This Cookies and Privacy Notice (“Notice”) provides information on how RAP collects and uses your “Personal Data” (information provided by you or others that we can connect to you). We encourage you to review this Privacy Notice and others published by us frequently as they may be updated to reflect latest developments without prior notification.

This Notice applies to the different purposes and scenarios when your Personal Data is collected directly from our websites or apps operated by the responsible entities identified in this Notice, as well as when your Personal Data is obtained from other sources not directly from you, and used by the responsible RAP entities and others. Your Personal Data is used for all the scenarios described in this Notice if and where we have the permission and right (“Lawful Basis”) to do so. Where the scenario applies exclusively to a specific platform we operate, the name of the platform would be identified at the end of the heading in a bracket like this: HEADING – {name of platform}.

Please read the general information as well as the specific scenarios by clicking on the relevant headings below. You should also read any additional Cookies and Privacy Notices displayed when you provide Personal Data to us as they provide details of the specific scenario which may not be covered by this Privacy Notice.

If you access any of our platforms by using a Virtual Private Network (also known as “VPN”) to interact with us – including making purchases – in a country that is not your current or residential country, please read the Cookies and Privacy Notice displayed at that specific platform or portal to understand how the responsible entities, our affiliated brands and RAP subsidiaries at that country use and protect your Personal Data.

1. Who is responsible for your Personal Data?

For the purposes described in this Notice and compliance with local privacy laws and the GDPR, the following RAP entities are responsible:

• RAP Industrial, Lda with registered office at Avenida do Brasil, 231, 3700-070 São João da Madeira – Portugal

Also, for the purposes of:

• Sales of RAP products – online and off-line order
• Product research and development

They are known as the RAP “Joint Controllers” under the GDPR and local privacy laws. They are jointly responsible for determining why (“Purpose”), how (“Processing”), and if (“Lawful Basis”) we use your Personal Data. In this Notice, we call them “Responsible Entities” to make it easier for you to understand.

For some scenarios described in this Notice, there may be other RAP and/or non-RAP entities also responsible for using your Personal Data, please refer to the specific scenario for more information.

2. Your rights for your Personal Data?

 In order to exercise your right to access, rectify, erase, forget or block your personal data, you just need to go to your customer area on the online store.

2.1. Access to information about your Personal Data. Please refer to the details provided in this Cookies and Privacy Notice to have information about:

• why we have your Personal Data;
• what categories of data we have;
• what we do with your Personal Data;
• who has access to your Personal Data (and where they are);
• where your Personal Data might be transferred to;
• how long we are keeping your Personal Data;
• if you didn’t provide your Personal Data directly to us, how did we get them;
• your rights under applicable laws and the possibility to restrict processing;
• if we use your Personal Data for any automated decision-making; and
• In some cases, you have the right to know how our automated decision-making works, if the decision significantly affects you.

2.2. Make sure your Personal Data is correct. Please  access your account at RAP to make changes directly.

2.3. Unsubscribe from our email marketing messages. You can unsubscribe from our email marketing messages at any time. Please use the “Unsubscribe” function at the bottom of each email marketing message.

2.4. Restrict how we use your Personal Data

2.5. Withdraw your consent

2.6. Object when we process your Personal Data based on “Legitimate Interest” (including unsubscribing from our direct marketing messages)

2.7. Challenge a decision generated solely by automated decision-making process without human intervention

2.8. General assistance. Please contact our Customer Service team ([email protected]) for general support.

2.9 .File a complaint with your local data protection supervisory authority. You have the right to file a complaint with the local authority if you are not happy with how we have handled any of your rights listed above. We invite you to first share and discuss your concerns and complaints about how we handle your individual rights and use your Personal Data with our Privacy team and our Data Protection Officer by writing to our RAP Privacy Compliance Query and Complaint Inbox ([email protected]) so we can promptly address, and hopefully resolve your concerns and complaints. If you are not clear about any of the rights listed here, please consult your local authority about your Personal Data rights under the law and to best understand what these rights mean.

3. What Personal Data do we collect and use (“Categories of Personal Data”)?

Most of the time, you give us your Personal Data for specific purposes. However, sometimes, this Personal Data may also be used for other purposes if we have the right and permission (“Lawful Basis”) to do so. Also, we may use your Personal Data from other companies or sources for some purposes, if it is legally allowed. Please see the Categories of Personal Data below to help you understand how we use your Personal Data. The Categories include Personal Data you provided directly and indirectly to Responsible Entities.

3.1. Identity Information

Any information that identifies you as an individual, living person. This may include: name [first, last, initials], Date of Birth, e-mail address including your name, phone number, unique customer identifier number (including your Membership member ID, or ID from any RAP Platform), nickname, password, social media identifiers and handles, your device fingerprint, gift card codes that are assigned to you, gender identity and expression.    

3.2. Contact Information

Any information we can use to contact you. This may include: your phone number, shipping and billing address, e-mail address, Messenger ID, social media handle, any other communication channel you have used to contact us for more information.

3.3. Payment, Purchase and Transaction Information

Any information we use to complete or in relation to your purchase record and invoice. This may include: your payment information (credit card details, or bank details, or payment platform details), shopping cart details (your ordered items), delivery details, shipping and billing address, customer order number, purchase history with RAP, receipt number, transaction ID, invoice ID, purchase value, order confirmation number, order tracking number.

3.4. Measurements

Any information we can use to make sure your shoes fit.

3.5. Location Information

Any information we can use to know or guess where you are, real time or otherwise. This may include: your residential location, current log-in location [IP address], real-time device location information via device sensors and signals, GPS location (if you wish to share us, for example through your mobile device settings), or information that helps us guess where you may be such as the specific RAP site you have visited that might give us clues about where you are.

3.6. Behavioural and Preference Information

Any information which indicates your preference whether explicitly – if provided by you – or inferred. This may include: site/brand preference, language preference, product and product attributes preferences, your shopping history (all items in shopping carts), Wishlist items, any “preference” details you provided to us in your profile and Platform setting.

3.7. Browsing Information

Any information on. your browsing behaviour. This may include: browser name, IP address (including hashed IP address), clickstream data, data and time of site visits, time remained on site, pages visited, and the links you have clicked in our marketing messages or website , the referral URL that brought you to our site.

3.8. Mobile Device Information

Any information related to your mobile device. This may include: device EUI, device ID, P/Wifi Information, operating system, data stored on device when access is granted.

3.9. Social Media Interaction and Activity

Any information about you we obtain through different social media channels such as Facebook, Instagram, Google, etc., when we use these channels for advertising, analytics purposes or to enrich your profile with RAP. This may include: any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are public, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”, comments or messages you shared with us publicly or privately on social media platforms. Also, we may be able to obtain information indirectly from social media companies (Facebook, Google, etc.) when we advertise on these platforms, which may include your participation and membership on particular topics and/or groups, your profile settings and preference, your behaviour on different platforms owned by the same company.

3.10.Correspondence

Any correspondence you have with Customer Service teams, and/or our employees and personnel.

3.11. Image and Recording

Any image, voice or video recordings we have captured or obtained where you may be identified for example, any images you share with us through social media.

3.12. Personal Opinion

Any opinion you share with us that indicates your point of view and comments. This may include when you provide us feedback and review rating our service or products, or if you participate in any product research and development discussions.

3.13. Sensitive Personal Opinion

Any opinion you share that may indicate or reveal certain characteristics about you including your political view, your sexual orientation, information about race and ethnicity, religious or philosophical beliefs, trade union membership or health. This is used only when you have allowed us to use it – with your consent – for specific reasons and purposes.

4. How and why do we use your Personal Data? (Purpose, Processing, Legal Basis)?

In this section, we provide details to all the scenarios and reasons (“Purposes”) where we may collect (directly and indirectly) and use your Personal Data from all our Platforms.

PURPOSE

Why do we collect and use your Personal Data?

PROCESSING

What do we do to your Personal Data?

LEGAL BASIS

Why are we allowed to use your Personal Data for this Purpose?

CATEGORIES OF PERSONAL DATA

What are the Categories of Personal Data we use to accomplish this purpose, including the Personal Data you provided to us for this Purpose, and the Personal Data we have obtained from other sources for other purposes? Specifically, these are the Categories of Personal you may or may not have given to us for this specific purpose, but we either have it on file, or have obtained it from a different source for a different purpose, and we know it is connected to you.

RETENTION PERIOD

How long do we keep your Personal Data for this Purpose?

CATEGORIES OF RECIPIENTS

With whom (types of service providers or companies) do we share your Personal Data to achieve the purpose?

4.1. Site Operation and App Operation

PROCESSING

We screen all traffic to our sites and apps, and analyze data that is received by our servers to:

• run the sites that are connected to our domain and apps,
• fix bugs to make sure the layout and design are displayed properly,
• fix bugs to make sure the sites and the apps function properly,
• monitor compliance with our Terms and Conditions.

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information. 

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity Information
• Contact Information
• Browsing Information
• Mobile Device Information

RETENTION PERIOD       

Browsing Session – We need your data for as long as you are on the site. We keep it for the duration of your browsing session.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Site Administration Support Providers

4.2. Domain and Network Security and User Authentication

PROCESSING

To protect our domains, detect unusual activities, and prevent security threats and protect our site-visitors from unauthorised accesses (such as hackers), we screen all traffic to our sites, and authenticate user log-in information using tokens to verify the details you provide to us and compare it with other available information, such us the credentials you have provided directly to us or other platforms (such as Facebook) or information that is available in the public domain to ensure only “authorised” users have access to our sites.

reCAPTCHA

We may use reCaptcha operated by Google on our websites and apps to authenticate user identity and secure our platforms from malicious software (or known as a “bot”) that might engage in abusive activities on our platforms. reCAPTCHA works by collecting information about your hardware, and software (for example, device and application data) This data is shared with Google for analysis. Data captured by reCAPTCHA is also subject to the Google Privacy Policy and Terms of Use. 

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information. More information is available in “Collecting Your Device Information on Our Website and Apps Using Cookies, Pixels, Tags, And Similar Technologies”.

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity Information
• Contact Information
• Browsing Information
• Mobile Device Information 

RETENTION PERIOD       

Browsing Session – We need your data for as long as you are on the site. We keep it for the duration of your browsing session.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Site Administration Support Providers

4.3. Persistent Log-In

PROCESSING

If you select to be logged in persistently, you do not have to log in every time you visit the RAP website for up to 30 days. Your personal data will be used by the RAP website to show your personal information: Your email will be used during checkout journey to let you know the email that will be used for the order confirmation, your first name will be used for personalization and your unique identifier may be used for Frontend Analytics. Please note that no consent status will be stored.

This basic profile information will be stored for up to 30 days in the browser that was used for the login *within an access token. The access token is a HTTP only cookie. The token is valid for 20 minutes if the ‘keep me logged in’ functionality was selected. After the expiration of the token it is no longer possible to access personal information so the logged in session is over. For persistent login we additionally store a refresh token in the browser which can be used to refresh the access token within a 30 days period and extend the logged in session that way*. If this refresh token is missing (if you have not selected persistent login or cookies were cleared) the access token cannot be refreshed. Hence, your session cannot be extended, and you will not be logged in anymore.

Please note: If you chose persistent log-in, your personal address details may be exposed to an unauthorised third party if you forget to log-out from persistent log-in from a publicly accessible device.

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information

RETENTION PERIOD       

The information will retain in your browser for up to 30 days. You can delete the data yourself by clearing your cookies from your browser or by selecting the “Logging out from all my devices” option in your account section.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Site Administration Support Providers

4.4. Sales of RAP Products – Online and Off-Line Order

PROCESSING

To process your online and/or in-app orders, provide you with different payment options, create a smooth check-out process for you, make sure your payment is received, comply with the requirements under our Terms and Conditions (3. Purchase Terms) (for selling you the products) including invoice processing, delivery, personalisation services, exchanges and refunds, click and collect. Your order cannot be completed if our payment fraud detection solutions flag your transaction as suspicious and potentially fraudulent.  Please note the payment fraud detection system is an automated decision-making process. It is required to allow us to conclude the contract with you. You have the right to request a human review of this decision, and challenge the decision.

LEGAL BASIS    

• Performance of Contract
• Legitimate Interest
• Legal Obligation

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information
• Location information
• Measurements
• Payment, Purchase and Transaction Information
• Correspondence
• Browsing Information
• Mobile Device Information
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

Duration of contract and statutory limitation period (10 years). We need to keep the information in case of any legal disputes concerning the contract.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Selling Partners (where applicable)
• Manufacturing Providers
• Delivery Service Providers
• Payment Processing Providers
• IT Cloud Solution Providers

4.5. Enrichment and Improvement of your Digital Shopping Experience

PROCESSING

When you shop at various RAP digital shopping platforms (RAP website, and RAP app), we collect your Personal Data to enrich and improve your shopping, browsing and check-out experience. This may include helping you find the right size, helping you visualise how a product will look on you via our digital platforms.

SIZE RECOMMENDATION

To help you find the best size that fits your measurements best, we use a size recommendation table  on our app and website. 

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Measurements
• Behavioural and Preference Information
• Payment, Purchase and Transaction Information

RETENTION PERIOD       

We retain it for as long as you do not delete your data.

CATEGORIES OF RECIPIENTS     

Size Recommendation Provider

4.6. Payment Fraud Detection

PROCESSING

We combine the Payment, Purchase and Transaction Information you provide to us with other information we obtain through our third-party payment risk and fraud prevention service providers to ensure any purchases are legitimate, or you do not purchase our products in violation with our terms and conditions. This means depending on the outcome of the analysis of your information, we may reject your order, and decline your payment. This is an automated decision-making process that is required to conclude our sales contract with you.

LEGAL BASIS    

Performance of Contract and Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information
• Payment, Purchase and Transaction Information
• Browsing Information
• Mobile Device Information

RETENTION PERIOD       

Duration of contract and statutory limitation period. We need to keep the information in case of any legal disputes concerning the contract.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Payment Risk Solution Providers
• Payment Processing Providers
• IT Cloud Solution Providers

4.7. Product Delivery

PROCESSING

Once you have successfully placed an order, we use your contact details (home and/or shipping address) and other Payment, Purchase and Transaction Information to deliver the products you purchased to you.

LEGAL BASIS    

Performance of Contract

CATEGORIES OF PERSONAL DATA           

• Identity information: Name
• Contact information: Shipping Address

RETENTION PERIOD       

Duration of contract and statutory limitation period. We need to keep the information in case of any legal disputes concerning the contract.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Service Providers
• IT Cloud Solution Providers
• Electronic Delivery Tracking

PROCESSING

This service is provided by our Delivery Service Providers, and is subject to availability by the Delivery Service Provider servicing your delivery address. Depending on the delivery service provider, you may have the option to track your delivery using services provided directly by our delivery partners. This service is provided on the basis of our consumers’ legitimate interest so they can organise receipt of their parcels. However, with some service providers, this may only be possible with your consent. The service is hosted on the Delivery Partner’s platform. You should read their Cookies and Privacy Notice for the processing of your Personal Data for this purpose.

LEGAL BASIS    

Legitimate Interest / and where applicable, Consent

CATEGORIES OF PERSONAL DATA           

• Identity information: email address
• Contact information: phone number
• Any other information you may directly and voluntarily provide to the Delivery Partner

RETENTION PERIOD       

As determined by our Delivery Partner.

CATEGORIES OF RECIPIENTS     

• Delivery Service Providers

4.8. Business Operational Analytics

PROCESSING

We need to know how we do as a business. This is in the interest of our shareholders, our board members, our employees, and our partners, as well as our consumers. We create data models for different analytical purposes, and analyse using these data models to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of our marketing and advertising campaigns, our product designs and distribution strategy, our website design and overall user experience, so we can establish, implement, and evaluate our business strategy.

This includes, for example, analysing data to understand how users browse our site and use the app to improve our user experience design to make sure you will continue to purchase our products and interact with us on our sites and applications.

We remove any identity information that would directly identify you (for example, your name and email address), and use only our internal unique identifier IP address to minimise any possible privacy risks to you.

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information. 

You can learn more about how our Data Analytics Solution Providers provide analytics services by using your data here:

Adobe Analytics Data Collection: https://marketing.adobe.com/resources/help/en_US/reference/c_Privacy_Overview.html

Google Analytics Data Collection:

https://support.google.com/analytics/answer/6318039?hl=en

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity information: Unique Consumer Identifier (only)
• Measurements
• Behavioural and Preference Information
• Location Information
• Payment, Purchase and Transaction Information
• Browsing Information
• Mobile Device Information
• Correspondence
• Social Media Interaction and Activity
• Personal Opinion
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

When using analytics services provided by the vendors identified above, we are required to retain data for the period specified by these vendors. You can find the retention period indicated by the vendors here:

Adobe Analytics: 36 months (https://marketing.adobe.com/resources/help/en_US/reference/data-retention.html )

Google Analytics: 38 months

(https://support.google.com/analytics/answer/7667196?hl=en)

We need the information for this duration to produce accurate analysis of our business operations.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Prospective Buyers and Investors
• Business Consulting Service Providers
• Data Analytics Solution Providers
• IT Cloud Solution Providers

4.9. Customer Service

PROCESSING

We collect your Personal Data to answer your queries about your order, inform you when the product you like is available upon your request, and respond to your questions and concerns through various communications channels we make available to you. Your requests to our customer service will be analysed so that we can provide you with valuable service in the future. 

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information
• Location information
• Measurements
• Payment, Purchase and Transaction Information
• Correspondence
• Membership Administration Information (where RAP brand membership applies / if available to RAPI
• Image and Recordings (with your consent only)

RETENTION PERIOD       

Statutory limitation period: 2 Years

We need to keep the information in case of any legal disputes.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Selling Partners (where applicable)
• Delivery Service Providers
• Payment Processing Providers
• IT Cloud Solution Providers

4.10. Personalised Marketing Messages Via Email (Newsletter Sign-Up)

PROCESSING

We send you marketing messages that we think you would be interested (“personalised”) to the email address you provide to us. To send you “personalised” messages, we observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behaviour means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information. 

LEGAL BASIS    

Consent

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information
• Location information
• Measurements (if available to RAP)
• Payment, Purchase and Transaction Information (if available to RAP)
• Social Media Interaction and Activity (if available to RAP)
• Browsing Information
• Mobile Device Information
• Behavioural and Preference Information (if available to RAP)
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

We retain it for as long as you do not withdraw your consent sending you emails or object to us processing your Personal Data for marketing purposes.

CATEGORIES OF RECIPIENTS     

• RAP AG Subsidiaries and Affiliates 
• Email Marketing Support Providers
• IT Cloud Solution Providers

4.11. Personalised Marketing Messages Via Email (Via Existing Contract)

PROCESSING

When you purchase our products or conclude any contracts with us, we consider that to be an indication of interests to our products, services, promotions, and various offerings. We send you marketing messages that we think you would be interested in (“personalised”) to the email address you provide to us. To send you “personalised” messages, we observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what product lines you might be interested in, and you can benefit from. This requires us to collect various categories of Personal Data from you. We use different analytics tools to understand what your behaviour means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information. 

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information
• Location information
• Measurements (if available to RAP)
• Payment, Purchase and Transaction Information (if available to RAP)
• Social Media Interaction and Activity (if available to RAP)
• Browsing Information
• Mobile Device Information
• Behavioural and Preference Information (if available to RAP)
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

We retain it for as long as you do not withdraw your consent sending you emails or object to us processing your Personal Data for marketing purposes.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates 
• Email Marketing Support Providers
• IT Cloud Solution Providers

4.12. Targeted Messages On 3rd-Party Advertising Platforms

PROCESSING

We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted at you, based on your behaviour and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. In order to do this, we share your Personal Data with our Advertising Agency Partners as well as Social Media Platforms. We use third-party solutions such as Google Analytics and Facebook Business Manager tools to help us do a better job at targeting our campaigns and messages for our consumers. Social Media Platforms will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from RAP. We also need to analyse necessary information to understand the impact of our campaigns. If you don’t accept that we track you for this purpose, you will still see RAP advertisements on Social Media Platforms and other third-party platforms at random. Please also read the Cookies and Privacy Notice on the Social Media Platforms to understand how your Personal Data is used by them for this purpose.

Use of Cookies/Tags/Pixels: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect your device information.

You can learn more about how our Advertising Partners and Social Media Platforms help us achieve this purpose by visiting their sites:

Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en

Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956

Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531

Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience

LEGAL BASIS    

Consent

CATEGORIES OF PERSONAL DATA           

• Identity information
• Contact information (if available to RAP)
• Location information
• Measurements (if available to RAP)
• Payment, Purchase and Transaction Information (if available to RAP)
• Social Media Interaction and Activity (if available to RAP)
• Browsing Information
• Mobile Device Information
• Behavioural and Preference Information (if available to RAP)
• Personal Opinion
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

We retain it for as long as you do not withdraw your consent.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates 
• Advertising Agency Partners
• Social Media Platforms
• Targeted Marketing Service Providers
• IT Cloud Solution Providers

4.13. Product Research and Development

PROCESSING

We conduct analysis to research improve our products and services. This includes asking you questions in surveys, asking you for feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us, try new technologies in our product that might collect Personal Data to stay ahead of the competition. We retain this information based on our “legitimate interest”, so by participating in any product review or survey, you agree that this is our legitimate interest. Where it is possible for the specific project or if you object to this legitimate interest, we will remove any identity, contact, or mobile device information, so the information cannot be used to identify you, and will no longer be your Personal Data, and is considered “anonymised”.

LEGAL BASIS    

Legitimate Interest

CATEGORIES OF PERSONAL DATA           

• Measurements (only if required by the project)
• Identity information (only if required by the project)
• Contact information (only if required by the project)
• Location information (only if required by the project)
• Payment, Purchase and Transaction Information (only if required by the project)
• Social Media Interaction and Activity (only if required by the project)
• Browsing Information (only if required by the project)
• Mobile Device Information (only if required by the project)
• Correspondence (only if required by the project)
• Behavioural and Preference Information (only if required by the project)
• Membership Administration Information (where RAP brand membership applies / if available to RAP)

RETENTION PERIOD       

The duration of the project and statutory retention period stated to protect our IP rights.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Prospective Buyers and Investors
• Business Consulting Service Providers
• Data Analytics Solution Providers
• Manufacturing Providers
• IT Cloud Solution Providers

4.14. Legal Obligation – Cooperation with Law Enforcement And Regulatory Authorities (Including Courts)

PROCESSING

When we are legally required to provide your Personal Data for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims, we will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law. We may not be able to notify you if it is against the law to do so.

LEGAL BASIS    

Legal Obligation

CATEGORIES OF PERSONAL DATA           

All Categories of Personal Data as requested by the enforcement authority.

RETENTION PERIOD       

For as long as required by law.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates 
• Local and national government authorities, including tax authorities
• Local and national law enforcement agencies
• Local and national judiciary

4.15. Evidence – Contract Dispute and/or Legal Compliance

PROCESSING

We need to keep evidence in case of any contractual dispute, or to defend ourselves in case of any investigatory audits or privacy compliance disputes and complaints, including how we have handled your individual rights.

LEGAL BASIS    

Legal Obligation

CATEGORIES OF PERSONAL DATA           

All Categories of Personal Data as required to be used as evidence

RETENTION PERIOD       

Statutory Limitation period depending on the contractual period and/or the legal requirement

CATEGORIES OF RECIPIENTS     

RAP Subsidiaries and Affiliates 

4.16. Collecting Your Device Information on Our Website and Apps Using Cookies, Pixels, Tags, And Similar Technologies (“COOKIES NOTICE”)

PROCESSING

When you visit the RAP site, we store data collectors such as cookies, tags, pixels, tag containers, beacons, among others, in your browser to obtain certain information about your current browsing session. These technologies are often referred to as “Cookies” collectively by other websites. Cookies also enable our website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. We use Cookies for different purposes, which also mean they have different legal bases. Please review the information below to understand how we use different types of Cookies to fulfil different purposes.

“REQUIRED”

Site functionality and business operation:

We use “Required Cookies” to operate our site.

This includes storing a unique identifier to manage and identify you as a unique visitor to our site, to provide a consistent and accurate service to you.

This includes making sure that we remember the products you have placed in your cart, or your language preferences.

These Cookies are stored for the duration of your browsing session. Without these Cookies, you will not be able to view our site properly.

LEGAL BASIS    

Legitimate Interest

“FUNCTIONAL”

Website improvement and performance. We use “Functional Cookies” to continuously improve our website performance. This includes using the data we collected from you to do the following:

• Web analytics —Based on your browsing behaviour, we will analyse the data to improve the functionality and design of our site.
• Ad response rates— Based on how you come to our site, we will measure our ad response rates by analysing our ad click-through rates to improve the effectiveness of advertising purchased on a site external to ours.
• Affiliate tracking— We need to let our affiliate marketing partners, or service providers have certain information if you came to our site, and purchased products, through a visit to theirs. This is required as we may need to provide them a fee for such services. For this purpose, we will share information about your visit, including the products you have purchased.
• Error management— We measure errors presented on a website, to make sure we fix bugs or any issues promptly.
• Testing designs— We need to use A/B testing or multivariate testing, to ensure a consistent look and feel is maintained for the user of the site in the current and subsequent sessions.

LEGAL BASIS    

Legitimate Interest

Consent – for the installation of any “Cookies” tagged as a “Functional Cookie” on your device and browser

“MARKETING”

Website improvement and performance. We use “Marketing Cookies” provided by our advertising partners to make sure our advertising messages are shown to you at the right time and the right place. These Cookies are persistent but time-limited cookies. These Cookies contain a unique key to distinguish individual users’ browsing habits. We also use these Cookies to limit the number of times a user sees a particular ad on a website and to measure the effectiveness of a particular campaign. The identifier stored by these Cookies are provided by our partners. We cannot use the same identifier in our own systems. We also use these cookies to serve ads that are relevant to your immediate geo-location.

LEGAL BASIS    

Consent – for the installation of any “Cookies” tagged as a “Marketing Cookie” on your device and browser, and for using your Personal Data collected for the purposes described under above.

CATEGORIES OF PERSONAL DATA           

• Identity Information (when available to RAP)
• Browsing Information
• Mobile Device Information
• Location information: this is collected through observing your browsing behaviour
• Membership Information (when available to RAP)
• Behavioural and Preference Information (if available to RAP)

RETENTION PERIOD       

The cookies, pixels, tags, and other similar technologies used to collect your device information and browsing behaviour information are stored in your browser for the session or for as long as you do not clear your browser cookie setting.

The data we obtained through the cookies related to other purposes will be stored for the duration of that purpose.

CATEGORIES OF RECIPIENTS     

• RAP Subsidiaries and Affiliates
• Site Administration Support Providers
• Business Consulting Service Providers
• Data Analytics Solution Providers
• Advertising Agency Partners
• Social Media Platforms
• Targeted Marketing Service Providers

You can change your browser settings to delete or prevent certain cookies from being stored on your computer or mobile device without your explicit consent. The ‘help’ section in your browser should provide information on how to manage your cookie settings.

Find out how this works for your browser here:

Internet Explorer: https://support.microsoft.com/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies

Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

Safari: http://support.apple.com/kb/PH5042

Opera: http://www.opera.com/browser/tutorials/security/privacy/

Adobe (flash cookies): http://www.adobe.com/privacy/policies/flash-player.html 

Google Chrome App: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DAndroid&hl=en

These websites will also help you understand more about how Cookie-based advertising works and how you can manage your Cookie Settings:

http://www.aboutads.info/choices

http://www.youronlinechoices.eu/

Network Advertising Initiative opt-out page: http://optout.networkadvertising.org/?c=1

You can learn more about the laws governing the use of “Cookies” here: http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm

4.17. User-Generated Content (UGC) Acquisition From Social Media

PROCESSING

We invite you to provide your images to us via social media platforms by following specific instructions such as “#ARAUTORAP” and “#RAPSHOES”. We will be using the images you provide for our campaign communications. We will obtain rights to your image through a licence agreement in the form of our terms and conditions. By submitting your images via social media platforms to us, you will agree for us to use your images as described in the licence agreement.

LEGAL BASIS    

Performance of Contract

CATEGORIES OF PERSONAL DATA           

• Identity information: your social media handler
• Community information: images, videos, comments, sound recordings and other files provided through the social media platform promoting RAP
• Social Media Interaction and Activity

RETENTION PERIOD       

Duration of licence agreement and statutory limitation period in case of any disputes.

CATEGORIES OF RECIPIENTS     

• RAP  Subsidiaries and Affiliates
• Event Partners (where applicable)
• UGC Support Partners
• Advertising Agency Partners
• Social Media Platforms
• IT Cloud Solution Providers (where applicable)

5. What does Rap do when we transfer your Personal Data outside of the EU/EEA?

Depending on the Personal Data processing activity, your Personal Data is shared with different “Categories of Recipients”. Where the recipient is located outside the EU/EEA, we have implemented necessary measures such as singing the EU Standard Contractual Clauses approved by the EU Commission and appropriate security safeguards.

6. How do we secure your Personal Data?

We implement appropriate technical and organisational measures to address the risks corresponding to our use of your Personal Data, including loss, alteration, or unauthorised access to your Personal Data, and empowering you to exercise your rights. We require our service providers to do the same through contractual agreements. However, you should be aware that any transmission of your Personal Data through the internet is at your own risk. We can only protect your Personal Data when we have it.

7. General Questions, Support

RAP CUSTOMER SERVICE

If you have any general questions or require immediate assistance and support concerning your rights or how we use your Personal Data, please contact our Customer Service team “[email protected]”.

LOCAL AUTHORITIES

If you have any questions about your rights, please consult your local authorities’ websites and offices. 

8. Recipients of your Personal Data

You can find a list of Data Recipients who processes your Personal Data under Responsible Entities’ instructions below. The list is subject to change as necessary.

COMPANY – SERVICE

• • Facebook
  • Google Analytics
  • Paypal
  • Fedex
  • Amazon
  • etc

Where your personal data may be used by non-RAP Data Controllers via RAP platforms, applications or elsewhere for their own purposes, please consult the Cookies and Privacy Notice of the non-RAP Data Controller for more information about how they handle your personal data.