Privacy Policy & Cookies - Start-Rite Shoes

Privacy Policy

Important Information

This Privacy Policy outlines how we collect and process your personal data using the Start-Rite website and mobile app, and how we keep your data safe.

It is important that you read this Privacy Policy and any updates to this policy so that you understand how and why we use your data.

Please ensure that you read this policy carefully in conjunction with our Cookie Policy, below.

Who We Are

Start-Rite Shoes Limited is a private limited company, number 00140697, with a registered office at Peachman Way, Broadland Business Park, Norwich, Norfolk, NR7 0WF. When we mention Start-Rite, “we”, “us” or “our” in this policy, we are referring to Start-Rite Shoes Limited.

We want to be clear about the information we collect when you use our services, how we use it, who we share it with and the choices we give you to control and access your data. For the purposes of data protection legislation, we are the data controller of your personal data and we are registered with the Information Commissioners Office under registration number Z6481650.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to The Data Protection Manager and Data Controller, Start-Rite Shoes Limited, Peachman Way, Broadland Business Park, Norwich, NR7 0WF. Alternatively, you can email us at customer.services@startriteshoes.com.

The Personal Information We Collect and Use

Information You Give to Us:

You may give us information about you by filling in forms on our site https://www.startriteshoes.com (our site) or mobile app (app), or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you sign up to receive emails from us, register to use our site or app, place an order on our site or app and when you report a problem with our site or app. The information you give us may include your name, address, e-mail address, phone number, and payment method used to make a purchase.

Information We Collect Automatically:

Our servers, logs and other technologies collect certain pieces of information about you automatically. This information helps us to deliver and improve our services, analyse usage and improve the user experience. We collect information about how you use our services, such as the types of content and products you view or search for, the frequency and duration of your activities, and page interaction information. We only share data with third parties as described in this policy or where the law permits or requires it.

On each of your visits to our site or app, we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Cookies

Our website and app use cookies and other technologies such as unique advertising identifiers to collect information about your activity, browser and device. This helps us to provide you with a good experience when you use our website and app, to improve our site and app, and to build a profile of our users. Some of this data will be used in aggregated or statistical form, which means that we may not be able to identify you individually.

If you prefer, you can remove or disable browser cookies using the settings on your browser or device. However, removing or disabling cookies could affect the availability and functionality of our services. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy, below.

How We Use Your Personal Data

The General Data Protection Regulation (GDPR) sets out a number of different lawful grounds under which companies may collect and process your personal data, including:

Consent

In some situations, we will ask your consent to process your personal data, such as when you give consent to receive email newsletters via our newsletter sign-up page, when you register for an account, or in your account settings. We will always make it clear to you what data we are collecting and how we process it.

Legal Obligation

We may need to collect and process your data to comply with the law, such as in the case of suspected fraud or criminal activity.

Contractual Obligation

In the case that you make a purchase, we must process your personal data to comply with our contractual obligation to fulfil your order.

Legitimate Interest

In some situations, we process your personal data to pursue our legitimate interests which are reasonably expected as part of running our business and do not negatively impact your fundamental rights, freedoms or interests. An example of this is to tailor adverts to your interests according to your shopping history.

The table below shows our purposes of processing each category of personal data and our legal basis for processing.

Category of Personal Data Purpose of Processing Legal Basis for Processing Under the GDPR

Name and Contact Details

Fulfil your order

Contractual obligation

Send order updates and service messages by email or SMS

Contractual obligation

Send marketing information by email, if you have purchased from us

Legitimate interests

Send marketing information by email, if you have not purchased from us

Consent

Send marketing information by post or SMS

Consent

Fraud prevention and detection

Legal obligation

Improve our website and user experience

Legitimate interests

Tailor adverts shown to you as you browse social media and the web, according to your browsing behaviour and preferences

Legitimate interests

Tailor marketing communications to your preferences

Legitimate interests

Contact history with Start-Rite (e.g. phone, email or social media)

Provide customer service and support

Contractual obligation

Payment information (we do not store this information)

Take payment and process refunds

Contractual obligation

Fraud prevention and detection

Legal obligation

Information about your device and how you use our website

Improve our website and user experience

Legitimate interests

Tailor adverts according to your browsing behaviour and preferences

Legitimate interests

Tailor marketing communications to your preferences

Legitimate interests

Geo-location data collected by our mobile app, if you allow location data via your device settings

Send location-relevant push messages and allow you to find your nearest stockist

Legitimate interests

Data you provide us in our mobile app about your child(ren), including name, gender, date of birth and foot measurements

