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SKOLEOM PRIVACY AND COOKIE POLICY

This Privacy Policy describes the personal data that is collected or generated (processed) when you interact with Skoleom through our websites, digital experiences, mobile applications, stores, events, or any of our other products or services, all of which are part of the Skoleom Platform (“Platform”). It also explains how your personal data is used, shared and protected, the choices you have regarding your personal data, and how you can contact us.

Who is responsible for processing your personal data?

The Skoleom entity responsible for processing your personal data will depend on how you interact with the Skoleom Platform and your geographic location in the world. The relevant Skoleom entities are referred to as “Skoleom”, “our”/”us” and “we” in this Privacy Policy.

Please see our Local Entity List for the name of the responsible Skoleom entity and its contact information.

What personal data do we collect and when?

We ask you to provide us with certain personal information in order to provide you with the products or services you request. This is the case, for example, when you make purchases, contact our customer service department, request to receive communications, create an account, participate in our events or competitions, or when you use our Platform. In addition, when you request specific services in-store, we may ask you to log in to provide those services, which are then associated with your account (e.g., size, fit, preferences).

This personal data includes your :

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

– user and account information, including your username, password and unique user ID;

– personal information, including your gender, city, date of birth and purchase history;

– payment or credit card information;

– images, photos and videos;

– physical characteristics data, including weight, height and measurements (such as estimated stride, shoe size or clothing size);

– fitness data provided by you or generated through our Platform (such as time, duration, distance, location, calorie calculation, pace/run); or

– personal preferences, including your wish list, marketing and cookie preferences.

We collect additional personal data from you to enable specific features on our Platform. For example, we request access to your phone’s location data to provide you with your running route, your contacts to allow you to interact with your friends, your calendar to schedule a training session, or your social network credentials to post content from our Platform to a social network.  This personal data includes your :

– motion data from your device’s accelerometer;

– photos, audio, contacts and calendar;

– sensor data, including heart rate and location data (GPS); or

– social network information, including usernames and any information resulting from your public posts about Skoleom or your communications with us.

When you interact with our Platform, certain data is automatically collected from your device or web browser.  More information about these practices is provided in the “Cookies and Tags” section below. This data includes:

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

– cookies, IP addresses, referrer headers, data identifying your web browser version, web beacons, and interactions with our Platform.

Children’s Data

We comply with local laws and do not allow children to register on our Platform if they have not reached the legal age limit of the country in which they reside. We will seek parental consent for children to participate in Skoleom experiences and events.

Tools for managing the personal data we collect

When you use our Platform, we will provide you with timely information or obtain your consent for certain uses. For example, we will collect your consent to use your location or send you notifications. We may collect this consent from the Platform or by using the standard permissions available on your device.

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

Why and how we use your personal information

We use your personal data for the following purposes:

To provide the features of the Platform and Services that you request.

If you use our Platform, we will use your personal data to provide you with the product or service you requested.  For example, if you make a purchase from Skoleom.com, or participate in an event or promotion, we will use the contact information you provide to communicate with you about the purchase, event or promotion. If you contact our customer service department, we will use information about you, such as delivery or payment information or information about the product you purchased, to help resolve your problem or answer your question.

If you use our Platform to track your physical activity or physical characteristics, we will collect this personal data and store it for you to view on the Platform. Your physical activity data may include data you enter about your activity or data collected by your device during your activity, such as location or motion data.  We may use this activity data to calculate other information, such as the distance of a run or calories burned, so that this information can be provided to you as part of the Platform’s functionality.

In many cases, the use of certain features of our Platform require you to provide Skoleom with additional data or consent to use your data for certain purposes. For example, to use the heart rate tracking available on our Platform, you may need to log in to a heart rate tracking tool. Similarly, to share content on social networks, you may be asked to provide your social network account credentials to register.

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

If you consent, we will send you marketing communications and news about Skoleom products, services, events and other promotions that may be of interest to you.  You may unsubscribe at any time after giving your consent.

Direct Marketing

If you are currently a Skoleom customer (for example, if you have placed an order with us), we may use the contact information you provide to send you marketing communications about similar Skoleom products or services, where permitted by applicable law (unless you have opted out). In other cases, we will ask for your consent to send you marketing communications.

Personalization

We may use the information you provide to us, along with information from other Skoleom products or services – such as your use of the Skoleom Platform, your visits to or purchases from Skoleom stores, your participation in Skoleom events and competitions – to send you personalized communications about products and services that may be of interest to you. In doing so, we may combine the information you provide with information we generate based on your online activity, including internal observations and analyses.

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 this information for accounting, auditing and other internal purposes. We may use personal data about how you use our products and services to improve your user experience and to enable us to detect technical or service problems and administer our Platform.

To protect our rights, property, and those of others, and to ensure our safety and the safety of others

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

For research and analysis purposes

We use data about how our visitors use our Platform and services to understand consumer behavior and preferences.  For example, we may use information about how visitors to Skoleom .com search for and find products on this site to understand how best to organize and display our products in our store windows.

