Shoes (“Company,” “we,” “us,” or “our”) with respect to personal information (as defined below) and other data that are collected by Company in our retail location(s) (each a “Store”) and by any other means. Any information collected through the website, https://www.vpshoes.com/, is governed by this privacy policy. All services made available in our Stores, on our website, or for which you sign-up in our Stores or on our website (for example, a newsletter or email information service) are referred to collectively as the “Service”.
Before using the Service or submitting any Personal Information to Company, please review this Privacy Policy carefully and contact us (see below for contact information) if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Service.
When used in this policy, “Personal Information” means any information about an identifiable individual. Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be Personal Information.
Table of Contents
1.Personal Information We Collect
2.How We Use Personal Information
3.Sharing and Disclosure of Personal Information
4.Access and Correction of your Personal Information
5.California Privacy Rights and Disclosures
6.Usage Data
7.Tracking Technologies and Cookies
8.Payments
9.Children
10.Security and Retention
11.International Users
12.Your Choices
13.Social Media
14.Changes to the Privacy Policy
15.Contact Us
PERSONAL INFORMATION WE COLLECT We limit the collection of Personal Information to what is reasonably required to fulfill the purposes for which it is collected. We collect Personal Information directly from you, through in-store technologies, or when you otherwise interact with us. We collect information Personal Information as follows: Personal Information You Provide: We collect Personal Information when you (i) provide it to us to access a Service (for example, when you sign-up for a newsletter or email information service), (ii) provide it to Store personnel (for example, upon checkout), (iii) provide it to us in order to measure your feet and/or gait using in-Store technology, or (iv) provide it to us to receive custom insoles. The Personal Information collected during these interactions may vary based on what you choose to share with us, but it will generally include name, address, email address, and phone number. Foot Measurement & Pedorthic Solutions: We may offer in-Store solutions that utilize various technologies to assist you in finding shoes and/or insoles best suited to your feet. Our Store may collect data from you if you choose to have your feet scanned for the purpose of obtaining feet measurement data and/or product recommendations. For example, if you choose to use the Aetrex Foot Scanner, it creates a three-dimensional (“3D”) pixelated scan image of your feet and displays key measurement metrics, such as foot length, width, and arch height, to enable a proper fit recommendation matched to your needs, including shoe size and/or style recommendations. The following information from which you are not identifiable is collected and/or displayed via the Aetrex Foot Scanner scanning solution: gender, raw scan data (images captured to create 3D scan images) and scan images, measurement data, shoe size and sizing recommendations and, if you made a purchase, the time of purchase, shoe purchased, anonymous scan ID and store where the purchase was made. Further, our Store may collect data from you if you choose to have your feet measured for the purpose of finding optimally sized insoles (including the creation of custom insoles), shoe modifications, and shoe repairs. If you choose to have a custom insole made, we will also collect your name, weight, address, and phone number that, along with your foot measurements, are used by our certified pedorthist to create your custom insole in Store. Data We Receive Automatically from Your Use of the Service: In our Stores, we may collect or receive data and information about things such as the number of customer traffic in the store and the volume of transactions concluded in a particular store. HOW WE USE PERSONAL INFORMATION
We generally use your Personal Information to provide the Service, to manage our business operations, to communicate offers and information we think might interest you, to generally enhance your customer experience with us, and as otherwise authorized or required by law.
More specifically, we may use Personal Information for the following purposes:
• To provide the Service;
• To respond to your inquiries, comments, feedback or questions;
• To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
• To analyze how you interact with our Service;
• To maintain and improve the Service, including the content and functionality of the Service;
• To develop new products and services;
• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our premises, IT systems, architecture and networks; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners.
Marketing. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
Foot Measurement Solutions.
Where you use the Aetrex Foot Scanner, we may use the information collected to:
• Display your 3D foot scan image;
• Generate measurement metrics, such as foot length, width, and arch height; and
• Use your scan image and measurement data to recommend which shoes and in which sizes are best suited to your needs.