Tailor your shopping experience based on products available in your child’s size and appropriate to their age and gender

Legitimate interests

Send reminders via push messaging and email, where you have set your preferences to receive these, to re-measure your child’s feet at intervals appropriate to their age

Legitimate interests

Inform our product development according to shoe sizes at different ages

Legitimate interests


We rely on legitimate interests as a processing basis for the purposes of sending marketing emails to customers who have purchased from us and for the segmentation, targeting and personalisation of our content. To do so, we conducted a stringent 'Legitimate Interests Assessment'. We carefully balanced our legitimate interests with any impact on you, whether positive or negative, and with your rights. In short, our legitimate interests in processing your data are to give you the best service and experience through highly relevant and targeted content and to ensure the commercial viability of our eCommerce channel. We do not use your personal data for processing activities where our interests are overridden by the impact on you unless we have your consent, are required to fulfil our contractual obligations, or are otherwise permitted or required to by law, as shown in the above table.

Who We Share Your Personal Data With

As part of providing our services, we share your data with the following types of companies:

  • Companies involved in processing your order, such as payment service providers and delivery companies
  • Professional service providers, such as advertising partners, website hosts, marketing agencies and data insight agencies who help us to run our business
  • Credit reference agencies and fraud prevention agencies
  • Companies approved by you, such as social media platforms

We will only share the information they need to perform their specific services and they may only use your data for the specific purposes outlined in our contract with them. Should we stop working with a third party for any reason, your data will be either anonymised or deleted. We will not share your personal information with any other third party.

To help personalise your journey and to improve our business and services, we use the following companies, who will process your personal data as part of their contracts with us.

BigCommerce
Dotdigital
More2
NN4M
FeeFo
Williams Commerce
AWIN
Soreto
UpSellit
Royal Mail
TNT
Facebook
Sagepay
Paypal
Google
Instagram
Prima Solutions
Sub2
Apple

Transfer of Your Information out of The EEA

The European Economic Area includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

Your information may be transferred to and from the United States of America. This website uses Google Analytics, a web analytics service provided by Google, Inc. which uses cookies to help the website analyse how individuals use the site. Please see our Cookie Policy below for more information about how cookies work. The information generated by the cookie about your use of the website, including your IP address, is transmitted to and stored by Google on servers in the United States of America. Google will use this information to evaluate your use of the website, which we may then use for marketing purposes, such as letting you know about new products and promotions.

Google are registered under the Privacy Shield, which means that they have committed to provide equivalent standards of care when processing your personal data as we take ourselves.

How Long We Will Keep Your Personal Information

Generally, we will hold your information for up to seven years from the date of your last purchase or use of our site or app.

In the case that we are required to meet legal requirements, resolve disputes, prevent fraud or abuse, or enforce our terms and conditions, we may hold some of your data after this time.

Your Control Over Your Information

Under the GDPR, you have the right to:

  • Be informed about how your personal data is used
  • Access the personal data we hold about you
  • Request that we rectify any incorrect information that we hold about you
  • Receive the personal information that you have provided to us in a structured, commonly used and machine-readable format
  • Request that we transfer certain elements of your data to another data controller
  • Request that we erase your personal data in certain situations
  • Object to processing of your personal data

For more information on your rights and the situations in which they may apply, please read the Guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the GDPR.

If you wish to exercise your rights, please contact The Data Protection Manager and Data Controller, Start-Rite Shoes Limited, Peachman Way, Broadland Business Park, Norwich, NR7 0WF. Alternatively, you can email our Customer Service team at customer.services@startriteshoes.com or phone 01603 595200.

To respond to your request, we will need you to provide enough information to identify you, proof of identity and address, and the information to which your request relates. We endeavour to respond to all such requests within one month.

Keeping Your Data Secure

We have security measures in place to prevent personal data being lost, accessed, or used in an unauthorised manner, as well as procedures to deal with any suspected breach. Only those with a genuine business need have access to your data and these individuals will process your information in an authorised and confidential manner. We will notify you of any suspected security breach and, where we are legally required to do so, notify the appropriate regulatory body. All information you provide to us is stored on secure servers and protected by an enterprise level security firewall. We do not collect or store any payment information, including card details. Instead, we work with third party secure payment providers to ensure your payment details are safely processed.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Where we have given you a password which enables you to access certain areas of the site or app, you are responsible for keeping that password confidential and the password should not be shared with anyone.

