Privacy and Cookie Policy

Last Updated: May 25, 2018

I. Privacy Policy

II. Cookie Policy

I. Privacy Policy

Thank you for placing your trust in New Balance. We are committed to protecting your privacy and take our responsibilities regarding the safety and security of customer’s personal information very seriously. This Privacy Policy describes what personal information we collect about you, how and why we collect and use it, who has access to it and what your privacy rights are. Please review it carefully.

This Privacy Policy is provided in a layered format so you can click through to the specific sections set out below:

1. When Does This Privacy Policy Apply to Me?

2. Who Is Responsible for My Personal Information?

3. What Personal Information Does New Balance Collect About Me and How?

4. For What Purposes Does New Balance Use My Personal Information?

5. What Is the Legal Basis For New Balance’s Use of My Personal Information?

6. With Whom Does New Balance Share My Personal Information?

7. How Is My Personal Information Kept Secure?

8. International Transfers of Personal Information

9. What Is the New Balance Children's Privacy Policy?

10. How Do Links from New Balance To Other Sites Or Apps Affect Me?

11. For How Long Does New Balance Keep My Personal Information?

12. What Are My Privacy Rights?

13. How Can I Opt-Out/Unsubscribe from New Balance Marketing Emails?

14. How Can I Access, Update or Delete "My Account" Information?

15. How Can I Contact New Balance If I Have Questions or Complaints About This Privacy Policy?

16. Changes to This Privacy Policy and Your Duty to Inform Us of Changes

Please note that you have the right to object to us processing your personal information for our legitimate business purposes or for direct marketing purposes (including any related profiling we do to help ensure that our marketing is relevant to our customers’ interests). For more information about your right to object and how you can exercise it, please see section 12. What Are My Privacy Rights?

1. When Does This Privacy Policy Apply to Me?

This Privacy Policy applies to all personal information collected by New Balance Athletic Shoes (U.K.) Limited and its affiliates, either in New Balance retail stores or through the operation of the following services:

• www.newbalance.co.uk, and any other website operated by or on behalf of New Balance Athletics Shoes (U.K.) Limited, including but not limited to the following (the "Website"):
• www.newbalance.de
• www.newbalance.es
• www.newbalance.pt
• www.newbalance.ie
• www.newbalance.se
• www.newbalance.lv
• si.newbalance.eu
• www.newbalance.fr
• www.newbalance.it
• www.newbalance.be
• dk.newbalance.eu
• fi.newbalance.eu
• www.newbalance.lu
• ee.newbalance.eu
• lt.newbalance.eu
• nl.newbalance.eu
• at.newbalance.eu
• www.newbalance.com.gr
• www.newbalance.co.hu
• cz.newbalance.eu
• www.nbblackoutsquad.com;
• all services made available by New Balance through the Website; and
• the Stride I.D. Experience made available by New Balance in selected stores.

For the purpose of this Privacy Policy, the services listed above (including the operation of New Balance retail stores) are referred to collectively as, the "Service”.

This Privacy Policy applies whether you are a "Visitor" (which means that you simply browse the Service) or you are a "Member" (which means that you have registered for “My Account” with New Balance, have purchased any products on our Website or used any component of the Service).

2. Who Is Responsible for My Personal Information?

New Balance Athletic Shoes (U.K.) Limited (a company registered in England and Wales with company number 01616165 and registered address at Appleton House, 430 Birchwood Boulevard, Birchwood, Warrington, Cheshire, WA3 7WD, UK) and New Balance Athletics, Inc. (a company registered in Massachusetts, USA and registered address at 100 Guest Street, Boston, MA 02135 USA) are the joint “data controllers” of the personal information that is collected about you when you use the Service (referred to in this Privacy Policy as “New Balance”, "we", "us", or "our"). This means that we control the ways your personal information are collected in connection with the Service and determine how and why such personal information is used for the purposes of applicable data protection law.

3. What Personal Information Does New Balance Collect About Me and How?

Personal information (or personal data) is any information which identifies you personally whether directly (for example, your name) or indirectly (for example, information about your use of the Service).