Where you use the services of our Certified Pedorthists, we may use the information collected to:
• Recommend insoles best fitted to your feet; and
• Where you elect to purchase custom insoles, to have the insoles created and shipped to Store.
Where you use the Aetrex Foot Scanner, we may use the information collected to:
• Display your 3D foot scan image;
• Generate measurement metrics, such as foot length, width, and arch height; and
• Use your scan image and measurement data to recommend which shoes and in which sizes are best suited to your needs.
Where you use the services of our Certified Pedorthists, we may use the information collected to:
• Recommend insoles best fitted to your feet; and
• Where you elect to purchase custom insoles, to have the insoles created and shipped to Store.
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In certain circumstances, we may share your Personal Information with third parties without further notice to you, including with our service providers, in the course of a business transaction or when required or authorized by law. We may also share anonymized data with certain third parties.
More specifically, we may share your Personal Information as set forth below:
• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support
services. Pursuant to our instructions, these parties will access, process or store Personal
Information in the course of performing their duties to us.
• Foot Measurement Solutions:
Where you elect to have your feet scanned using the Aetrex Foot Scanner, we share the following information from which you are not identifiable: raw scan data, 3D scan image, measurement data, shoe and sizing recommendations, and purchase information (time of purchase, shoe purchased, anonymous scan ID and store). We do not share any Personal Information (such as your name, email address or phone number) with the Aetrex Foot Scanner. The Aetrex Foot Scanner uses the data we share to provide the foot scanning and recommendation services, and for its internal research and product development.
• Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets. In the event the transaction is completed, your Personal Information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your Personal Information in any manner whatsoever and to delete such data completely, in compliance with applicable laws.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability, we may share your Personal Information as needed.
• Affiliates: We may share Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Company for purposes consistent with this Privacy Policy.
In certain circumstances, we may share your Personal Information with third parties without further notice to you, including with our service providers, in the course of a business transaction or when required or authorized by law. We may also share anonymized data with certain third parties.
More specifically, we may share your Personal Information as set forth below:
• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support
services. Pursuant to our instructions, these parties will access, process or store Personal
Information in the course of performing their duties to us.
• Foot Measurement Solutions:
Where you elect to have your feet scanned using the Aetrex Foot Scanner, we share the following information from which you are not identifiable: raw scan data, 3D scan image, measurement data, shoe and sizing recommendations, and purchase information (time of purchase, shoe purchased, anonymous scan ID and store). We do not share any Personal Information (such as your name, email address or phone number) with the Aetrex Foot Scanner. The Aetrex Foot Scanner uses the data we share to provide the foot scanning and recommendation services, and for its internal research and product development.
• Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets. In the event the transaction is completed, your Personal Information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your Personal Information in any manner whatsoever and to delete such data completely, in compliance with applicable laws.
• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability, we may share your Personal Information as needed.
• Affiliates: We may share Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Company for purposes consistent with this Privacy Policy.
ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION We respect your right to access and correct your Personal Information. Please contact us if you need to access or correct your Personal Information.
CALIFORNIA PRIVACY RIGHTS AND DISCLOSURES
Third Party Marketing:
California Civil Code Section § 1798.83 permits users of our Service that are California residents to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties.
These requests may be made once per year. To make such a request, please email us at vpinfo@vpshoes.com or write us at: Vernon Powell Shoe Co. 2401 E. Naylor Mill Road Salisbury, MD 21804 CCPA RIGHTS: The California Consumer Privacy Act (“CCPA”) provides California residents with the following rights, where applicable:
• Access: you may have the right to access the categories of Personal Information we have collected about you, the sources from which the Personal Information was collected, the business or commercial purpose for collecting your Personal Information, the categories of third parties with whom we share your Personal Information, the specific pieces of Personal Information we have collected about you, the categories of Personal Information we sold about you, the categories of third parties to whom we sold Personal Information about you, and the categories of Personal Information we disclosed for a business purpose.