Links to Other Websites

The site and app may from time to time contain links to and from other websites. If you follow any of these links please note that these websites have their own privacy policies and we do not accept responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Contact Us

If you wish to contact us please write to The Data Protection Manager and Data Controller, Start-Rite Shoes Limited, Peachman Way, Broadland Business Park, Norwich, NR7 0WF.

Alternatively, please email our Customer Service team at customer.services@startriteshoes.com or phone 01603 595200.

If you feel we have not been fair or honoured your rights or have not dealt with your complaint fairly and reasonably, you can complain to the UK's Information Commissioner's Office. Please visit their website for more details: https://ico.org.uk/

Updates to This Privacy Policy

This Privacy Policy was published on 23rd May 2018 and last updated on 11th December 2019. Any changes made to this policy will be published on this page.

Definitions

Data Controller

Any person, authority, agency or body who either wholly or partly determines the purposes and means of processing personal data.

Data Subject

A natural person whose personal data is processed by a controller or processor.

Encrypted Data

Personal data that is protected through technological measures to ensure that data is only accessible to those with specified access.

Personal Data

Any information related to a natural person, or ‘data subject’, that can be used to directly or indirectly identify the person. This includes identifiers such as a name, identification number, location data, online identifier and factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing

Any operation performed upon personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

COOKIE POLICY

This policy is provided to ensure you understand what cookies are, that you are fully aware of the cookies we use, and that you know how these relate to your privacy online.

What Are Cookies?

Cookies are small text files that contain letters and numbers, which are placed on your computer or device when you visit a website. On later visits, this data is then returned to that website, allowing the website to recognise your PC, mobile, tablet or other device as you browse. Cookies are not computer programs and cannot be used to transmit viruses.

For more information about cookies and how they work, please visit www.allaboutcookies.org.

Data transmitted by cookies will never contain your name, address, phone number or payment details.

Why Do We Use Cookies?

Cookies are very important in helping us to monitor the use of our site and app and to help us improve the services we are able to offer you. Cookies can serve many different functions. For example, they allow us to recognise you automatically when you visit our site or app so that we may personalise your experience and provide you with a better service. Cookies allow us to remember whether you are logged in and what items you had placed in your shopping basket. We also use cookies for fraud prevention purposes and use cookies with our partner marketing agencies to serve you appropriate advertising as you browse the internet.

Types of Cookies That We Use

Session (or Transient) Cookies

Session cookies are stored in your device's memory for the length of your browsing session. They become inaccessible after the session has been inactive for a time and are automatically deleted from your device when the browser is closed. They allow you to move from page to page without having to log-in repeatedly. If your browser is set to refuse these cookies from our website, you will not be able to complete a purchase or take advantage of certain site features, such as storing items in your shopping basket.

Persistent (or Permanent) Cookies

Persistent cookies are stored on the user's device memory and are not deleted when the browser or app is closed. They are used to keep your preferences for the website or app, so they will be remembered for your next visit. They are also used to collect information about the numbers of visitors, the average time spent on a page and analyse shopping behaviour on the website or app. This information is used to find out how well the website and app work and where they can be improved.

Flash Cookies (or Locally Shared Objects)

You may have Adobe Flash installed on your computer. Websites that contain Flash can also store small files on your computer that are used in the same way as cookies. Flash cookies can back up the data that is stored in other cookies. When you delete cookies, your Flash cookies are not affected. Therefore, a website may still recognise you if it backed up the deleted cookie information on a Flash cookie.

Third-Party Cookies

Start-Rite Shoes works with selected companies to provide additional content and services and these companies may also set cookies on our behalf. Most of these companies use both session and persistent cookies, which are used to deliver relevant adverts to you, limit the number of times you see an advert and help us measure the effectiveness of our advertising campaigns. Cookies do not contain sensitive information such as your name, address, phone number or payment details.

Sharing with Social Networks

If you use the buttons that allow you to share products and content with your friends via social networks like Twitter and Facebook, these companies may set a cookie on your device memory. Find out more about these here:

By using our website, you agree that we can place these types of cookies on your device.

Contact Us

Questions, comments and requests regarding this Cookie Policy should be addressed to The Data Protection Manager and Data Controller, Start-Rite Shoes Limited, 15 Peachman Way, Broadland Business Park, Norwich, NR7 0WF. Alternatively, please email our Customer Service team at customer.services@startriteshoes.com or phone 01603 595200.

What Cookies Do Start-Rite Use?

To make it easier for you to understand how our website app uses cookies, we have grouped them into simple categories. This information is provided to you in an open and transparent manner, so that you can understand how cookies improve your user experience and so that you can make an informed choice in allowing their usage.

