This Privacy Shield Policy ("Policy") describes how FLEET FEET, INCORPORATED and its U.S. affiliates Fleet Feet Sports Development Company, LLC; FFS Digital, LLC; The Original, LLC; Robinsons on the Run, LLC ("Company," "we," or "us") collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA Personal Data”). This Policy applies to the following US affiliated entities: (i) FLEET FEET, INCORPORATED and (iii) FLEET FEET SPORTS DEVELOPMENT COMPANY, LLC. This Policy supplements our Website Privacy Policy located at www.fleetfeet.com/privacy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

We recognize that the EEA has established strict protections regarding the handling of EEA Personal Data, including requirements to provide adequate protection for EEA Personal Data transferred outside of the EEA. To provide adequate protection for certain EEA Personal Data about consumers received in the US, we have elected to self-certify to the EU-US Privacy Shield Framework.

Fleet Feet, Incorporated complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries transferred to the United States pursuant to Privacy Shield. Fleet Feet, Incorporated has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

For purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the US Federal Trade Commission. To review our representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: www.privacyshield.gov/list

1. Personal Data Collection and Use

In addition Website Privacy Policy located at www.fleetfeet.com/privacy, which describes the categories of EEA Personal Data that we may receive in the US as well as the purposes for which we use that EEA Personal Data online and how we share that data with third parties, we may collect personal data within our stores that is transmitted between the EEA and US. This in-store data includes physical characteristics related to an indiviudal’s foot size and shape from a customer’s voluntary use of the fit id scanning system. This data is then used to recommend the best-fitting shoe to that customer. We will only process EEA Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. Before we use your EEA Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. We maintain reasonable procedures to help ensure that EEA Personal Data is reliable for its intended use, accurate, complete, and current.

2. Data Transfers to Third Parties

a) Third-Party Agents or Service Providers. We may transfer EEA Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. In addition, we may transfer data to third-parties for uses in connection with the fit id foot-scanning system. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection as set forth in this policy, and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA Personal Data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA Personal Data that we transfer to them.

If we transfer your EEA Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EEA Personal Data is protected with the same level of protection as set forth in this policy.

b) Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your EEA Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

3. Security

We maintain reasonable and appropriate security measures to protect EEA Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

4. Access Rights & Choice

You may have the right to access the EEA Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

We will also provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to the contact information provided below.

5. Questions or Complaints

In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. EEA individuals with Privacy Shield inquiries or complaints should first contact Joey Pointer at:

Fleet Feet Sports
Re: Privacy Compliance
310 East Main Street, Suite 200
Carrboro, North Carolina 27510

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

6. Contact Us

If you have any questions about this Policy or would like to request access to your EEA Personal Data, please contact us as follows:

Fleet Feet Sports
Re: Privacy Compliance
310 East Main Street, Suite 200
Carrboro, North Carolina 27510

7. Changes To This Policy

We reserve the right to amend this Policy from time to time consistent with the Privacy Shield's requirements.

Effective Date July 22, 2018