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Privacy Policy

Revised & Effective May 15, 2018

Aetrex Worldwide, Inc. (“Aetrex”) respects the privacy of our customers and users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy is intended to describe for users of Aetrex’s websites (including but not limited to:  aetrex.com, myfeet.com, aetrextechnology.com, aetrexacademy.com, and foot.com) (collectively, the “Websites”) and any mobile applications (collectively, the “Apps”), or those who otherwise provide us with information through various means:   the information we collect, how we may use that information, with whom your information may be shared, and your choices about such uses and disclosures. 

Please read this Privacy Policy carefully when using our Websites and Apps, and when purchasing our products from our Websites and Apps. By using our Websites and/or Apps, you are accepting and agreeing to the terms in this Privacy Policy and you consent to the application of this Privacy Policy to the collection, storage, use and disclosure of all your personal and other information described.

Protecting the privacy and security of your personal information is a priority at Aetrex, and we believe that a single, comprehensive privacy policy that is straightforward and clear is in the best interests of our customers and our businesses.  If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

Information collected from visitors from outside the United States

Please note that this Privacy Policy is intended to cover collection of information on our Websites and Apps from residents of the United States.

If you are visiting our Websites and/or Apps from outside the United States and provide us with personal information, please be advised that your personal information may be transferred, stored and processed within the United States where our servers may be located.   Additionally, Aetrex may transfer your personal information to other countries, for example because a server or third party service provider is located there. The data protection and privacy laws of other countries, including the United States, may not afford you the same level of protection as those in your own country 

Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, and visiting our Websites and Apps, by providing your personal information, and/or making purchases on our Websites and Apps, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.  Aetrex will take appropriate steps to protect your information.

By visiting our Websites, and Apps, and/or making purchases, providing your personal information to Aetrex, and/or interacting with Aetrex, you are consenting to the transfer, storage, and processing of your personal information to and within facilities located in the United States and other facility locations selected by Aetrex, and are consenting to the application of United States laws only. 

Notwithstanding the above, the personal information received from EU individuals who have had their feet scanned in the EU and who are subject to the GDPR will be maintained by Aetrex in compliance with and subject to GDPR requirements (see GDPR Amendment below). 

 Information We Collect About You

 Generally:  Generally, you can browse our Websites and Apps without submitting your personal information to us, although we may receive and collect certain personal information automatically, as outlined elsewhere in this Privacy Policy, and including analytics regarding our Websites and Apps, information your Internet browser automatically sends when you visit our Websites and Apps, and information collected by cookies. Aetrex may collect personal information that can identify you such as your name and email address, and other information that does not identify you. When you provide personal information through our Websites and Apps, the information may be sent to servers located in the United States and other countries around the world.