Use (Processing) of Training Information

As noted above, Skoleom collects data about your physical activity or physical characteristics (“Workout Information”) to provide services to you on our Platform.  Given the personal nature of this data, we strive to provide you with clear information about how this data will be used.  To the extent that such data may be considered sensitive in some countries, we take appropriate steps to protect it and its use and, if required by applicable law or Skoleom’s internal policies, we will seek your consent for its use.

Other Purposes

We may also use your personal data for other purposes; in such cases, we will provide you with specific information at the time of collection and seek your consent if required.

Legal basis

We rely on different legal grounds to process your personal data, depending on how you interact with our Platform.

– When you purchase Skoleom products from our Platform, we need your personal data to perform the contract between us and you. For example, we need your contact and payment information to deliver your order.

– When you use our Apps, we rely on your consent to processing and, for certain limited purposes, the performance of the contract between us (e.g., for purchases via the App).

– We also rely on other legal grounds, such as our legitimate business interests to process information relating to the effectiveness of our advertising campaigns, products, services, events and any other promotional initiatives; to operate, improve and maintain our business, products and services; to protect our rights, property or ensure our safety or the safety of others; and for research and analysis purposes. Where we process personal data to further our legitimate interests, we take appropriate steps to ensure that the interests pursued are proportionate to your interests, rights and freedoms, and we are available to explain these upon your request.

– We also process your personal data in order to comply with a legal obligation or to protect your vital interests.

Sharing of your personal data

Sharing by Skoleom

Skoleom shares your personal data with:

– Skoleom entities for the purposes and under the conditions specified above;

– service providers who process personal data on behalf of Skoleom, for example, for payment and credit card processing, shipping and delivery, hosting, administration and management of your data, e-mail distribution, research and analysis, brand management and product promotion, and the administration of certain services and features. When we use the services of service providers, we enter into contracts that require them to implement appropriate technical and organizational measures to protect your personal data;

– Other third parties to the extent necessary to: (i) comply with a governmental request, court order, or applicable law; (ii) prevent unlawful uses of our Platform or violations of our Platform Terms of Use and rules; (iii) defend against third party claims; and (iv) provide our assistance in fraud prevention or investigations (e.g., forgery).

– Third-party targeted advertising providers who provide us with customized advertisements tailored to our needs. We use such services to combine all of the information we have collected with personal data in their databases to create personalized audiences and advertisements based on your interests on the Internet, including social networks, as permitted by applicable law. You may withdraw your consent to personalized advertising and audiences by using the settings provided on our Platform;

– any other third party if you have expressed your consent.

We may also transfer your personal data in the event of a sale or transfer of all or part of our business or assets (including in the event of a reorganization, assignment, dissolution or liquidation).

Your Shares

When you use certain social features on our Platform, you may create a public profile that may contain information such as your screen name, profile picture and location. You may also share content with your friends or with the public, including information about your activity with

Skoleom.  We encourage you to use the tools we provide to best control the information you make available through the Skoleom features.

Protection and management of your personal data

Encryption and Security: We use a variety of technical and organizational security measures, including encryption techniques and authentication tools, to ensure the security of your personal data.

International Transfers of Your Personal Data: Personal Data that we collect (or process) for our Platform is stored in the United States and other countries. Some of the recipients with whom Skoleom

shares your Personal Data with may be located in countries other than the country in which your Personal Data was originally collected. The laws in these countries may not provide the same level of protection for personal data as those in the country where the personal data was originally collected. Nevertheless, when we transfer your data to recipients in other countries, including the United States, we protect that information as described in this Privacy Policy and in accordance with applicable law.

We take steps to comply with applicable legal requirements for the transfer of personal data to recipients located in countries outside the EEA, the United Kingdom (UK) or Switzerland, to ensure that your personal data transferred to these countries receives adequate protection in accordance with applicable data protection rules; this includes signing the EU Standard Contractual Clauses, or verifying that the recipients have adopted Binding Corporate Rules. When personal data is transferred within Skoleom, we use intra-group data transfer agreements.

Retention of Your Personal Data: Your personal data will be retained for as long as necessary to fulfill the purposes set forth in this Privacy Policy, unless a longer retention period is required by applicable law. In general, this means that we will retain your Personal Data for as long as you maintain your Skoleom account. For personal data related to product purchases, we retain it for a longer period of time in order to comply with legal obligations (such as tax or sales regulations and warranty purposes).

Your rights

You have the right to request: (i) access to your personal data; (ii) an electronic copy of your personal data (portability) and the transmission of this information to another company; (iii) rectification of your personal data if it is found to be incomplete or inaccurate; or (iv) erasure or restriction of your personal data in certain circumstances as provided by applicable law. These rights are not absolute. In cases where you have provided us with your consent to process your personal data, you have the right to withdraw your consent at any time.

If you wish to request a copy of your personal data or exercise any of your rights, simply log on to our skoleom.com platform.

