Sports Connection ApS Privacy Policy

Privacy policy

1. Who are we?

When you visit Sports Connection ApS’ (”our/we”) website www.sportsconnection.dk or communicate with us in any other way, we will receive and process personal data about you. We are the data controller and our contact details are:

Sports Connection ApS
Central Business Reg. 18 13 38 81
Kvaglundvej 89
DK-6705 Esbjerg Ø

E-mail: post@sportsconnection.dk
Phone: +45 75 10 19 80


1.1. Joint controllership

When we process personal data about you within our group (Sports Connection ApS and subsidiaries Skechers Retail Danmark ApS, Skechers Retail Norge AS, SC Retail Sverige AB and Sports Connection Finland Oy as well as ultimate parent company Skechers USA Inc.), the group companies act as joint controllers. When processing your personal data as described below, we disclose your personal data to the companies within the group.

We have entered into a joint controllership agreement stating that we are responsible for providing you with a privacy policy. We are also responsible for making sure, that we have a legal basis for the processing of your personal data, just as we are responsible for making sure, that you can exercise your rights in relation hereto. You can find more information on how to exercise your rights in section 5 or by contacting us via the contact details above.


2.
How do we process your personal data?

In the sections below you will find a description of each processing activity as well as information about the processed personal data, the purpose of processing, the legal basis, disclosures (as well as any third country transfers if relevant) and the retention periods.


2.1. 
Wholesale customers
As a natural part of the establishment and maintenance of the ongoing collaboration with our wholesale customers, we process personal data about you as our customer contact person.

We process personal data in the form of your name, e-mail address and phone number for the purpose of establishing the initial contact, customer registration in our IT-systems, maintaining the ongoing relationship (handling orders, delivery, complaints and returns), conducting customer credit assessments as well as for invoicing and debt collection purposes.

We may disclose your personal data to our external partners who assist with credit assessments, invoicing, freight services and debt collection.

Our legal basis for the processing and disclosure of your personal data is GDPR article 6(1)(f) (legitimate interests), as it is in our legitimate interest to process ordinary personal data about you as a customer contact person in order to maintain the ongoing wholesale customer relationship.


2.2. 
Collaborations with influencers and brand ambassadors
If you collaborate with us as an influencer or a brand ambassador, we process personal data about you for the purpose of managing our ongoing collaboration, including to enter into agreements, send products, approve content and provide you with the agreed payment (to the extent you are entitled to receive payment).

In this context, we process ordinary personal data about you in the form of your name, e-mail address, phone number, address, bank account details, shoe size and pictures of you. Our legal basis for the processing and disclosure of your personal data is GDPR article 6(1)(b) (performance of a contract).

If you are not VAT registered, we will also process confidential personal data about you in the form of your social security number (CPR-number). Our legal basis for the processing and disclosure of your personal data is section 11(2)(1) of the Danish Data Protection Act, as we are legally required to report this information to the Danish Tax Authorities (SKAT).

If, as part of our collaboration, you create content featuring your child, we will also process personal data about your child in the form of the child’s picture and shoe size. Our legal basis for the processing and disclosure of personal data is GDPR article 6(1)(a) (consent), as the processing is based on the consent from the child’s custodial parents.

As part of our collaboration, we will disclose your (and your child’s) personal data in the form of your pictures, as the content you provide us with will be published on our social media profiles on Facebook and Instagram. We will also disclose your personal data to our freight service providers and to the Danish Tax Authorities (SKAT) and our bank when making payments to you.


2.3. 
Social media
We have a company profile on LinkedIn and in relation hereto, we are joint controllers with LinkedIn, particularly for processing involving the use of insights and analytics tools and other similar features. Therefore, we have entered into a joint controllership agreement with LinkedIn, stating that we are responsible for providing you with a privacy notice:

When you interact with our LinkedIn profile, we are joint controllers with LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. As for the part of the processing for which LinkedIn is independently responsible, you can find more information about LinkedIn’s processing of your personal data here.

Insights and analytics tools
Our purpose in using insights and analytics tools offered by LinkedIn is to target our ads to specific audiences on social media and to enable us to generate analyses and statistics about the performance of our advertising campaigns and other online content, as well as your use of our website.

When you visit our website, we thus collect information you related to your behavior on the website and other information collected via cookies, tags, pixels, plug-ins, etc. For further information about our use of cookies, please refer to our cookie policy. We are responsible for ensuring a legal basis for this processing, and we disclose your personal data to LinkedIn.

Our legal basis for the processing of personal data is GDPR article 6(1)(a) (consent). We are responsible for obtaining this consent. You are, at any time, entitled to withdraw your consent by changing your cookie settings in the cookie banner.

Exercising your rights
LinkedIn is independently responsible for ensuring a legal basis for the personal data that LinkedIn processes about you and which they have not received from us.

LinkedIn is also independently responsible for enabling you to exercise your rights under GDPR articles 15-20. You can find more information on how to exercise your rights via the above link to the LinkedIn privacy policy.