Information you give to us

We collect the following personal information from you:

• Basic identity and contact information: We collect your name, title, postal/delivery address, email address and telephone number if you purchase any products on our Website. We may also collect some or all of this information if you:
• register for “My Account” on our Website;
• complete the “About Me” questionnaire to tell us about your shopping preferences, in which we may also collect your gender, shoe size, shoe width, clothing size, hobbies, shopping preferences, information about your weekly workouts and whether you have kids and their genders;
• sign up to receive our marketing communications;
• enter any of our competitions, contests, promotions, surveys or questionnaires, in which we may also collect your social media handle(s);
• contact or correspond with us about the Service (or any component of it); and/or
• participate in a New Balance run club.
• Payment information: We collect your payment card details and billing address if you purchase any products on our Website. We won’t retain your payment card details for longer than is necessary in order to fulfil your order. However, if you register for “My Account", you can choose to store your payment card details in your account so that you don’t have to re-enter your full payment card details the next time you make a purchase. Please see section 7. How Is My Personal Information Kept Secure? to find out more about how we safeguard your payment card details;
• Transaction information: We keep a record of your order history, including the products purchased and the date, time and value of each transaction, and your billing and shipping address;
• Account login: If you register for “My Account”, we keep a record of your account login username and email address in case you need reminding of these in the future;
• Correspondence and feedback: We collect any additional personal information that you may provide to us from time to time when you visit a New Balance retail store, if you complete a survey or questionnaire or contact us by email, letter, telephone or through our Website. If you contact us by telephone, we may also record the call for training and service improvement purposes, and make notes in relation to your call; and
• Marketing and communications preferences: We collect information regarding your preferences in receiving marketing from us and your communications preferences.

Information you give to us if you participate in the Stride I.D. Experience

The New Balance Stride I.D. Experience features scan technology provided by our technology provider Volumental that uses infrared imaging to create a three-dimensional (3D) image of your feet and collects key measurements about you and your feet, including your gender, foot length, foot width, arch height, strike, flexibility and foot size. The scan technology also creates a shoe profile including foot size and foot width in order to generate a 3D mesh image of your feet.

The scan technology can also be combined with gait analysis technology, which involves conducting a video analysis of your feet as you run to measure your gait.

We also collect information about the shoe model you try on and if you make a purchase.

Together, this information is used to help us provide a better fit recommendation matched to your needs and find the perfect shoes to optimise the performance of athletes.

Where you elect to receive a copy of your 3D foot scan (and where applicable a snapshot image from your gait analysis video) we also collect your name, email address, telephone number and age range and retain this information with your Stride I.D. and gait measurement metrics. If you elect not to receive a copy of your 3D foot scan image or snapshot image from your gait analysis video, we will delete your gait analysis video and will retain only the resulting measurement data from which we cannot identify you. We retain this information in order to better understand and improve how our products fit.

We share the measurement data (but never your contact information) with Volumental, who use this information to improve their scanning technology. Volumental also retains the raw infrared images from your scan and the resulting 3D mesh image for the same purpose of improving their foot scanning technology to offer customers best fit solutions. We never share any contact information (such as your name or email address) with Volumental. If, after your scan, you object to the processing as described in this section, we will delete your scan and any measurement data and instruct Volumental to do the same.

Information we collect from other sources

We also obtain information about you from other sources:

• CCTV: If you visit a New Balance retail store, we may collect your image as a result of our use of CCTV.
• Cookies and similar technologies: When you visit our Website we use cookies and similar technologies, such as web beacons and pixel tags, to automatically collect information about:
• your browsing activity and use of the Service; and
• the device you have used to access our Website (including the make, model and operating system, internet protocol (IP) address (from which we may derive your geographic location), browser type and mobile device identifiers).

We also engage third parties who place cookies on our Website to collect the same or similar information and share the information with New Balance. Please see our Cookie Policy for further details.

Social Media: If you mention New Balance or New Balance-related information in a posting on any social media platform, such as Facebook, Instagram or YouTube, we may collect publicly-available information about your post, including your name, social media handle, your location, the date and time of your post, the content of your post and any images and/or videos included with your post. We will only collect data that the social media provider has expressly permitted us to receive as a result of your privacy settings on those social media platforms. We do not have any control over the privacy practices of the social media platforms; please see their privacy statements for details of how they use your personal information, whom they share it with and how to manage your privacy settings on those platforms.