Opting Out of Direct Marketing

If you have a Skoleom account, you may opt-out of receiving marketing communications from Skoleom by changing your preferences in the “view or edit my profile” section of our Sites. You may also opt-out by modifying your email or SMS subscriptions by clicking on the unsubscribe link or by following the unsubscribe instructions included in the message. You may also contact us using the contact addresses listed in the “Questions and Comments” section below.

Cookies and Beacons

Skoleom collects information, which may include personal data, from your browser when you use our Platform. We use various methods, such as cookies and beacons, to collect this information, which may include your (i) IP address; (ii) unique identification cookie, information cookie, and content information from your hardware to access certain features; (iii) unique hardware identification number and hardware type; (iv) domain, browser type and language; (v) operating system and settings; (vi) country and time zone; (vii) previously visited sites; (viii) information about your actions on our Platform, such as clicking behavior, purchases and preferences; and (ix) access times and referring URLs.

Third parties may also collect information from our Platform through cookies, third-party modules and widgets. These third parties collect data directly from your browser and the processing of such data is subject to their own privacy policies. More information about the identity of these third parties and their privacy policies is available at this address.

We use cookies and beacons to track our customers’ use of our Platform and understand their preferences (such as country and language). This allows us to provide services to our customers and improve their online experience. We also use cookies and beacons to obtain general information about Platform traffic and interactions, to identify trends and obtain statistics, and to improve our Platform. There are generally three categories of cookies used on our Platform:

– Functional cookies: These cookies are required for basic website functionality and are therefore always active. This includes cookies that allow us to recognize you when you visit our Platform during the same session or, if you wish, from one session to another. They allow us to establish your shopping cart and the payment procedure but also to ensure the security of exchanges and compliance with regulations.

– Performance cookies: These cookies allow us to improve the functionality of our Platform by tracking their use. In some cases, these cookies allow us to improve the speed with which we process your request and to remember the preferences you have selected. Rejecting these cookies may result in less relevant recommendations and slower site performance.

– Social Network and Advertising Cookies: Social network cookies provide the ability to connect to your social networks and share content from our Platform on social networks. Advertising cookies (from third parties) collect information to help tailor ads to your interests, both on and off our Platform. In some cases, these cookies require the processing of personal data. Rejecting these cookies may result in the display of ads that are not tailored to you or prevent you from effectively connecting to Facebook, Twitter or other social networks and/or prevent you from sharing content on social networks.

You can change your preferences at any time by visiting the “Cookie Settings” at the bottom of each page of our Platform.

For a clear and up-to-date summary of each third party accessing your web browser (via the Skoleom Platform or otherwise), we recommend that you install a specific module providing this function. You may also choose to have your computer alert you each time a cookie is sent, or you may choose to decline all cookies. You can make these choices by accessing the Internet browser settings on each of your devices. Each browser is different. Therefore, check your browser’s “Help” menu to understand how to change your cookie settings. If you refuse cookies, access to many of the contents of our Platform may be less efficient and some of our services may not function properly. There are also ways to opt out of targeted advertising in aggregate that are available on the Digital Advertising Alliance website.

Also, you can adjust your advertising choices from your mobile device in your mobile device settings. For example, to set your advertising preferences on iOS, go to Settings > Privacy > Advertising > Custom Ads. To set your advertising preferences on Android, go to Settings > Google > Ads > Turn off ads by interest.

Using the Skoleom Platform with Third Party Products and Services

Our Platform allows interaction with a wide variety of other digital products and services. For example, our Platform may integrate with third-party modules that enable activity tracking, connection to social networks, provision of music streaming services and other digital services.

If you choose to connect your Skoleom account with third-party modules or accounts, your rights and personal data will be governed by the terms of those third-party platforms. For example, if you decide to share your Skoleom activity on a social network, the terms of that social network will apply to the personal data involved.

Our Platform may provide links to other (third party) websites and apps to serve your needs or provide you with information. These third party websites and apps have their own data protection policies, which we invite you to read. Because Skoleom does not own or control these third-party sites or apps, we cannot be responsible for their content, use or privacy practices.

Changes to our Privacy Policy

Laws and practices change over time. If we decide to update our Privacy Policy, we will post the changes on our Platform. If we make material changes to the way we process your personal data, we will provide you with prior notice or, where required by law, we will ask for your consent before implementing such changes. We urge you to read our Privacy Policy and to check for changes regularly. This Privacy Policy was last modified in June 2021.

Questions and Comments

We welcome your questions, comments and concerns about our Privacy Policy and practices.

If you have any comments, questions or concerns, or if you wish to exercise your rights in relation to your personal data, simply log on to our Skoleom.com platform.

The contact information for our Data Protection Officer is as follows Personal Data Protection Office, skoleom France 157-159 rue du faubourgs Saint Honoré 75008 Paris.  [email protected]

If you contact us with a complaint about your personal data, it will be handled with a view to resolving it in a timely and effective manner. You also have the right to lodge a complaint with the competent supervisory authority in the country of your residence.