• Deletion: you may have the right, under certain circumstances, to request that we delete the Personal Information you have provided to us.
• Opt out: you may have the right to opt out of the sale of Personal Information to third parties. You can exercise your right to opt out by clicking here.
• Non-discrimination: you have the right to be free from discrimination related to your exercise of your CCPA rights.
Third Party Marketing:
California Civil Code Section § 1798.83 permits users of our Service that are California residents to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties.
These requests may be made once per year. To make such a request, please email us at vpinfo@vpshoes.com or write us at: Vernon Powell Shoe Co. 2401 E. Naylor Mill Road Salisbury, MD 21804 CCPA RIGHTS: The California Consumer Privacy Act (“CCPA”) provides California residents with the following rights, where applicable:
• Access: you may have the right to access the categories of Personal Information we have collected about you, the sources from which the Personal Information was collected, the business or commercial purpose for collecting your Personal Information, the categories of third parties with whom we share your Personal Information, the specific pieces of Personal Information we have collected about you, the categories of Personal Information we sold about you, the categories of third parties to whom we sold Personal Information about you, and the categories of Personal Information we disclosed for a business purpose.
• Deletion: you may have the right, under certain circumstances, to request that we delete the Personal Information you have provided to us.
• Opt out: you may have the right to opt out of the sale of Personal Information to third parties. You can exercise your right to opt out by clicking here.
• Non-discrimination: you have the right to be free from discrimination related to your exercise of your CCPA rights.
USAGE DATA
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
TRACKING TECHNOLOGIES AND COOKIES
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
• Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
PAYMENTS
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors). We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
CHILDREN
Our Service is not directed to children who are under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Service, please contact us and we will endeavor to delete that information from our databases.
Our Service is not directed to children who are under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Service, please contact us and we will endeavor to delete that information from our databases.
SECURITY AND RETENTION
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
INTERNATIONAL USERS By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to the facilities and servers of Company in the United States and you hereby consent to such transfers.
YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you withdraw your consent or you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update, withdraw or correct your Personal Information. You can also withdraw your consent to the use and sharing of your Personal Information by contacting us, subject to legal or contractual restrictions and reasonable notice. SOCIAL MEDIA
We use social media platforms including Facebook, Instagram, and Twitter (“Social Media Platforms”). When you interact with these Social Media Platforms, we will collect Personal Data that you elect to provide to us or the Platform, including your social media username and your social media contacts, if applicable. Social Media Platforms may provide us with information and analytics regarding your engagement with us on social media. We may occasionally ask you for information for sweepstakes, contests, or surveys. This information may include without limitation your name, email and physical addresses, your phone number, and social media handle/user-names. This information is given on a voluntary basis and participation is not required. We may also use the information you provide to send you marketing communications CHANGES TO THE PRIVACY
YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you withdraw your consent or you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update, withdraw or correct your Personal Information. You can also withdraw your consent to the use and sharing of your Personal Information by contacting us, subject to legal or contractual restrictions and reasonable notice. SOCIAL MEDIA
We use social media platforms including Facebook, Instagram, and Twitter (“Social Media Platforms”). When you interact with these Social Media Platforms, we will collect Personal Data that you elect to provide to us or the Platform, including your social media username and your social media contacts, if applicable. Social Media Platforms may provide us with information and analytics regarding your engagement with us on social media. We may occasionally ask you for information for sweepstakes, contests, or surveys. This information may include without limitation your name, email and physical addresses, your phone number, and social media handle/user-names. This information is given on a voluntary basis and participation is not required. We may also use the information you provide to send you marketing communications CHANGES TO THE PRIVACY
POLICY
The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version in our stores, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
The Service, and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version in our stores, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at vpinfo@vpshoes.com.
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at vpinfo@vpshoes.com.