Necessary Cookies – important to the technical operation of the site to ensure that it performs as users would expect.
Cookie Expiry Provider Description

f5_cspm

Session

pubmatic.com

Saves the address and port number of the web server that is managing the session. Used to improve the website’s performance security

cj_session

1 day

freshfilter.co.uk

Maintains a user state during a browser session for consistency of user experience

csrftoken

1 year

instagram.com

Helps prevents Cross-Site Request Forgery attacks

debug

Persistent

startriteshoes.com

Unclassified HTML cookie

rur

Session

instagram.com

Ensures visitor browsing security

SHOP_SESSION_TOKEN

6 days

startriteshoes.com

Enables shopping cart functionality

urlgen

Session

instagram.com

Ensures visitor browsing security

Site Experience Cookies – used to support your experience of the site and app, including user-entered options and site navigation support. These types of cookies do not generally collect personally identifiable information
Cookie Expiry Provider Description

feefo.translations

Persistent

startriteshoes.com

Translates into the preferred language of the user

feefo.translationsUpdatedAt

Persistent

startriteshoes.com

Allows the website to show content relevant to the user’s country and language settings

mid

10 years

instagram.com

Identifies the user through an application, allowing the user to login into the website through Instagram

Performance and Operation Cookies – used in the management of the site and app, recording data such as visitor numbers and web analytics. Limited personally identifiable information may be collected.
Cookie Expiry Provider Description

ajs_anonymous_id

1 year

startriteshoes.com

Identifies the number of specific visitors on the website

_cfduid

29 days

Pingdom.net, feefo.com, r1.trackedweb.net

Used by the content network, Cloudflare, to identify web traffic

formax_anonymousId

10 years

startriteshoes.com

Registers statistical data on the user’s behaviour on the website for internal analytics

_ga

2 years

startriteshoes.com

Registers a unique ID that is used to generate statistical data on how the visitor uses the website

_gat

Session

startriteshoes.com

Used by Google Analytics to throttle request rate

_gid

Session

startriteshoes.com

Registers a unique ID that is used to generate statistical data on how the visitor uses the website

S2Sv4

Session

startriteshoes.com

A Sub2 cookie which stores information such as the presence of an email address, number of pages in the session and whether a user is a customer or guest

STORE_VISITOR

1 day

startriteshoes.com

Unclassified HTTP cookie

V1v4, V2v4, V3v4, V9v4

10 years

startriteshoes.com

Sub2 application cookie which records activity on the website, which is then used to deliver relevant adverts

Marketing Cookies – track browsing preferences and activity to build a profile of search and browsing history and to serve relevant and/or personalised marketing content. We may collect personally identifiable information and use this to display targeted advertising, which may also be shared with third parties for the same purpose.
Cookie Expiry Provider Description

_adroll

1 year

d.adroll.com

Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads

_ar_v4

2083 days

startriteshoes.com

Optimises ad display based on the user’s movement combined and various advertiser bids for displaying user ads

_fbp

3 months

startriteshoes.com

Used by Facebook to deliver advertising from third parties

_tld_

Session

startriteshoes.com

Tracks visitors on multiple websites to present relevant advertising based on user preferences

AA003

3 months

atdmt.com

Optimises relevant advertising based on visitor behaviour collected from multiple websites

adrl

3 months

outbrain.com

Used by Outbrain to analyse user behaviour and the content on the website, enabling us to recommend relevant related content to our users

ajs%3Acookies

1 year

startriteshoes.com

Collects data on visitors to make advertising more efficient

ajs%3Atest

1 year

startriteshoes.com

Collects data on visitors to make advertising more efficient

ajs_group_id

1 year

startriteshoes.com

Assigns visitors into segments based on their behaviour to target advertising to larger groups

ajs_group_properties

Persistent

startriteshoes.com

Collects data on visitors to make advertising more efficient

ajs_user_id

1 year

startriteshoes.com

Collects data on visitor behaviour to assign them to a segment based on common preferences

ajs_user_traits

Persistent

startriteshoes.com

Collects data on visitors to make advertising more efficient

APID

1 year

advertising.com

Unclassified HTTP cookie

ATN

2 years

atdmt.com

Targets advertising based on behaviours and location

bkdc

179 days

bluekai.com

Optimises advertising based on user behaviours on the website and other sites that use the same network

bkpa

179 days

bluekai.com

Used to present the visitor with relevant content and advertising

bku

179 days

bluekai.com

Optimises advertising based on user behaviours on the website and other sites that use the same network