  1. a.     Information Provided by You:  Aetrex may collect and store the personal information that you enter yourself on our Websites and Apps, or that you provide to us in some other manner.  This may include identifying information, such as your name, address, e-mail address, birth date and telephone number, and, if you make purchases from us, financial information such as your payment methods (credit card numbers or other financial information). We also may request information about your interests and activities, your gender and age, and other demographic information.  The most common of these circumstances where you would provide personal information include the following:
    1. i.               Making a PurchaseWhen you place an order online for one of our products, you may need to submit personal information to us.
    2. ii.              Creating an account or joining an Aetrex Program: In order to use certain Apps and features of our Websites, or to make purchases, you may be required to create a password-protected user account and provide us with personal information. Similarly, when you enroll in an Aetrex member program or other promotion, you may be asked to submit personal information as part of your member profile. We will store and use this information to administer the programs and services in which you choose to participate, and as permitted by this Privacy Policy.
    3. iii.            Using  Aetrex Websites and Apps: Aetrex’s Websites and Apps may provide you with the ability to enter (either directly, or by authorizing Aetrex to access the information from a third party such as a social networking site or application) certain information such as your contacts, photos, or images you may submit to us to help us locate products for you.
    4. iv.            Contacting Customer Service:  When you contact customer service, we may ask you to provide, or confirm, personal information so that we can better serve you.
    5. v.             Entering a sweepstakes or contest: If you enter a sweepstakes or contest we offer, we may ask you to provide personal information so that we can consider your entry and, if you win, so that you may redeem your prize.
    6. vi.            Interacting with social networking sites: Our Websites and/or Apps may provide you with the ability to enter (directly, or by authorizing us to download the information from a third party such as a social networking site or application) personal information such as contacts or lists of friends. These or related applications may also allow you to provide information directly to social networking sites including information about your purchases, physical location, or comments. If you sign up to receive promotional communications or notifications from us, we may ask you to provide personal information so that we can provide these to you.
    7. vii.          Information You Provide From Other Sources.  We may also periodically obtain both personal and non-personal information about you from advertising companies, and ad networks business partners, contractors and other third parties and add it to our account information or other information we have collected. Examples of such information that we may receive include: updated delivery and address information, purchase history, and additional demographic information.
  1. b.     Use of cookies and other technologies to collect information. We also may use various technologies to collect information from your computer and about your activities on our site. 
  1. i.               Information collected automatically. We may automatically collect information from your browser when you visit our Websites and Apps. This information may include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address.
  2. ii.              Social Media. We may provide you the ability to sign into an Aetrex Website or App using a social media account such as a Facebook, Twitter, Instagram, Snapchat, or Google account, or use your social media accounts to share information from Aetrex’s Websites or Apps. In these cases, as well as when you use an Aetrex App on a social media site or choose to join (or "like") an Aetrex  page on a social media site, the social media site may provide us with certain information about you, including but not limited to your contacts and other "likes". In addition, we may share your information, including personal information, with third party vendors to facilitate your choice to sign into an Aetrex Website or App using a social media account. Please see the privacy policy for the applicable social media site to learn more about how these sites share your personal information.
  3. iii.   Cookies. When you visit our Websites and/or Apps, we may assign your computer one or more cookies to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on our site, such as the web pages you visit, the links you click, and the searches you conduct on our site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies please note that you may not be able to sign in or use some of the interactive features offered on our Websites or Apps. A cookie is a small text file that is stored on a user's computer for record keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our website. A persistent cookie remains on your hard drive for an extended period of time. For example, when you sign in to our Websites or Apps, we will record your user or member ID, which is your email address, and the name on your user or member account in the cookie file on your computer. We store your unique member ID in a cookie for automatic sign-in. This cookie is removed when you sign-out. For security purposes, we will encrypt the unique member ID and any other user or member account-related data that we store in such cookies. In the case of sites and services that do not use a user or member ID, the cookie will contain a unique identifier. We may allow our authorized service providers to serve cookies from our website to allow them to assist us in various activities, such as doing analysis and research on the effectiveness of our site, content and advertising. You may delete or decline cookies by changing your browser settings (Click "Help" in the toolbar of most browsers for instructions). If you do so, some of the features and services of our Websites and/or Apps may not function properly.
  4. iv.   Information to third partiesWe may allow third-parties, advertising companies, and ad networks, to display advertisements on our Websites and Apps. These companies also may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements. Our Websites and Apps do not provide any personal information to these third parties, but they may collect information about where you, or others who are using your computer, saw and/or clicked on the advertisements they deliver, and possibly associate this information with your subsequent visits to the advertised websites. They also may combine this information with personal information they collect from you. The collection and use of that information is subject to the third-party's privacy policy. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies (www.networkadvertising.org).
  5. v.    Other technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Websites and Apps. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our Websites and Apps visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies. Unlike cookies, which are stored on the user's computer hard drive, web beacons are embedded invisibly on the web pages (or in email) and are about the size of the period at the end of this sentence. Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns. We also may receive an anonymous identification number if you come to our site from an online advertisement displayed on a third-party website.

How We Use the Information We Collect

GENERALLY.  We may use information that we collect about you to:

  • deliver the products and services that you have requested;
  • manage your account and provide you with customer support;
  • perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
  • communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us or other third parties;
  • develop and display content and advertising tailored to your interests on our site and other sites;
  • verify your eligibility and deliver prizes in connection with  promotions, contests and sweepstakes;
  • enforce our terms and conditions;
  • manage our business and perform functions as otherwise described to you at the time of collection.
  • to process payment for any purchases or sales made on our Websites and Apps, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business; and/or
  • to use the information you provided to occasionally notify you about special Aetrex sales or services and other valuable updates to personalize your Aetrex shopping transactions (If you prefer that we not contact you in this manner please follow the Opt-Out instructions elsewhere in this Privacy Policy.


With Whom We Share Your Information

Protecting the privacy and security of your personal information is a priority at Aetrex. We want you to understand when and with whom we may share personal or other information we have collected about you or your activities on our Websites and Apps or while using our services.


Personal information. We do not share your personal information with others except as indicated in this Privacy Policy below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share personal information with: 

  • Authorized service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, delivering packages, providing customer service and marketing assistance, performing business and sales analysis, supporting our Website and/or App functionality, and supporting contests, promotions, sweepstakes, surveys and other features offered through our Websites and Apps. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purposes.
  • Business partners: When you make purchases or engage in promotions offered through our Websites and Apps, we may share personal information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes. When you elect to engage in a particular merchant's offer or program, you authorize us to provide your email address and other information to that merchant.
  • Other situations: We also may disclose your information:


i.  In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

 ii. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies. 

iii.  In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.


Third-Party Privacy Policies:  Any third parties to whom we may disclose personal information may have their own privacy policies which describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the United States. 

Third Party Websites:  There are a number of places on our Websites and Apps where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our website, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting.

