Privacy Notice for California Residents

Last Reviewed on: October 16, 2024

Fleet Feet California Consumer Privacy Act Notice Summary

This Fleet Feet California Consumer Privacy Act Notice (“California Notice”) supplements the information contained in Fleet Feet’s Privacy Policy. This California Notice (i) applies solely to consumers who reside in the State of California, and to information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer, household or device, and (ii) describes how we handle your personal information, the reasons we do so, and the rights you have as a California resident regarding your information. Fleet Feet provides this California Notice to comply with our obligations in our capacity as a “Business” under the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020 (“CPRA”)) and its implementing regulations (collectively, “CCPA”), and serves as Notice at Collection under the CPRA. Any capitalized term used in this California Notice, but not defined will have the meaning ascribed to it in the CCPA or our Privacy Policy, as applicable.

What are the Categories of Personal Information Collected?

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Reviewed/Updated date of this California Notice) the categories of personal information listed below. Not all categories will be collected or received for every individual.

  • Identifiers: Personal identifiers, such as name, alias, telephone number, physical address, email address, your Fleet Feet account log-in information, and signatures
  • Customer Records: Personal information, such as name, email address, phone numbers, dates of birth, physical address, driver’s license number, employment, bank account number, debit/credit card number or other financial information
  • Protected Classification Characteristics: date of birth, gender, and education
  • Device Information and Online Activity: Device and online identifiers, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information
  • Commercial Information: Purchase and transaction history information (such as products or services you have purchased, rented, or returned), health and safety-related information, product testimonials, travel and vacation information, and competition entries
  • Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where Walmart is a party to the exchange
  • Demographic Information: Demographic information, such as date of birth
  • Financial Information: Financial information, such as credit or debit card numbers or other payment information, financial account numbers, and claims information
  • Biometric Information: Biometric information, such as foot imagery
  • Geolocation Information: Physical location information
  • Professional or employment-related information: Current or past job history
  • Inferences: Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors, intelligence, and aptitudes
  • Sensitive Personal Information: Account log-in and financial information (such as credit card and other payment details)

What are the Categories of Sources from Which We Collect Your Personal Information?

We may obtain and combine personal information from different sources, as described in the How Do We Collect Information section of the Fleet Feet Privacy Notice and provided below:

  • Provided directly by you or a member of your household
  • Collected from a device associated with you or your household
  • Collected through in-store technology
  • Collected through our service providers and vendors
  • Collected from another company within our family of companies and franchises and each of their respective service providers and vendors
  • Collected from an external third party source
  • Collected from other sources, when it is appropriate, to help us correct or supplement our records, improve the quality or personalization of our services, increase the appeal and relevance of advertising, and to prevent or detect fraud

What are the Purposes for Collecting Personal Information?

We may use your personal information for the purposes as provided below:

  • All uses described under the “How We Use Your Information” section of the Fleet Feet Privacy Policy.
  • To conduct recruiting and candidate evaluation activities and to inform our employment decisions.
  • To provide, support, personalize, and develop our Sites and Services.
  • To audit our interactions with you, such as counting impressions or verifying the quality and effectiveness of content including advertisements.
  • To prevent malicious, deceptive, fraudulent, or illegal activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity.
  • To maintain the safety, security, and integrity of our Sites, Apps, other technology assets, and our Services, including the detection of security incidents.
  • To debug, identify, or repair errors or effectuate similar functional enhancements in connection with our Services.
  • To develop, improve, and deliver marketing and advertising, including targeting advertising.
  • Product recommendations based on preferences and biomechanical information, including foot scans with videos of walking and/or running motion data
  • For internal operational uses such as research, analytics, development, audits, and security.
  • For legal and operational compliance purposes, such as monitoring whether our operations are effectively implementing this policy.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
  • To engage in or enable internal uses consistent with our relationship with you, or compatible with the context in which you provided the information, such as internal research and development.
  • For any other purpose described to you when collecting your personal information before or at the time of collection.

We use sensitive personal information for some of the purposes described above and to make inferences about customers, which we may use to promote certain products or services.

To the extent we process de-identified information, we will maintain and use the information in de-identified form and will not attempt to reidentify the information unless permitted by applicable law.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sale and Sharing of Personal Information

Disclosing Personal Information for Business Purpose:

We may share or disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

During the twelve (12) months prior to the “Last Reviewed” date identified at the beginning of this California Notice, Fleet Feet has disclosed the following categories of personal information for a business purpose:

· Identifiers.

· Personal information.

· Protected classification characteristics under California or federal law.

· Commercial information.

· Biometric information.