Fit Finder: If while on the Website you use our “Fit Finder” feature, we will collect your height, weight, body shape, clothing size, sizing preferences and age in order to recommend a size that fits you based on sizes purchased by other people similar to you. You are not identifiable from the information you submit and we do not link any information you provide through this feature with you or your account.

Except for information we collect through the operation of CCTV in New Balance retail stores, which we keep separate at all times, we may combine the personal information we collect from you and from the other sources listed above. We do this to help us ensure that the information we hold about you is kept up to date and to form a clearer picture about our customer base so that we can understand the kinds of offers in which you might be interested and improve the Service in the future.

4. For What Purposes Does New Balance Use My Personal Information?

We use the personal information that you submit to us or that we collect about you through your use of the Service for the following purposes:

To process your orders and returns

We need to use your personal information to process any orders and returns you make in accordance with our Terms and Conditions. This activity includes contacting you to confirm when you have successfully placed an order, managing payments, fees and charges, and collecting and recovering any money owed to us. It requires us to process your identity and contact information, payment information and transaction information.

To register you for, and manage, "My Account”

If you wish to create an account using the "My Account" service, we need to process your identity and contact information. You will also be asked to provide account login details. Once the account has been created, we use this information to identify you as a new or returning customer and manage your account going forwards. This includes keeping a record of your account login details (your username and email address) in case you need reminding of these in the future.

To provide you with the services available through our Website

In order to provide certain services through our Website, we need to process your personal information. For example, New Balance uses your personal information for the following purposes with respect to providing you with services available through our Website:

• “Find a Store” feature: by inputting your post code or city, we can help you to locate a New Balance retail store;
• Inventory: We use your location information to provide you recommendations of stores nearby that have product inventory available;
• “Help” or “Live Chat”: New Balance customer service representatives may communicate with you in real time to assist you with any questions you have while you are on the Website;
• Idea Submission: to submit an invention and idea for New Balance’s evaluation, we request you to fill out a submission form with your name, company, address, phone and email so we may contact you if needed regarding your submission;
• Job Application: if you apply for a job through our Website, you will be taken to our third party provider Workday’s site and asked to provide an email address to create a Workday account;
• “Fit Finder” feature: we collect sizing and other personal information to assist us with recommending a size for a particular product; and/or
• Newsletter: to sign up to our newsletter, we will collect your email address in order to send you the newsletters.

To manage your relationship with us

We use your identity and contact information to manage our relationship with you in connection with the Service, including notifying you of changes to the terms of any contracts between us or to any related information (such as changes to this Privacy Policy).

To operate the Stride I.D. Experience

If you participate in the Stride I.D. Experience and have provided your consent to do so, we use the information collected from you to:

• send you a copy of or provide access through your New Balance Account to your 3D foot scan and (where applicable) a snapshot image from the video of you running for your gait analysis;
• provide analysis and advice as to which products are best suited to your needs;
• call you to get your feedback on your Stride I.D. Experience and find out how our products are performing;
• contact you by telephone or email about other New Balance products, services and offers where you have consented to receiving these marketing communications from us; and
• carry out analysis on the information received (on an aggregated, non-identifiable basis) to help improve the Stride I.D. Experience.

For more information about the Stride I.D. Experience, see section 3. What Personal Information Does New Balance Collect About Me and How.

To keep New Balance retail stores secure

We operate CCTV at our retail stores where necessary to monitor security and safeguard the safety of visitors and staff. There are prominent signs in the areas where CCTV is operated. Your image may be collected if you visit one of our stores. Any CCTV footage is automatically deled after three months.

Please note that access to CCTV footage is restricted to authorised New Balance staff only. It is not shared with any third party, except law enforcement agencies in limited circumstances where we are required to make such disclosure by law for the prevention and detection of crime.

To deliver relevant marketing to you (which involves automated decision-making and profiling in order to personalise and improve your customer experience)

Our marketing communications

If you have provided your consent to do so, we will use your identity, contact information and preferences to send you marketing communications by email about our products and services, including our newsletters and details of special offers and promotions which we think might be of interest to you.

You can unsubscribe or opt-out of our marketing communications at any time. See section 13. How Can I Opt-Out/Unsubscribe from New Balance Marketing Emails? for details of how to do this.