Aggregated and Non-personal Information:

We may share aggregated and non-personal information we collect under any of the circumstances set forth in this Privacy Policy. We may also share it with third parties to develop and deliver targeted advertising on our Websites and Apps and on websites and apps of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Websites and Apps and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.

How You Can Access Your Information

If you have an online account with us, you have the ability to review and update your personal information online by logging into your account.  You can also review and update your personal information by contacting us. More information about how to contact us is provided below.

You may request to have all of your personal information collected by us removed from our database by submitting a request to our contact information set forth at the end of this Privacy Policy Customer Service, identifying the subject as "Privacy". We will remove such information as soon as practicable for us, however, we may still retain certain information associated with your account for analytical purposes and record keeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by applicable law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties' policies.

Your Choices About Collection and Use of Your Information  You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our website because such information may be required in order for you to register as a member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our website. 

Opt-Out.   At any time you can choose to no longer receive commercial or promotional emails or newsletters from us by modifying your email preferences by selecting the "Opt-Out" link found in the footer of the communication or on our Websites or Apps and following the instructions or contacting us.  When you register on our Websites or Apps, you will be given a choice as to whether you want to receive e-mail messages about special offers and deals related to your interest. You may modify your choice at any time by using the "Opt-Out" link as described above.

You also will be given the opportunity, in any commercial e-mail that we send to you, to opt out of receiving such messages in the future. It may take up to thirty (30) days for us to process an opt-out request. We may send you other types of transactional and relationship e-mail communications, such as service announcements, administrative notices, and surveys, without offering you the opportunity to opt out of receiving them. Please note that changing information in your account, or otherwise opting out of receipt of promotional email communications will only affect future activities or communications from us. If we have already provided your information to a third party before you have changed your preferences or updated your information, you may have to change you preferences directly with that third party.

Even if you opt-out of receiving promotional communications, you may continue to receive emails and notifications relating to order confirmations, back order notifications, membership information, and/or other business-related communications.

California Residents: You may tell us not to share your personal information with third parties for direct marketing purposes by selecting the "Opt-Out" link found in the footer of the communication or our Website and Apps.

 
How We Protect Your Personal Information


We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information.

 
We want you to feel confident whenever you visit us in our Websites and Apps. While we are focused on the security of your personal information and follow strict standards, processes and procedures that are designed to protect your personal information, you must remember that the Internet is a global communications vehicle open to threats, viruses and intrusions from others and so we cannot promise, and you should not expect, that we will be able to protect your personal information at all times and in all circumstances.

Users should also take care with how they handle and disclose their personal information and should avoid sending personal information through insecure email. Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

We are committed your Security.  Our Websites and Apps take all reasonable precautions to protect our users’ information. When users submit sensitive information via the website, your information is protected both online and offline.

When you are asked to enter sensitive information (such as credit card number), that information is encrypted and is protected with Secure Sockets Layer (SSL) technology. While on a secure page, such as our order and registration forms, the lock icon on your web browser appears and appears locked, as opposed to unlocked, or open, when you are just “surfing.”

A Bit about SSLWe take significant and appropriate security measures, including physical, technological and procedural measures, to help to safeguard your personal information and to prevent unauthorized access and disclosure. In addition, we use industry-standard technology, such as Secure Sockets Layer (SSL) encryption technology in the transmission of certain sensitive personal information, designed to prevent unauthorized persons from gaining access to your personal information, and, as technology develops, we intend to take additional measures to improve security.

Secure connections (often called SSL, or Secure Sockets Layer technology) are the industry standard in Web security. SSL is used primarily for transmitting sensitive information over the Internet. When you have a secure connection between your browser and a website, no one else can easily access the data that you send across the connection. 

While we use SSL encryption to protect sensitive information online, we also protect user information offline. All of our users’ information, not just the sensitive information mentioned above, is restricted in our office. Only employees who need the information to perform a specific job (for example, our accounting department or customer service department) are granted access to personally identifiable information. Furthermore, all employees are kept up-to-date on our security and privacy practices. Our employees are regularly notified and reminded about the importance we place on privacy, and what they can do to ensure our customers’ information is protected.

Finally, the servers on which we store personally identifiable information are kept in a secure environment.

Children's Privacy

Our Websites and Apps are general audience sites, and we do not knowingly collect personal information from children under the age of 13.  The Children's Online Privacy Protection Act imposes requirements on Web sites that collect personal information about children under 13 years old (for example - name, address, email address, social security number, etc.). Our current policy is not to collect any personal information on any person under 13 years old online. For this reason, our contests and other promotions conducted online are restricted to entrants who are at least 13 years old.  If this policy changes, we will revise this portion of our Notice of Privacy Practices and will comply with the requirements of the Children's Online Privacy Protection Act, which includes providing notice and choice to each child's parent or guardian before collecting any personal information.