c

Session

rubiconproject.com/p>

Registers anonymised user data, such as IP address, geographical location, visited websites, and what ads the user has clicked, with the purpose of optimising ad display based on the user’s movement on websites that use the same ad network

cart-quantity

Persistent

startriteshoes.com/p>

Registers the user’s shopping cart quantity

CMDD, CMSC, CMST

Session

casalemedia.com

Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads

CMID, CMRUM3

1 year

casalemedia.com

Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads

CMPRO, CMPS

3 months

casalemedia.com

Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads

consent/hod

Session

d.adroll.com

Measures the efficiency of advertising on multiple websites

EE

119 days

exelator.com

Unclassified HTTP cookie

feefoUserId

Persistent

startriteshoes.com

Identifies a user’s Feefo ID

fr

3 months

facebook.com

Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers

getuid

Session

adnxs.com

Synchronises and gathers visitor data from multiple websites

https://cx.atdmt.com/

Session

atdmt.com

Sets a unique ID for the visitor to allow third parties to target the user with relevant advertising

i

1 year

openx.net

Registers anonymised user data, such as IP address, geographical location, visited websites, and what ads the user has clicked, with the purpose of optimising ad display based on the user’s movement on websites that use the same ad network

IDE

1 year

doubleclick.net

Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user

IDSYNC

1 year

advertising.com

Unclassified HTTP cookie

ig_did

10 years

instagram.com

Unclassified HTTP cookie

index.php

Session

startriteshoes.com

Determines shopping cart contents and promotes related products or advertising

KRTBCOOKIE_#

29 days

pubmatic.com

Registers a unique ID that identifies the user’s device during return visits across websites that use the same ad network. The ID is used to allow targeted ads

lastVisitedCategory

Session

startriteshoes.com

Registers the last category visited by a user

lscache-insta_startrite_shoes

Persistent

startriteshoes.com

Unclassified HTML cookie

lscache-insta_startrite_shoes-cacheexpiration

Persistent

startriteshoes.com

Unclassified HTML cookie

obuid

3 months

outbrain.com

Used by Outbrain to analyse user behaviour and the content on the website, enabling us to recommend relevant related content to our users

pagead/1p-user-list/#

Session

google.com

Unclassified pixel cookie

pagevisit

Session

r1.trackedweb.net

Unclassified pixel cookie

PUBMDCID

3 months

pubmatic.com

Registers a unique ID that identifies the user’s device during return visits across websites that use the same ad network. The ID is used to allow targeted ads

PugT

29 days

pubmatic.com

Unclassified HTTP cookie

rlas3

179 days

rlcdn.com

Collects anonymous data related to the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads

sync-his

1 year

tidalTV.com

Sets a unique ID for the visitor that allows third party advertisers to target the visitor

t_gid

1 year

taboola.com

Allocates a user ID to each user who interacts with the widget allowing targeting of relevant content and advertisements

tidal_ttid

1 year

tidaltv.com

Tracks ads provided by Videology that the user has seen or clicked

tluid

3 months

3lift.com

Unclassified HTTP cookie

tr

Session

facebook.com

Unclassified pixel tracker

tuuid

1 year

bidswitch.net

Registers whether or not the user has consented to the use of cookies

tuuid_lu

1 year

bidswitch.net

Identify the user to display relevant ads on the ad exchange network

ud

119 days

exelator.com

Collects anonymous data related to the user’s visit to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads

uuid

1 year

mathtag.com

Collects data on the visitor’s behaviour on the website to target them with relevant advertising

uuid2

3 months

adnxs.com

Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads

uuidc

1 year

mathtag.com

Collects data on the visitor’s behaviour on the website to target them with relevant advertising

recordID

1 year

startriteshoes.com

Displays targeted advertising to improve conversion rate based on products viewed and added to cart

spot/#

Session

flashtalking.com

Unclassified pixel cookie

Turning Off and Deleting Cookies

Many browsers and devices allow all cookies as a default setting. You can manage the cookies that you allow on your device through your internet browser or device. You can also ask to be alerted every time a cookie is offered. Please be aware that many interactive functions of a website are dependent on cookies and therefore turning off or deleting cookies can impact the functionality of a website or app. For some website or app pages requiring a login or authentication, cookies are mandatory and choosing not to accept cookies will likely mean you will be unable to access those pages.

Different web browsers manage cookies in different ways. Below you can find information, directly from the manufacturers, to configure your browser settings.

We do not have control over the third-party sites contained in the above links. No liability can be claimed if the information provided on these sites is inaccurate. Please remember that when you link to a third-party site or request a service from a third party, this Privacy Policy no longer applies.