Our use of automated decision-making and profiling

We want to ensure that the marketing communications we send to you are relevant to your interests. Consequently, we use cookies and other similar technologies (if you have accepted them) to track and analyse your use of our Website, the services available through them and your interaction with any marketing communications that we send to you to help us build a profile of your preferences. For example, we collect information on how you browse our Website, including the web pages or products you have viewed or put in your shopping basket, in order to help us understand what you like.

What this means for you is that, if you have agreed to receiving marketing communications from us, you are more likely to receive messages, special offers and promotions that we think you might like and are tailored to your preferences, based on your previous activity. It also means that we do not send the same marketing communications to all of our customers, so you may not be made the same offers as another customer.

In addition, we may use the information we collect about your preferences in order to display content and offers on our Website and other websites and apps that are more relevant to you and your interests.

This may include delivering targeted advertising on our Website or other websites and apps that you access, or limiting the number of times you see a particular advertisement.

Please see our Cookie Policy to find out more about our use of cookies and how you can manage your cookie preferences.

If you don’t agree with an automated decision that our technology has made in relation to you or you wish to object to us using profiling to send you tailored marketing communications and deliver targeted advertising, you can let us know (see section 15. How Can I Contact New Balance If I Have Questions or Complaints About This Privacy Policy?). If you do object, we won't be able to continue to send you tailored marketing communications, which means the offers you receive from us may not be as relevant to you.

Please note that the legal basis for us tailoring our marketing communications to your preferences is that it is in our legitimate interests to do so, having taken into account whether your interests and fundamental rights and freedoms are overridden by this type of processing. See section 5. What Is New Balance’s Legal Basis for Its Use of My Personal Information? for more information about what our legitimate interests are.

To communicate with you on social media

If you include New Balance or New Balance-related information in a social media posting, we may use the publicly-available information that you post to communicate with you regarding the post. We may also aggregate the data with data from other social media posts regarding New Balance (from which you cannot be identified) to better understand and more effectively manage New Balance’s social media presence and marketing campaigns.

To run competitions and contests

If you choose to enter a competition, contest or survey that we run, including those that we run on third party sites, we need to use your identity and contact information and any other personal information that you provide at the time of entry so that we can manage the competition or contest (as applicable).

To administer and protect our business and Website

We process your personal information in the course of administering our business and Website. This includes troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

To use data analytics to improve our Website marketing and the services available through our Website

We rely on the use of personal information to build a clearer picture of our customers both as a group and as individuals. We do this by using cookies and similar technologies to capture and analyse your use of our Website, the services available through them and your interaction with any marketing communications that we send to you. We may also aggregate this information on an anonymous basis with information relating to other customers for analytical purposes.

This enables us to serve you better as a customer as the information we gather helps us to improve:

• our Website and the information technology systems (including security) that are used to operate them;
• our product selection and the services we provide through our Website; and
• the effectiveness of our marketing communications to you.

Please see our Cookie Policy to find out more about our use of cookies and how you can manage your cookie preferences.

To provide and improve Customer Care

We use your personal information to be able to provide and improve our Customer Care service. For example, we use the personal information we hold about you to help us address any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing the Service to you.

To conduct market research

We may invite you to be involved in market research, such as customer surveys or questionnaires. If you accept our invitation, we will use your feedback to improve the Service. If you tell us that you don't wanted to be contacted about market research, or you don't accept our invitation, we will respect this choice and it won't affect your ability to access and use the Service.

To comply with our legal obligations and to detect, prevent and investigate other actual or suspected violations of law or misuse of our Service

In certain circumstances, we use your personal information only to the extent required in order to enable us to comply with our legal obligations, including to detect, prevent and investigate fraud or to facilitate the exercise of your consumer rights. In addition, we may need to use your personal information to detect, prevent and investigate any other actual or suspected violations of law or misuse of our Service.

5. What Is the Legal Basis for New Balance’s Use of My Personal Information?

Data protection law requires us to only process your personal information if there is a legal basis for us to do so. These are set out in data protection law and we rely on a number of different legal bases for the processing we carry out. These are as follows:

Consent

In certain circumstances, we process your personal information after obtaining your consent to do so for the purposes of:

• sending you marketing communications;
• conducting market research; and
• operating the Stride I.D. Experience and providing our customers with advice on their best shoe fit in connection with the Stride I.D. Experience.