Your California Privacy Rights

California Civil Code Section 1798.83 permits California residents to request a notice from us describing which categories of personal information we have shared with third parties or corporate affiliates for those third parties or corporate affiliates' direct marketing purposes within the last calendar year, and the name and address of such parties. If you are a California resident and would like a copy of this notice, please send an email to rkojima@aetrex.com, and insert "California Privacy Rights Request" in the subject line.  Please allow thirty (30) days for a response. 


No Rights of Third Parties


This Privacy Policy does not create rights enforceable by third parties.

Changes to this Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services and post the most recent. If we make any material changes in the way we collect, use, and/or share your personal information, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an email address), and/or by prominently posting notice of the changes on our Websites and Apps. We recommend that you check our Websites and Apps from time to time to inform yourself of any changes in this Privacy Policy or any of our other policy.

How to Contact Us


If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail as follows: Webmaster, Rui Kojima, Aetrex Worldwide, Inc. 414 Alfred Ave., Teaneck, NJ  07666, rkojima@aetrex.com

____________________________________

gdpr amendment – FOR EUROPEAN UNION individuals

Notification of personal data collection and use

On May 25, 2018, a new European Union (“EU”) data protection law, the General Data Protection Regulation (“GDPR”), takes effect.  The GDPR gives EU individuals subject to the law more control over how their data is used and places certain obligations on business that collect and process information of EU residents.  Aetrex has updated its policies to take into account the new requirements of the GDPR, and which, if applicable to you, includes the rights outlined therein.  We collect and process personal information about you with your consent or as necessary to provide services to you, operate our business, meet our contractual and legal obligations, and/or fulfill other legitimate interests.  Please note that Aetrex is committed to ensuring that your privacy is protected and your information will only be used in accordance with our policies  and GDPR requirements. 

 If you are an EU individual in the EU, are subject to the GDPR and have provided personal information while having your feet scanned; you have received subsequent e-mail(s) with your foot scan results; you have received subsequent follow up e-mail(s) or reminders related to your foot scan or associated products; and/or you have accessed your foot scan or personal information account through a specific portal or function on our Websites or Apps, please be aware of the following which applies specifically to you:  

This Notification of Personal Data Collection and Use is intended to provide you with information about the collection and use of your personal data by Aetrex:

How can you contact Aetrex?

Questions or inquiries related to this Privacy Policy should be directed to Aetrex’s Data Protection Officer (“DPO”).  Aetrex’s DPO is Devraj Agarwal. He may be reached at:

 

            Aetrex Worldwide, Inc.

            414 Alfred Avenue

            Teaneck, NJ  07666 USA

            dagarwal@aetrex.com

            Tel: 201-833-2700

 

What personal data has Aetrex collectedAetrex has collected the following information about you: Your name, e-mail address, home address, phone number, and digital scan of your feet. Aetrex was provided this data by a shoe retailer that you visited and to whom you provided this data.

Why does Aetrex collect your personal data?

Aetrex has collected this personal data so that it can provide you with products and services that you have requested.  Accordingly, Aetrex’s legal basis for the processing of your personal data is that it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.  If you refuse to provide Aetrex with your personal data, you may be unable to obtain the products and services from Aetrex that you requested. 

Aetrex also may use your personal data to occasionally notify you about special sales or services related to your feet and scan.  At the time you provided your personal data to the shoe retailer, you gave your consent for Aetrex to use your personal data in this manner. This notification also is intended to provide you with a record of your agreement.  If you would like to withdraw your consent for Aetrex to use your personal data in this manner, please contact Aetrex using the contact information provided above. 

What will Aetrex do with your personal data?

Aetrex will use your personal data solely for the purposes for which it was collected. 

Aetrex will keep your personal data for as long as Aetrex may need it to provide you with products and services, to notify you about special sales or services, and/or to comply with its contractual and/or legal obligations.

Aetrex will not disclose your personal data to any third-parties, and will not use any automated decision-making (such as profiling) with respect to your personal data. 

Security:  Aetrex is committed to ensuring that your information is secure.  In order to prevent unauthorized access or disclosure, we have in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect which complies with GDPR requirements.

What rights do you have with respect to Aetrex’s collection and use of your personal data?

You have the right to request from Aetrex access to your personal data, and the rectification of inaccurate personal data concerning you.  You have the right to obtain from Aetrex the deletion or the restriction of processing of your personal data in certain circumstances, including when the data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, except when Aetrex is required by law to maintain or otherwise process your personal data, for the establishment, exercise, or defense of legal claims, or for the protection of the rights or another person.  You may exercise these rights by contacting Aetrex using the contact information provided above.

If you are an EU resident, you also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of an alleged infringement of the applicable data protection law.

If you have any questions about this notification, please contact Aetrex using the contact information provided above.