If you wish to exercise your rights regarding the personal data stored with us (i.e., information collected through your visit to our website), you can do so as described under section 5.

If you wish to object to the processing of personal data in connection with the use of insights and analytics tools, pursuant to GDPR article 21, you can do so by contacting both LinkedIn and us.


2.4. 
Cookies
Our website uses cookies. When using cookies, we process personal data about you in the form of IP address, device ID, referrers, information about browser or device type, information about your behavior on the website (and across websites), preferences (e.g., regarding language and settings), and unique ID’s.

Essential cookies
When we process personal data about you in connection with the use of essential cookies, the legal basis for the processing is GDPR article 6(1)(f) (legitimate interest), as it is in our legitimate interest to process personal data about you in order to provide a fully functional website.

The purpose is thus to ensure that our website operates optimally.

Non-essential cookies
When we process personal data about you in connection with the use of non-essential cookies, including preference, statistics, and marketing cookies, the legal basis for the processing is GDPR article 6(1)(a) (consent). You are, at any time, entitled to withdraw your consent by changing your cookie settings in the cookie banner.

The purpose of processing personal data in connection with the use of

  • preference cookies is to ensure that the website can remember, for example, chosen language, settings, etc.
  • statistics cookies is to enable us to gain insight into your interactions with our website.
  • marketing cookies is to be able to track your behavior across websites and platforms for the purpose of behavioral advertising.

Use of third-party cookies
When we use third-party cookies, your personal data may be disclosed to such third parties. You can find more information about the respective third parties in the cookie banner. Certain providers of third-party cookies also process your personal data for their own purposes. We thus encourage you to review these providers’ privacy policies via their respective websites.


3.
When will we delete your personal data?

Information used for the maintenance of the ongoing wholesale customer relationship is generally stored as long as the collaborative relationship is active and for a period of 5 years thereafter. However, accounting material is continuously deleted in accordance with the rules of the Danish Bookkeeping Act regarding storage for 5 years plus the current year from the invoice date. Similarly, we continuously delete correspondence received via e-mail and customer support in accordance with our e-mail policy and policy for the storage of complaints and returns. Any correspondence related hereto is stored for a maximum of 2 years from the time of the complaint.

Information processed as part of collaborations with influencers and ambassadors is stored for a period of 5 years plus the current year in accordance with the Danish Bookkeeping Act, although images are only stored as long as they are contemporary in terms of trends and collections, and thus for a maximum period of 4-5 years.

Cookies are stored and deleted in accordance with the specified expiration times in the cookie banner.


4.
Who do we share your personal data with?

When processing your personal data, we use a number of so-called data processors, including providers of IT systems, hosting solutions, etc.

As part of our group structure, we may transfer your personal data to the USA. Such transfers will be based on the EU-Commission’s Standard Contractual Clauses and supplementary measures in the form of a Transfer Impact Assessment.

In connection with our use of Microsoft Office, according to Microsoft’s standard terms and in a very limited scope, there may be a transfer of personal data to countries outside the EU/EEA in cases where we may need to receive support from Microsoft. The transfer is carried out in accordance with Microsoft’s standard terms.

When we use other data processors, as well as providers of third-party cookies, we may transfer your personal data to the USA based on the European Commission’s adequacy decision and the respective data processors’, sub-processors’, or third-party providers’ certification under the EU-US Data Privacy Framework. In addition, we may transfer your personal data to the United Kingdom based on the European Commission’s adequacy decision.


5.
What are your rights?

According to the GDPR and the Danish Data Protection Act you have several rights. If you wish to exercise any of these rights, please contact us by using the contact details provided in section 1 of this privacy policy.

Consent, article 7
Where our processing of your personal data is based on your consent in accordance with GDPR article 6 (1) (a), you have the right to withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on the consent before its withdrawal.

Right to access data, article 15
You have the right to gain access to the personal data we process about you as well as a variety of other information in this regard.

Right to rectification, article 16
You have the right to have any inaccurate personal data about you rectified.

Right to erasure, article 17
Under certain circumstances, you are entitled to request, that personal data about you is deleted before the usual expiry of our retention period.

Right to restriction of processing, article 18
Under certain circumstances, you are entitled to request restriction of the processing of your personal data. If you are entitled to restriction, we may in the future only process your personal data (except for storage) with your consent or for the purposes of establishing, exercising or defending legal claims or protecting a physical person or important public interests.

Right to transmit data (data portability), article 20
Under certain circumstances, you are entitled to receive your personal data in a structured, commonly used and machine-readable format, and to have such data transmitted from one data controller to another without hindrance.

Right to object, article 21
At any time you have the right to, on grounds relating to your situation, object to processing of your personal data, which is based on our legitimate interests, cf. GDPR article 6 (1) (f).

You are also entitled to object to our processing of your personal data for direct marketing purposes.

Further information and filing complaints
You can find more information about your rights in the Danish Data Protection Agency’s guidance on the rights of data subjects.

You may file a complaint about our processing of your personal data with the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, DK-2500 Valby, e-mail: dt@datatilsynet.dk, phone: +45 33 19 32 00.