Necessary for the performance of a contract between us

It is necessary for us to process your identity and contact information, payment information, transaction information and account login details for the performance of certain contracts between us. This includes, for example, terms and conditions relating to the use of our Website and the services made available through it, the sale of our products and the operation of our competitions and contests. In particular, we rely on this legal ground to process your orders, returns and payments, register you for “My Account”, manage your account and your relationship with us, run competitions and contests and provide and improve Customer Care.

Necessary to comply with our legal obligations

In certain circumstances, we use your personal information only to the extent required in order to enable us to comply with our legal obligations, including to detect, prevent and investigate fraud or to facilitate the exercise of your consumer rights.

Necessary for the purposes of our legitimate interests

It is sometimes necessary for us to collect and use your personal information in accordance with this Privacy Policy for the purposes of our legitimate interests as a business, which are to:

• provide our customers with products and services that are as useful and beneficial as possible, including by personalising our contact with customers and telling customers about offers that we think might be of interest to them;
• develop and improve our Website to enhance the customer experience;
• safeguard the security and effective operation of the Service;
• better understand our customer base by engaging with customers and conducting research into, and analysis of, how customers use each of our services and interact with us so that we can improve those services as well as our product selection, marketing activities and communications (all of which could also benefit you);
• train our staff so that we can provide our customers with a better customer service;
• ensure effective operational management and internal administration of our business, including in relation to keeping our records, Website updated, document retention, IT security, compliance with regulatory guidance and exercise or defence of legal claims; and
• provide a safer, more secure environment for visitors and staff at New Balance retail stores, and to protect our property.

Please contact us if you would like further information regarding the balancing tests that we have carried out (see section 15. How Can I Contact New Balance If I Have Questions or Complaints About This Privacy Policy?).

6. With Whom Does New Balance Share My Personal Information?

For the purposes described in this Privacy Policy, we may have to share your personal information with the following third parties:

New Balance affiliates: Our business is headquartered in the U.S. and we operate on a global scale. In order to provide the services you request from us, including participation in the Stride I.D. Experience, our affiliates and participating stores may need to access your personal information. Our affiliates will only use your information for the purposes for which it was originally collected in accordance with this Privacy Policy. Some of our affiliates are located in countries outside of the EEA and where we transfer your information outside of the EEA, we do so under specific contracts approved by the European Commission, which give personal information the same protection it has within the EEA as further described in section 8. International Transfers of Personal Information.

Third party service providers: For the purpose of operating our business, we may need to transfer your personal information to our third party service providers who use that information to conduct New Balance business on our instructions and act as “data processors” on our behalf for the purposes of applicable data protection law. Some of our third party service providers are located in countries outside of the EEA and where we transfer your information outside of the EEA, we make sure adequate safeguards are used to protect your personal information, including using specific contracts approved by the European Commission and/or ensuring the service providers located in the United States are part of the EU-US Privacy Shield as further described in section 8. International Transfers of Personal Information.

For example, our third party service providers assist us with credit card processing, shipping, data management, email distribution, information analysis, promotions management and other related services for New Balance. We provide our preferred service providers with the personal information they need to perform their services and work with them to ensure your personal information is protected.

Where you elect to participate in the Stride I.D. Experience, we share certain information with Volumental as described in section 3. What Personal Information Does New Balance Collect About Me and How.

Third parties providing targeted product recommendations and other communications: We use third party companies to help serve targeted product recommendations and other communications. To enable these companies to provide you with targeted recommendations and other communications, we may provide these companies with certain personal information about you, such as your name, address and email address, as well as your transaction history. These third parties may also collect information about your browsing activity on the Website by using cookies and similar technologies. These companies may use such data about you in order to provide recommendations for products and services that might be of interest to you. Some of these companies who provide targeting marketing services to New Balance are located in countries outside of the EEA and where we transfer your information outside of the EEA, we make sure adequate safeguards are used to protect your personal information, including using specific contracts approved by the European Commission and/or ensuring the service providers located in the United States are part of the EU-US Privacy Shield as further described in section 8. International Transfers of Personal Information. If you wish to opt-out of this program, you can let us know (see section 15. How Can I Contact New Balance If I Have Questions or Complaints About This Privacy Policy?).

