PRIVACY POLICY

RANDEM'S PRIVACY POLICY

This privacy policy describes the personal data that is collected or processed when you use a RANDEM website, a digital experience, a RANDEM mobile application, or when you interact with one of our other products or services, all of which are part of the RANDEM Platform ("Platform"). It also explains how your personal data is being used, shared and protected, what choices you have regarding your personal data, and how you can communicate with us.

- WHO is responsible for processing your personal data?

- WHAT personal data do we collect and when do we collect it?

- MINORS

- TOOLS to manage the personal data that we collect.

- HOW and WHY do we use your personal data?

- DISCLOSURE of your personal data

- PROTECTION and MANAGEMENT of your personal data

- COOKIES and Pixel Tags

- USE of RANDEM's platform with third party products and services

- CHANGES in our privacy policy

- QUESTIONS and comments

WHO is responsible for the processing of your personal data?

"GRUPO ENAMEC ENLACE NACIONAL DE COMERCIO ESTRATÉGICO", SOCIEDAD DE RESPONSABILIDAD LIMITADA DE CAPITAL VARIABLE (a commercial company incorporated under the laws of Mexico); and Mr. José Saúl Gutiérrez Márquez and Mr. José Paulo Gutiérrez Márquez (referred to as "RANDEM", "our", "we" or "us" in this privacy policy).

WHAT personal data do we collect and when do we collect it?

We ask for certain personal information of yours in order to provide the products or services you request. For example, when you make purchases, communicate with our consumer services, request to receive communications, create an account, participate in our events, promotions, contests or use our Platform.

These personal data include:

- Your contact information, including name, email address, phone number, billing and shipping address;

- Your login and account information, including screen name, password and unique user ID;

- Your personal details, including gender, city of origin, date of birth and purchase history;

- Your payment or credit card information;

- Your images, photos and videos;

- Data on your complexion, including weight, height and body measurements (such as estimated stride and footwear/footwear measurements or clothing and accessories or clothing complements);

- Your personal preferences, including your wish list and marketing preferences.

We collect additional personal data from you to enable certain features within our Platform. For example, we request access to your phone's location data to record your location, your contacts to allow you to interact with your friends, or your social networking credentials to post content from our Platform on a social network. This personal data includes:

- Your social network information, including credentials and any information from your public postings about RANDEM or your communications with us.

When you interact with our Platforms, certain data is collected automatically from your device or web browser, as described below in the section entitled "Cookies and Pixel Tags". This data includes:

- Device ID, call status, network access, storage information and battery information; and

- Cookies, IP addresses, reference headers, data that identifies your web browser and version, web beacons, tags and interactions with our Platform.

MINORS

We do not knowingly collect personal information online from children under 13.

TOOLS to manage the personal information that we collect

When you use our Platform, we also provide you with notice at that time or obtain your consent practices. For example, we will obtain consent to use your location or to send you insertion notices. We may obtain such consent through the Platform or through the standard permissions available on your device.

In many cases, your web browser or the Platform on your mobile device will provide you with additional tools to allow you to control when your device collects or discloses certain categories of personal data. For example, your mobile device or web browser may provide tools to allow you to manage the use of cookies or location sharing. We encourage you to familiarize yourself with the tools available on your devices and to use them.

At this time, we do not respond to "no-tracking" signals sent by web browsers.

HOW and WHY do we use your personal information?

We use your personal data in the following ways:

To provide the characteristics of the Platform and the services you request

When you use our Platform, we will use your personal data to provide the requested product or service. For example, if you make a purchase at www.randemshoes.com or participate in an event or promotion, we will use the contact information you provide to communicate with you regarding the purchase, event or promotion. If you communicate with 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.

In many cases, to use certain features within our Platform, you may be required to provide RANDEM with additional data or consent for RANDEM to use certain data in a particular manner. For example, to use the heart rate monitoring features of our Platform, you may need to connect to a heart rate monitoring device. Similarly, to share content on social networks, you may need to provide your social network account credentials to log in.

