WHO is Responsible for the Processing of Your Personal Data?
WHAT Personal Data Do We Collect and WHEN?
We ask you for certain personal data to provide you with the products or services you request. For example, when you make purchases, contact our consumer services, request to receive communications, create an account, participate in our events or contests, or use our Sites or Apps.
This personal data includes your:
- contact details including name, email, telephone number and shipping, billing address;
- login and account information, including screen name, password and unique user ID;
- personal details including gender, hometown, date of birth and purchase history;
- payment or credit card information;
- images, photos and videos;
- personal preferences including your wish list as well as marketing and cookie preferences.
We collect additional personal data from you to enable particular features within our Sites and Apps.
When interacting with our Sites and Apps, certain data is automatically collected from your device or web browser. This data includes:
- Device IDs, call state, network access, storage information and battery information; and
- Cookies, IP addresses, referrer headers, data identifying your web browser and version, and web beacons and tags.
We comply with local laws and do not allow children to register on our Sites or Apps when they are under the legal age limit of the country in which they reside. We will ask for parental consent for children participating in Hurley experiences and events.
TOOLS to Manage What Personal Data We Collect
When using our Apps and Sites, we also provide in-time notice or obtain consent for certain practices. For example, we will obtain consent to use your location or send push notifications. We may obtain this consent through the Apps or Sites or using the standard permissions available on your device.
In many cases, your web browser or mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data. For example, your mobile device or web browser may offer tools to allow you to manage cookie usage or location sharing. We encourage you to familiarize yourself with and use the tools available on your devices.
WHY and HOW Do We Use Your Personal Data?
We use your personal data in the following ways:
To Provide the Features of the Sites, Apps, and Services You Request
When you use our Sites and Apps, we will use your personal data to provide the requested product or service.
For example, if you make a purchase on Hurley.com or participate in an event or promotion, we will use the contact information you give us to communicate with you about the purchase, event or promotion. If you contact our consumer services, we will use information about you, such as delivery or payment information, or the product you have purchased to help you resolve a problem or question.
To Communicate Information about our Products, Services, Events and for Other Promotional Purposes
When you consent, we will send you marketing communications and news concerning Hurley’s products, services, events and other promotions. You can opt-out at any time after you have given your consent.
If you are an existing customer of Hurley (for example, if you have placed an order with us), we may use the contact details you provided to send you marketing communications about similar Hurley products or services where permitted by applicable law (unless you have opted-out). In other cases, we ask for your consent to send you marketing information. We may use the information that you provide to us as well as information from other Hurley products or services - such as your use of Hurley’s Sites and Apps, your visits to or purchases made in Hurley stores, your participation in Hurley events and contests - to personalize communications on products and services that may be interesting for you.
To Operate, Improve and Maintain our Business, Products and Services
We use the personal data you provide to us to operate our business. For example, when you make a purchase, we use that information for accounting, audits and other internal functions. We may use personal data about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Sites and Apps.
To Protect Our or Others' Rights, Property or Safety
For General Research and Analysis Purposes
We use data about how our visitors use our Sites, Apps and services to understand customer behavior or preferences. For example, we may use information about how visitors to Hurley.com search for and find products to better understand the best ways to organize and present product offerings in our storefront.
We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent where necessary.
To process your personal data, we rely on certain legal grounds, depending on how you interact with our Sites and Apps.
- When you purchase Hurley products from our Sites and Apps, we need your personal data to fulfill our contract with you. For example, we need your payment and contact details to deliver your order.
- When you use our Apps, we rely on your consent for processing and for certain limited purposes to fulfill our contract with you (for example, for in-App purchases).
- We also rely on other legal grounds, such as our legitimate interests as a business, to comply with a legal obligation, or to protect your vital interests.
SHARING of Your Personal Data
Hurley shares your personal data with:
- Third party service providers processing personal data on Hurley’s behalf, for example to process credit cards and payments, shipping and deliveries, host, manage and service our data, distribute emails, research and analysis, manage brand and product promotions as well as administering certain services and features. When using third party service providers we enter into agreements that require them to implement appropriate technical and organizational measures to protect your personal data.
- to any other third party where you have provided your consent.
We may also transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
When you use certain social features on our Sites or Apps, you can create a public profile that may include information such as your screen name, profile picture and hometown. You can also share content with your friends or the public, including information about your Hurley activity. We encourage you to use the tools we provide for managing Hurley’s social sharing to control what information you make available through Hurley’s social features.
PROTECTION and MANAGEMENT of Your Personal Data
Encryption & Security
We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.
International Transfers of your Personal Data
We take measures to comply with applicable legal requirements for the transfer of personal data to recipients in countries outside of the EEA or Switzerland that do not provide an adequate level of data protection. We use a variety of measures to ensure that your personal data transferred to these countries receives adequate protection in accordance with data protection rules.
Retention of your Personal Data
YOUR RIGHTS Relating to Your Personal Data
You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability); (iii) correction of your personal data if it is incomplete or inaccurate; or (iv) deletion or restriction of your personal data in certain circumstances provided by applicable law. These rights are not absolute. Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.
Opting Out of Direct Marketing
If you have a Hurley account, you can opt-out of receiving Hurley’s marketing communications by modifying your preferences in the "view or change my profile" section of our Sites. You can also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or following the opt-out instructions included in the message.
COOKIES and Pixel Tags
Hurley collects information, which may include personal data, from your browser when you use our Sites. We use a variety of methods, such as cookies and pixel tags to collect this information, which may include your (i) IP-address; (ii) unique cookie identifier, cookie information and information on whether your device has software to access certain features; (iii) unique device identifier and device type; (iv) domain, browser type and language, (v) operating system and system settings; (vi) country and time zone; (vii) previously visited websites; (viii) information about your interaction with our Sites such as click behavior, purchases and indicated preferences; and (ix) access times and referring URLs.
Third parties may also collect information via Sites through cookies, third party plug-ins and widgets. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies.
- Functional: These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore our Sites within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.
- Performance: These cookies allow us to improve our Sites’ functionality by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember site preferences you have selected. Refusing these cookies may result in poorly-tailored recommendations and slow site performance.
- Social media and Advertising: Social media cookies offer the possibility to connect you to your social networks and share content from our Sites through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond our Sites. In some cases, these cookies involve the processing of your personal data. Refusing these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.
You can always change your preference by visiting the "Cookie Settings" at the bottom of each page of our Sites.
For a comprehensive and up-to-date summary of every third-party accessing your web browser (through Hurley Sites or otherwise), we recommend installing a web browser plugin built for this purpose. You can also choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings on each browser and device that you use. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you may not have access to many features that make our Sites and Apps more efficient and some of our services will not function properly.
USING Hurley Sites and Apps with Third-Party Products and Services
Our Sites and Apps allow you to interact with a wide variety of other digital products and services. For example, our Sites and Apps can integrate with third-party devices for activity tracking, social networks, music streaming services and other digital services.
If you choose to connect your Hurley account with a third-party device or account, your privacy rights on third-party platforms will be governed by their respective policies. For example, if you choose to share your Hurley activity on third-party social media platforms, the policies of those platforms govern the data that resides there.
Our Sites and Apps may provide links to other (third-party) websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.
QUESTIONS and Feedback
If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal data, please send email to email@example.com
If you contact us with a privacy complaint it will be assessed with the aim of resolving the issue in a timely and effective manner. You also have the right to lodge a complaint with the relevant supervisory authority in the country in which you reside.