· Internet or other similar network activity.

· Inferences.

We disclosed your personal information for a business purpose to the following categories of third parties:

  • Affiliated companies
  • Vendors.
  • Service providers.

· Franchisees and their affiliated companies, service providers and vendors.

Sales of Personal Information

In the past twelve (12) months prior to the “Last Reviewed” date of this California Notice, Fleet Feet has sold or shared for cross-context behavioral advertising the following categories of personal information to these categories of third-party recipients:

Category of Personal Information Sold or Shared

Category of Third-Party Recipient

Identifiers – Email Addresses

· Vendors

· Service Providers (such as advertising networks, analytics providers, etc.)

Stop Selling or Sharing My Personal Information

If you are 16 years of age or older, you have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising.

Your opt-out request (more information here) may be processed differently depending on whether you are logged into your account. If you are logged in, your preference will be associated with your account, and the device on which you exercised your choice. When you log in from another device or browser, it too will be automatically opted out. If you are not logged into your account, your request will only be associated with that one browser.

How Long Do We Retain Your Personal Information?

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in our Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal Fleet Feet policy. We dispose of the information we collect in accordance with Fleet Feet’s retention policies and procedures.

What Are Your California Privacy Rights?

The CCPA provides California residents with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request (see the section below on Exercising Access, Deletion, Correction, and Opt-Out Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for personal information we collected about you.
  • The business or commercial purpose for collecting, sharing or selling your personal information.
  • The categories of third parties with whom we share your personal information.
  • The specific pieces of personal information we collected about you.
  • A list of categories of personal information that we have sold or shared for cross-context behavioral advertising, along with the categories of third parties we sold it to or shared it with for cross-context behavioral advertising.

· A list of categories of personal information that we have disclosed for a business purpose, along with the categories of third parties to whom we disclosed such information.

Deletion Request Rights

You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct our service providers to do the same. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of in-store functions that require your personal information.

Correct My Personal Information Request Rights

You have the right to ask that we correct the personal information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law.

Limit the Use and Disclosure of Sensitive Personal Information

We limit our use of your Sensitive Personal Information for only a business purpose and as permitted by law.

Exercising Access, Deletion, Correction and Opt-Out Rights

To exercise the access, deletion, collection or Opt-Out rights described above, please submit your request to us by either:

Requests to access your personal information may be submitted up to two (2) times in a rolling twelve-month period.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child.

When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent disclosure of your personal information resulting from fraudulent requests. You may be asked to log into your online account and complete a one-time passcode validation. In the event more documentation is necessary to verify your identity, we will notify you directly.

What If You Can’t Verify My Identity?

If we can’t verify your identity, we will notify you, and your request(s) to access, delete, or correct your personal information or to opt-out may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.

How Do I Submit a Request Using an Authorized Agent?

If you’d like an authorized agent to exercise your rights for you, they may use the same links described above to submit requests. We require documentation demonstrating your agent’s authority to submit requests on your behalf. For example, a valid power of attorney or other documentation, including a letter, signed by you (the California resident) authorizing the agent to submit your requests. Documentation may be uploaded at the time you submit your request on our website or provided to us up to ten (10) business days after. If you submit your request by calling, you can email your forms to privacy@fleetfeet.com.

Your request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or an authorized representative, and
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Response Timing and Format

We endeavor to respond to a personal information request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver an electronic written response to the email address associated with the request. We can also respond by mail, at your option.

We do not charge a fee to process or respond to your personal information request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision, and we reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request if it is excessive, repetitive, or manifestly unfounded.

We endeavor to comply with a request to opt-out within fifteen (15) days of its receipt. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize our sale of your personal information or sharing of your personal information for cross-context behavioral advertising. However, you may change your mind and opt back in to our sales of your personal information or the sharing of your personal information for cross-context behavioral advertising at any time by either:

Non-Discrimination

You have a right to not receive discriminatory treatment for exercising your CCPA rights, and we will not discriminate against you for exercising any of your CCPA rights.

Shine the Light

California residents also have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address below.

Notice of Financial Incentive

If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do so.

Contact our privacy team at privacy@fleetfeet.com with any questions or comments about this notice or about how we handle your personal information. The Data Privacy Office’s address is:

Fleet Feet, Inc.

Re: Data Privacy

310 East Main Street, Suite 200

Carrboro, NC 27510

Changes to this California Notice

We reserve the right to amend this California Notice at our discretion and at any time. When we make changes to this California Notice, we will post the updated notice to our Sites and update the notice’s date. Your continued use of our Sites and Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy and this California Notice periodically for updates.