To communicate information about our products, services, events and for other promotional purposes

If you are already a customer of RANDEM (for example, if you have placed an order with us), we may use the contact data you provided to send you marketing communications about similar products or services of RANDEM, where permitted by applicable law (unless you have chosen to opt-out). In other cases, we ask for your consent to send you marketing information.

We may use the information you provide to us, as well as information about other products or services of RANDEM, such as your use of the RANDEM Platform, your visits or purchases made in RANDEM stores, your participation in RANDEM events and contests (eventually through other affiliates of RANDEM), to personalize communications and advertisements related to our products and services that may be of interest to you. In the case of registered users, this may include data collected from their interactions with our Platform and associated with their account on all devices.

To operate, improve and maintain our business, products and services

We use the personal data you provide to us to conduct our business. For example, when you make a purchase, we use that information for accounting, auditing and other internal functions. We may use personal data about how you use our products and services to improve your user experience and to help us diagnose technical and service problems and administer our Platform.

To protect our rights, property or safety or those of others

We may also use personal data about how you use our Platform to prevent, detect or investigate fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, government requests or applicable law.

For general research and analysis purposes

We use data about how our visitors use our Platform to understand customer behavior or preferences. For example, we may use information about how visitors search and find products in to www.randemshoes.com, for understanding the best ways to organize and present product offerings at the front of our store.

Other purposes

We may also use your personal data in other ways and will provide specific notice at the time of collection and obtain your consent when necessary.

DISCLOSURE of your personal data

Disclosure by RANDEM

RANDEM discloses your personal data to the following people:

  • RANDEM entities for the purposes and under the conditions described above.

  • Service providers that process personal data (including the personal data indicated in the section "What personal data do we collect and when do we collect it") for commercial purposes on behalf of RANDEM, for example, to process credit cards and payments, shipments and deliveries, to host, manage and service our data, to distribute emails, for research and analysis purposes, advertising, analytics, to manage brand and product promotions, and to administer certain services and features.

  • Other third parties as necessary to: (i) comply with a government request, court order or applicable law; (ii) prevent illegal uses of our Platform or violations of the Terms of Use of our Platform and our policies; (iii) defend against third party claims

 

  • Other third parties to the extent necessary to: (i) comply with a government request, court order or applicable law; (ii) prevent illegal uses of our Platform or violations of the Terms of Use of our Platform and our policies; (iii) defend against claims by third parties; and (iv) assist in the prevention or investigation of fraud (e.g., counterfeiting).

  • Any other third party when you have provided your consent.

We may also transfer personal data we hold about you in the event that 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).

We do not sell your personal data.

Disclosure by you

When you use certain social features on our Platform, 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 activity on RANDEM. We recommend that you use the tools we offer to manage the disclosure in RANDEM's social networks to control what information you make available through RANDEM's social features.

PROTECTION and MANAGEMENT of your personal data

- Encryption and Security: We use various technical, administrative and organizational security measures, including encryption and authentication tools in certain circumstances, to maintain the security of your personal data.

Despite our efforts, no website, mobile application, database or system is completely secure or "hacker-proof. To help keep your data safe, you can take reasonable steps to protect your personal information from unauthorized disclosure or misuse.

- Retention of Your Personal Information: We retain your personal information for as long as necessary to fulfill the purposes described in this policy, unless otherwise required or permitted by law. For example, we retain your account profile information as long as you retain your RANDEM account, but we may keep your order history longer to comply with legal obligations.

 

- Management of your personal data: you may have the right to request: (i) access to your personal data (both the categories of data we collect, which are set out in this policy, and the particular types); (ii) an electronic copy of your personal data; (iii) correction of your personal data if it is incomplete or inaccurate; or (iii) deletion or restriction of your personal data in certain circumstances as provided by applicable law. We will not discriminate against you in exercising these rights. If you request to delete your account, you may create a new account on our Platform at any time. If you have, any requests because the impediment to fulfill your personal data in your account settings, please contact us. You can find contact details in the "Questions and Comments" section below.

- Managing Your Content: You may request the removal of User Generated Content posted on the Platform, but please note that removal may not cover all possible locations, for example, backups or disclosures by other users initiated prior to removal.