Recipients resulting from legal requirements: We may disclose your personal information:

if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of our business, our customers or others. This includes, in specific cases, sharing information with law enforcement or regulatory agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or actual or suspected violation of law or misuse of our Service that may expose us and/or any customer or third party to legal risks or liability; and

to successors in title or replacement operators of all or part of our business.

7. How Is My Personal Information Kept Secure?

We have put in place a variety of security measures to protect the personal information we collect about you from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed.

For example, to ensure the information you provide online is secure during transmission, we use encryption technology and Secure Socket Layers (SSL). These controls are certified by DigiCert®. You can review our security certificate using your browser by clicking on the closed lock or solid key image at the bottom of your browser on any of the secure pages on our site. This will display the Service security information.

As mentioned above, you can choose to store your credit/debit card information in your "My Account" if you wish. To protect your security in these circumstances, we encrypt all stored credit/debit card information and we do not store your card's CVV/CVC number (which, as a precautionary measure, you are required to provide each time you place an order with us). If you choose not to store your credit/debit card information in an account with us, we will only temporarily store your entire encrypted credit/debit card information for as long as is necessary in order to validate your credit card (for example, to automatically contact a credit card company for verification). Once we have done this, we will securely delete your credit/debit card information from our systems.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know for the purposes set out in this Privacy Policy. They are required to only process your personal information in accordance with our instructions and are subject to a duty of confidentiality.

8. International Transfers of Personal Information

The personal information we collect about you is stored on secure servers located within the European Economic Area (“EEA”) and the United States. In addition, for the purposes set out in this Privacy Policy, we may transfer personal information we hold about you outside the EEA to the third parties identified in section 6. With Whom Does New Balance Share My Personal Information?

The countries concerned may not have similar data protection laws to the EEA. We are required by data protection law to ensure that where we or the third parties listed in this Privacy Policy transfer your personal information outside of the EEA, it is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Privacy Policy. We do this by ensuring that at least one of the following safeguards is implemented:

• In accordance with GDPR Article 46(2), we use specific contracts approved by the European Commission, which give personal information the same protection it has within the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• In accordance with GDPR Article 45, where we use service providers based in the United States, we may transfer personal information to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the EU and US. For further details, see European Commission: EU-US Privacy Shield.

The information in section 6. With Whom Does New Balance Share My Personal Information? sets out details of which of these safeguards is used to transfer your personal information to each of the third parties based outside of the EEA.

Please ask us if you would like more information about the safeguards that are used to protect your personal information when it is processed outside the EEA (see section 15. How Can I Contact New Balance If I Have Questions or Complaints About This Privacy Policy?).

9. What Is the New Balance Children's Privacy Policy?

We do not knowingly collect personal information from anyone under the age of 13 (a "Child"), including from any Child who participates in the Stride I.D. Experience. If you become aware that your Child or a Child for which you have parental responsibility has provided personal information to us without your consent, contact Customer Care toll-free at 0800 802 1057 or email customercare@newbalance.co.uk.

If we become aware that a Child has submitted personal information to us, we will promptly delete the information and we will not disclose it to third parties.

10. How Do Links from New Balance to Other Sites or Apps Affect Me?

At times, we may provide links from our Website to other websites and applications operated by third parties. These links are provided only for your convenience and intended to add value to your visit. However, we do not have control over these websites and applications, which are independent from New Balance and are subject to separate privacy policies and terms and conditions. When leaving our Website, you need to be aware that this Privacy Policy no longer applies and we are not responsible for your information that third parties may collect through these websites and applications. We strongly encourage you to review the privacy policies and terms and conditions of any third-party websites and applications before using them.

11. For How Long Does New Balance Keep My Personal Information For?

We retain your personal information for no longer than is necessary for the purpose(s) for which it was provided in accordance with this Privacy Policy. What this means in practice will vary between different categories of personal information. When determining the relevant retention periods, we take into account factors including:

• legal obligation(s) under applicable law to retain information for a certain period of time;
• statute of limitations under applicable law;
• the warranty period for any products you have purchased from us;
• potential or actual disputes; and
• guidelines issued by relevant data protection authorities.

Otherwise, we securely delete your personal information from our systems when it is no longer needed.

12. What Are My Privacy Rights?

You have the following rights with regard to your personal information: