Privacy

Company Name: JD Federation Scotland (Under JD Sports Fashion plc)

Company Number: 01888425

Territory: UK

1. the best bits

   We only use your data to improve your JD experience

2. keeping it real

   We’ll talk to you straight – no stress, no worries

3. No Junk

   You choose what and how we speak to you

4. Super Safe

   Your Data is Protected 24 / 7

Everything we do at JD is about you! Things change, but it’s nothing to worry about . We take our customers privacy and security very seriously and we are 100% committed to protecting it so you can shop away without a single worry. If you have any questions about how we protect your privacy, just shout us @ Privacy.Support@jdplc.com

HOW WE USE YOUR DATA

We are committed to protecting your privacy. It is important that you understand how we look after your personal data and how we make sure that we meet our legal obligations to you under the data protection rules and regulations in the relevant territory (including associated guidance) (the " Data Protection Laws "). This privacy policy outlines how JD Sports Fashion plc and its group companies (together, the " JD Group ") will collect, use, store and share your personal data.

If you have any questions in relation to this policy or generally how your personal data is processed by us, please contact our customer care team by letter addressed to: Hollinsbrook Way, Pilsworth, Bury, Lancashire, BL9 8R ; by email at Privacy.Support@jdplc.com ; or by phone on 0161 393 7055

This policy applies to any personal data that we collect about you when you:

• visit our one of our websites;
• purchase products from us;
• visit one of our stores;
• contact us, for example by telephone, email, post or through submitting a form on our websites.

WHO ARE WE?

In this privacy policy, the terms " we ", " our ", and " us " are used to refer to the JD Group.

The controller of your information for the purposes of the Data Protection Laws will depend on which member of the JD Group you are dealing with. The table below sets out each of the data controllers within the JD Group and each of the brands operated by those data controllers.

JD GROUP WEBSITES (OUR "WEBSITES")

The relevant controller above is responsible for your personal data. This policy applies to all of the controllers above and the JD Group as a whole. Our brands each have their own websites. This central policy provides information to you about the basis on which the JD Group as a whole collects, uses, stores and shares your information. We will use your personal data fairly, lawfully and in a transparent manner and in accordance with the Data Protection Laws.

CONSENT

The brands and data controllers listed above within the JD Group may send you marketing messages by email, SMS, social media and post; about us and our products; where you have not unsubscribed and where you have purchased similar products and/or services from that brand or entity, or where you have otherwise signed up, or consented, to receive marketing messages from a brand or entity.

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team using the details at the start of this privacy policy. You can tell us you no longer wish to receive marketing information from us by clicking here.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

If you have an account with us or make a purchase online with us, or enter a competition or respond to a survey with us, we collect your name and contact details (including your address, telephone number, details about your order, and your billing information (where you are purchasing products)).

We also collect details of your interactions with us through our customer contact centres, in store, online or via our apps. For example, when you telephone one of our contact centres, we collect notes of our conversations with you and details of your query and from time to time we may record your calls for training and monitoring purposes. We also collect information about the purchases that you make, your saved items, your payment information, any complaints and comments that you make and your shopping preferences. We also collect CCTV images in all of our stores.

Each time you visit one of our websites, we will also automatically collect information and personal data about your computer for system administration including, where available, your IP address, operating system and browser type. We do this to help us analyse how users use the websites (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account and improving your online experience. We also collect information about your activities on our websites, for example what device you are using and what products you're looking at.

By way of example, some of our websites use SessionCam for analysis purposes and specifically to identify any technical issues or difficulties the users of our websites are having during the customer journey. To do this, SessionCam records your mouse clicks, mouse movements, scrolling of pages and the text that you key into forms on our websites. The information that we collect about you through SessionCam does not include your bank details or any special categories of personal data, but does include your name, address, telephone number, email address and anything else you may insert when completing an order. The information collected by us through SessionCam is used for our internal purposes only and is used to improve our websites' usability and is stored and used only for the purposes of collecting aggregates and statistics relating to the functional performance of our websites. SessionCam is operated for the JD Group by SessionCam Ltd.

Please see our cookies policy for further information about what information may be automatically collected when you visit our websites

Please note that, from time to time, we will combine personal data that we receive from other sources with personal data you give to us and personal data we collect about you.

WHERE DO WE GET THIS INFORMATION FROM?

We collect some of your information directly from you, either through information that you give to us or information that we collect during your visits to our websites, stores, or through your communications with us. We may also obtain some information from third parties, including retail analytics companies, consumer insight companies and credit reference agencies and publicly available sources to assist us with understanding customer demographics and shopper behaviours, or where we merge with or otherwise acquire another business.

WHY DO WE NEED YOUR INFORMATION?

The main purpose for which we use your information is to provide you with the products that you purchase from us and to send you offers and promotions that you might be interested in.

In particular, we use your information:

• to provide you with the products that you have purchased from us and any receipts of purchase, including to deliver your products, and to send you order status updates;
• to take payments for the products that you have purchased and to give refunds or exchanges;
• to provide customer service and support to you;
• to develop and improve our products and services;
• to develop and improve our websites and set default options for you (such as language and currency) and to ensure that content is presented in the most effective manner;
• to provide you with information that you request from us or which we feel may interest you. We may send you marketing information by email, SMS or post. This can include information about new products and offers that you may find interesting;
• to research our customers' preferences and trending products;
• to run surveys and competitions;
• to notify you about changes to our products;
• as part of our efforts to keep our stores safe and secure (for example through the use of CCTV in our stores);
• to prevent and detect fraud and crime (for example, through the use of CCTV in our stores).

BASIS FOR USING YOUR INFORMATION

Compliance with legal obligations

As a corporate group there are certain laws we need to comply with. In particular, we will need to process your personal information to verify your identity and for fraud and crime prevention purposes. Failure to provide the requisite personal information on sign-up / as you use our websites, may mean we cannot provide our products to you, as to allow you to purchase our products may mean we may be in breach of our legal obligations. You will not be able to object to processing or ask for the deletion of your personal information insofar as it falls under this category.

Necessary for the entry into or performance of a contract

When you enter into a transaction with us or one of our brands, a contract between you and the relevant brand will have been entered into. In order for us to fulfil our obligations under such contract (e.g. to allow you to place an order and receive products from us), we will need to collect and process your personal information. Failure to provide the requisite personal information on sign-up to an account or on placing an order and payment information or objecting to this type of processing / exercising your deletion rights will mean we cannot provide our products to you.

Legitimate business interests

We use your personal data as set out in this privacy policy for the legitimate interests of our business to enable us to:

• provide you with products as requested by you;
• carry out research to understand our customers and how they purchase and use our products;
• develop and improve our products.

As indicated below, we will also pass your personal data to members of the JD Group and other third parties and this is also for our legitimate business interests.

We are required to carry out a balancing test of our legitimate business interests in using your personal data outlined above against your interests and rights under the Data Protection Laws and regulations in the relevant territory. As a result of our balancing test, which is detailed below, we have determined, acting reasonably and considering the circumstances, that we are able to process your personal data in accordance with the Data Protection Laws on the basis that we have a legitimate business interest.

Consent

As set out above, we will send you marketing communications where you have not told us that you wish to unsubscribe and where you have purchased similar products and/ or services from the same brand or legal entity (as set out in the table above). You will also receive marketing communications from us where you have signed up, or otherwise consented, to receive marketing messages from a brand or entity within the JD Group.

You have the right to withdraw your consent to processing of this nature at any time by contacting our customer care team using the details at the start of this privacy policy.

WHO DO WE SHARE YOUR INFORMATION WITH?

We do not, and will not, sell any of your information to any third party, including your name, address, email address or credit card information. However, we do share your information with a number of select third parties to enable us to provide our products and services to you, to send marketing information and to improve our business operations as set out below.

We will share your information with other members of the JD Group but only for the purposes specified in this privacy policy. In particular:

• we will share your information with other members of the JD Group where you have consented for us to do so for the purposes of receiving marketing from those other JD Group members;
• we will share your information with other members of the JD Group for group analysis and business information purposes, to improve our products and services.

We will also use a number of carefully selected third parties to help us to provide you with products, services and to market to you. In particular, we disclose your information to:

• Companies that do things to get your purchases to you, such as payment service providers, warehouses, order packers and delivery companies;
• Our trusted service providers,such as marketing agencies, advertising partners, website hosts and other third parties who provide services to help us to tailor our marketing to you;
• Credit reference agencies, law enforcement and fraud prevention agencies;
• Companies approved by you, such as social media sites, including companies such as Facebook and Google; and
• We will provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you.

We will only share your information with third party suppliers where it is necessary for them to provide us with the services we need.

We may disclose your information to other companies in connection with any merger, acquisition, insolvency situation or otherwise, in which case we will only disclose your information so far as is necessary.

We may also need to disclose personal data to third parties to comply with a legal or regulatory obligation, or if necessary for legal proceedings.

WHAT AUTOMATED DECISIONS DO WE MAKE ABOUT YOU?

We carry out some profiling of you for the purposes of improving and developing our products and services and to help us to tailor our marketing to you.

The impact of any automated decision is to ensure you experience the best service possible.

We use information that we learn about you such as your gender, preferences, hobbies, interests and purchase history to make sure the marketing you receive from us and the way our websites are displayed to you are appropriate and tailored to you.

WHERE IS YOUR INFORMATION STORED AND HOW LONG DO WE KEEP IT FOR?

Transfers outside of the European Economic Area

The information which we collect about you may be transferred outside the European Economic Area. In the event of such transfer, we will ensure the adequate standard of security is in place for example by incorporating the European Commission approved clauses into our agreements with such third parties to ensure the security of your personal data. A copy of the European Commission approved model clauses is available here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en

Retention of your personal data

We will only keep your information for as long as is necessary to carry out the purposes we collected it for, as set out in this privacy policy (unless a longer retention period is required by the applicable law). We typically keep your personal data for 6 years from the purchase in order to enable us to deal with any issues or concerns you may have about the products or services you have received, and to allow us to bring or defend legal proceedings. In some circumstances, some of your data will be deleted in much shorter timescales, for example:

• cookies are deleted in accordance with our cookies policy
• CCTV images are kept for 60 days;
• marketing consents will be refreshed/deleted after 4 years, however, our aim is only to market to you for as long as we believe you want to continue hearing from us based on how you interact with us.

If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we will also keep hold of some of your information, even if it is no longer needed to provide our services to you.

Security of your personal data

Transmission of information via the internet is not and cannot be completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

WHAT NON-PERSONALLY IDENTIFIABLE INFORMATION DO WE COLLECT?

We may also collect non-personally identifiable information (that is, information that does not specifically identify you), for the purposes of aggregates and statistics.

WHAT RIGHTS DO YOU HAVE?

You have a number of rights under the Data Protection Laws in relation to the way we process your personal data, which are set out below. You may contact us using the details at the beginning of this privacy policy to exercise any of these rights.

In some instances, we may be unable to carry out your request, in which case we will contact you to explain why.

Marketing

We always give you the choice of whether or not you wish to receive marketing communications from us.

By contacting us Privacy.Support@jdplc.com you can tell us that you do not wish to receive marketing communications from us and we will update your records. You can also click on the unsubscribe link in any promotional emails.

WHAT IF YOU HAVE A COMPLAINT?

If you have any concerns regarding our processing of your personal data, or are not satisfied with our handing of any request made by you, or would otherwise like to make a complaint, please contact our customer contact centre in the first instance using the details at the start of this privacy policy, so that they can do their very best to sort out the problem.

You can also contact the Information Commissioner's Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk .

OTHER WEBSITES

Our websites may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.

CHANGES TO THIS PRIVACY POLICY

We will take all measures necessary to communicate any changes to this privacy policy to you, and will post any updated privacy policies on this page.

This policy was last reviewed and updated in May 2018.