- Management of your notifications: If you have a RANDEM account, you may opt out of receiving marketing communications from RANDEM. To do so, change your preferences in your account settings. Alternatively, you may opt out by following the opt-out or unsubscribe instructions in the message or by contacting us. You can find contact information in the "Questions and Comments" section below.

COOKIES and Pixel Tags

RANDEM collects information that may include personal data when you use our Platform. We use various 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 the necessary 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 Platform, such as click behavior, purchases and preferences listed; and (ix) access times and referring URLs.

In addition, some advertising and technology partners may collect personal data when you use our Platform. These partners have agreed to act as service providers on behalf of RANDEM and have agreed to use your personal data for RANDEM's purposes only as described in this policy.

In some cases, our Platforms allow you to log in or connect your RANDEM account with an external social network account or partner. If you do so, your use of their technology within our Platform will be subject to the terms and policies of the external social network or partner.

We use cookies and pixel tags to track Platform usage and to understand our customers' preferences (such as country and language options). This allows us to provide services to our customers and enhance their online experience. We also use cookies and pixel tags to obtain aggregate data about Platform traffic and Platform interactions, to identify trends and to obtain statistics in order to improve our Platform. In general, there are three categories of cookies used on our Platform:

- Functional: These cookies are necessary for the basic functionality of the Platform and are therefore always enabled. They include cookies that allow you to remember while browsing our Platform within a single session or, if requested, from one session to another. They help make it possible to use the shopping cart and the checkout process, as well as assist in security and compliance issues.

 

- Performance: These cookies allow us to improve the functionality of our Platform by tracking usage. In some cases, these cookies improve the speed with which we can process your request and allow us to remember the preferences you have selected on the Platform. Rejecting these cookies may result in less than personalized recommendations and slow Platform performance.

- Social Networking and Advertising: Social Networking Cookies offer you the ability to connect to your social networks and share content from our Platform through them. Advertising cookies collect information to help better tailor advertising to your interests. In some cases, these cookies involve the processing of your personal data. When you reject these cookies, you may see advertisements that are not as relevant to you or you may not be able to effectively access them through a link to Facebook, Twitter or other social networks or share content on social networks.

Your browser can help manage cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this from your browser settings on each browser and device you use. Browsers differ slightly from each other, so please refer to your browser's Help menu for the correct way to modify your cookies. If you disable cookies, you may not have access to many features that make our Platform more efficient and some of our services will not function properly. There are also general resources for opting out of targeted advertising available on the Network Advertising Initiative and Digital Advertising Alliance websites.

Similarly, you can adjust your advertising preferences on your mobile device at the device level. For example, to adjust your advertising preferences in iOS, go to Settings > Privacy > Advertising > Limit Ad Tracking. To adjust your Android advertising preferences, visit Settings > Google > Ads > Cancel Ad Customization.

USING RANDEM's platform with third party products and services

Our Platform allows you to interact with a wide variety of other digital products and services. For example, our Platform can be integrated with third party devices for activity monitoring, social networks, music-streaming services and other digital services.

If you choose to connect your RANDEM account to a third party device or account, your privacy rights on the third party platforms will be governed by the respective policies of the third party. For example, if you choose to share your activity at RANDEM on third party social networking platforms, the policies of those platforms govern the data residing there.

Our Platform may provide links to other (third party) websites and applications for your convenience or information. The linked sites and applications have their own privacy notices or policies, which we strongly encourage you to review. To the extent that we do not own or control the linked websites or applications, we are not responsible for the content, use of the websites or applications, or the privacy practices of the websites or applications.

CHANGES to our Privacy Policy

Applicable law and our practices change over time. If we decide to update our privacy policy, we will post the changes on our Platform. If we materially change the way we process your personal data, we will provide you with prior notice or, if required by law, ask for your consent before implementing such changes. We strongly recommend that you read our privacy policy and keep yourself informed about our practices.

QUESTIONS and comments

We welcome your questions, comments and concerns about our privacy policy and practices.

If you have any comments or questions, or if you wish to exercise your rights regarding your personal data, please use our e-mail address support@randemshoes.com

If you contact us regarding a privacy complaint, we will evaluate it with the goal of resolving the issue in a timely and effective manner.

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