Hotter Shoes Privacy Policy
Hotter Shoes takes its data protection and security responsibilities seriously and we take all necessary steps
to ensure we treat your data according to best practice. This privacy policy aims to demonstrate how we
collect and use your data, for what purpose and with whom we share it.


The Aim of the Policy
This privacy policy tells you what to expect when you interact with Hotter through various channels and how we collect and use your personal information. This policy will be available on every page of our website via the footer and on request from our Contact Centre and Retail Stores.

How we use your information
Visiting our websites
When someone visits www.hotter.com we use third-party analytical services, such as Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.


How we use cookies
You can read more about how we use cookies on our ‘Cookies page’.

Search engine
Our website search facility is powered by IBM WebSphere and Attraqt. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific data is collected by either Hotter or any third party.

E-newsletters and email promotions
We use a third-party provider, IBM Watson Marketing, to deliver our regular e-newsletters and email offers. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our communications via this channel.

Security and performance
Hotter uses two third party services to help maintain the security and performance of the Hotter website (Thawte & Security Metrics). To deliver this secure service it processes the IP addresses of visitors to the Hotter website.

Shopping with us online
When you purchase something from Hotter online, we collect contact details from you in order to fulfil our contractual obligation to provide you with your goods and services. We also (upon your initial registration) ask you to confirm your marketing preferences with us. Up to and including 24/05/2018 this will have been through the use of pre-ticked boxes which you would have needed to untick in order to opt out. Any new customer account signups during checkout/order confirmation from 25/05/2018 will assume that you want Hotter to stay in touch with you using catalogues, emails, SMS & phone calls however you will need to explicitly opt-in to have your information passed to any Third-Parties for marketing via post. You can however opt out of all of these at the time by making the appropriate selections when prompted.

In order to do this, we use the legal basis of ‘Legitimate Interest’ which allows collection of data where these circumstances apply:

  • We obtained the contact details in the course of a sale (or negotiations for a sale) of a product or service to that person;

  • We are only marketing our own products or services; and

  • We gave the customer a simple opportunity to refuse or opt out of the marketing, both   when first collecting the details and in every message after that.

The options you will be presented with are as follows:

  • Email: Please send me the latest offers, details of products I might like, the latest news   and competitions.


  • SMS: I’m happy to receive details of your latest offers and information by SMS.


  • Telephone: I’m happy to receive details of your latest offers and information by   telephone.

  • Third Parties: I’m happy for you to share my details with the following carefully selected third parties who may contact me about relevant offers and products by post, from industries including but not limited to, clothing and footwear, general retail and charities. These partners may also analyse my data in an anonymised way, to help understand trends to improve services.

One exception to this is that when you make a purchase we will continue to send you our catalogues using the reasoning of legitimate interest. This will enable us to keep you up to date with our latest collections and offers. However, you are given the option to opt out of that also. The initial registration page will state “From time to time we will contact you via post about our products, relevant offers, news and competitions by post.”.

The full list of industries we currently have sight of are as follows; charities, transportation, service and professional industries, manufacturers of food and beverages, household goods, wearing apparel, furniture, health preparations, technology, electronic and optical products and motor vehicles, as well as health and care services, information and communication providers and financial and insurance industries.
Third party partners we work with on this include Epsilon, Abacus, Experian, Club Canvasse and Access DM Limited.

All pages which reference marketing preferences will include clear direction on how to opt out of or tailor your marketing communications. The details of this are as follows:

If you wish to opt-out of receiving marketing communications from Hotter at any time, please visit www.hotter.com/opt-out, call 01695 213213 or write to:

Customer Services
Hotter Shoes
2 Peel Road
West Pimbo
Skelmersdale
Lancashire
WN8 9PT

The security of your personal information is important to us.

Your details are recorded during your shopping experience with Hotter and communicated through our IBM WebSphere website. They are then sent to our central system (Microsoft Navision) which stores the information you have provided to us securely.

Details recorded as part of the above processes include names, addresses, telephone numbers, email addresses, comments on cases and dates of birth. You don’t have to give us your date of birth however, if you choose to, we will occasionally use this to send customised offers, usually on or around your birthday. Also, we could use this in an anonymised way to understand the demographics of our valued customers, to help us improve our offers.

We also take your payment card details during any credit/debit transactions however we do not store this information. We can, at your request, store an encrypted token that enables us to retrieve the last 4 digits of the card number and card expiry date in order to speed up any future purchases.


Contacting us via social media
We use social media platforms directly, rather than using a third-party system. This is managed by specially trained advisors in our Head Office. This is managed by specially trained advisors in our Head Office, rather than using a third-party system.

If you send us a private or direct message via social media, the message will be stored by the social media site itself, however you are able to sign in and change your privacy settings on these. Hotter will not actively share this information with any other organisation.

Calling our Contact Centre
When you contact our Hotter team in Lancashire by telephone, we collect Calling Line Identification (CLI) information. This information is used to help improve efficiency and effectiveness.

Our advisors will ask you if we can record your telephone number for further use, along with your address and email details (if we don’t have them already). Also, if you haven’t given us your marketing preferences, we will also ask you to clarify if you wish these to be restricted from use by various channels.

Our Contact Centre application is called K3 (Navision) and this is used for recording customer details for the following purposes:

  • Taking and processing your order (each new transaction is classed as a new contract between ourselves and our customer)

  • Recording and storing marketing preferences

  • Arranging returns

  • Storing sales transaction data – This information is retained for a minimum of 6 years under the Companies Act of 2006.

Details recorded as part of the above processes include names, addresses, telephone numbers, email addresses, comments on cases and dates of birth. You don’t have to give us your date of birth however, if you choose to, we will occasionally use this to send customised offers, usually on or around your birthday. Also, we could look to use this in an anonymised way to understand the demographics of our valued customers, to help us improve our offers.

We also take your payment card details during any credit/debit transactions however we do not store all of this information. We can retain the last 4 digits and expiry date here to speed up your purchase if you ask us to. Instead we communicate the remaining digits with banking services using an encrypted token ID which protects against misuse.

Our Telephony service is called Openscape and this uses a call recording service called ‘Redbox’. Approximately 30 calls can be recorded at any one time however this is purely for use in training and quality monitoring. All call recordings are deleted within a 30-day period.

Emailing us
We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with best practice. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Any exchange of information over email is recorded within our Contact Centre systems (Openscape and Outlook) and used for future contact with you in relation to account management. We won’t add you to any marketing database unless you ask us to.

Using our LiveChat service
Our web chat service is managed by our Customer Service Advisors here at our head office. We use our own solution, which sends information into our Openscape communication tool which we use to handle customer enquiries in real time.

If you use the LiveChat service we will collect your name, email address (optional) and the contents of your LiveChat session. This information will be retained for no more than 4 weeks and will not be shared with any other organisation.

You can request a transcript of your LiveChat session if you provide your email address at the start of your session or when prompted at the end.

Visiting one of our Retail Stores
Every Hotter store operates a CCTV system. This is purely for use by exception in conjunction with Crime and Fraud prevention investigations if necessary.

Our in-store advisors may ask you if we can record your telephone number for further use, along with your address and email details and we will also ask you to clarify if you wish these to be restricted from use by various marketing channels.

The IT system in use here is called Microsoft Navision and this is used for recording customer details in the following ways:

  • Taking and processing your order (each new transaction is classed as a new contract between ourselves and our customer)

  • Recording and storing marketing preferences

  • Arranging returns

  • Storing sales transaction data – This information is retained for a minimum of 6 years under the Companies Act of 2006.

Details recorded as part of the above processes can include names, addresses, telephone numbers, email addresses, comments on cases and dates of birth. You don’t have to give us your date of birth however, if you choose to, we will occasionally use this to send customised offers, usually on or around your birthday. Also, we could look to use this in an anonymised way to understand the demographics of our valued customers, to help us improve our offers.

We also take your payment card details during any credit/debit transactions however we do not store all of this information. We can retain the last 4 digits and expiry date online to speed up your purchase if you ask us to. Instead we communicate the remaining digits with banking services using an encrypted token ID which protects against misuse.

What happens when you allow us to use your data for marketing purposes?
As referenced above, you have the ability to opt out of any/all forms of marketing by or on behalf of Hotter at any time. For those customers who are opted in, we use your data in a number of different ways depending on which preferences you have selected. We look to retain data for marketing purposes for up to 6 years from your ‘last purchased’ date.

Email:
Generally, our special offers and marketing campaigns are put together by our internal team here in Lancashire. This team also deal with choosing the opted-in customers who would likely benefit from these offers. Sometimes though, we may ask a trusted third-party partner organisation (More2) to help us understand which categories of customers would benefit most from each of our campaigns. We will provide them with the marketing material and they will use this to guide us on how to make the most appropriate selections of customers. This ensures you don’t get offers which are less appropriate to your needs, and when you do get an email, it’s more likely to be of benefit to you. We then send these email offers to you from our own email address.

We also monitor browsing on our website. When an opted in customer has been shopping on our website and subsequently abandons a session without making a purchase, we may send an email prompt some time later asking if ‘you would like to continue with yourpurchase?’ We do this by use of marketing cookies provided by our partner (Sub2). Details of these can be found in our cookie policy

SMS
Very rarely we may feature special offers and marketing campaigns using this channel. Again, our internal team here in Lancashire facilitates this. This team also deals with choosing the opted in customers that we want to market to. We then send SMS’ out using a secure online portal called TextLocal.

Third Parties:
If you allow us to send your data to our partner organisations (listed below), we will only allow your data to be used for carefully selected offers and services and only using the medium of Direct Mail (not email). We have agreements and processes in place between these partners and ourselves which protects your data from misuse and ensures we continue to be responsible as the Data Controller. They, as data processors, will be managed closely by Hotter to ensure compliance with GDPR regulations.

Direct Mail:
If you allow us to use your data for catalogue and brochure postal mailings, our team here in Lancashire will compile the material and send these out to you via an appropriate and secure logistics organisation. Sometimes though, we may ask trusted third-party partner organisations to help us understand which customers would benefit most from each of our campaigns. These are as follows:

  • More2; handle and analyse Hotter customer data to understand the most relevant messages and offers for you. They also process and collate this data and send it to our mailing houses to facilitate printing and mailing.

  • Intact; cleanse Hotter customer data to ensure we are up to date with changes made, for example, where customers are marked as ‘gone away’ according to Royal Mail or ‘deceased’ according to up to date centralised records

  • Pindar; handle and process data to print and personalise our mailings.

  • 4DM Eclipse; receive data from More2. They process your name and address data and use it to enclose your mailings and batch them up for collection by Secured Mail Services.

  • GI Solutions, The Lettershop Group and Paragon; all may handle and process your name and address data to print and personalise your mailings from time to time.

  • Secured Mail; handle our enclosed customer mailings and post them to you.

  • AC data; handle your data to screen it against lists of prospective customers that we want to introduce to Hotter. This lets us identify true prospects.

What else is my data used for?
We also send your name and address details to our third-party logistics partners, but that is only so they can deliver or collect your goods. This data is not stored permanently by our partners and is retained for up to 2 years.

Your rights
Under the GDPR of 2018, you have rights as an individual which you can exercise in relation to the information we hold about you.

You can read more about these rights here.

Making a complaint to us
When we receive a complaint, we make up a file containing all the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for up to 6 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

Hotter tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Hotter’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

Access to personal information
Hotter tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘Subject Access Request’ under GDPR Legislation. If we do hold information about you we will:

  • give you a description of it;

  • tell you why we are holding it;.

  • tell you who it could be disclosed to; and

  • let you have a copy of the information in an intelligible form.

To make a request to Hotter for any personal information we may hold, you need to put the request in writing, addressing it to our Data Protection Officer at the address provided below.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

If we do hold information about you, you can ask us to correct any mistakes or erase by contacting the Data Protection Officer (details below).

Disclosure of personal information
In many circumstances, we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.

You can also get further information on:

  • agreements we have with other organisations for sharing information;

  • circumstances where we can pass on personal data without consent for example, to prevent and detect crime and to produce anonymised statistics;

  • our instructions to staff on how to collect, use and delete personal data; and

  • how we check that the information we hold is accurate and up to date.

Lawful basis for processing your information
As covered in the detail above, Hotter obtains data as the Data Controller and processing takes place securely both internally and externally via data processors. The lawful basis on which this data is handled and processed is determined as follows:

  • Purchases – Contractual obligation for purchase of goods and services

  • Marketing to customers– Legitimate interest with option to opt-out (Explicit consent for any third party marketing)

  • Marketing to non-customer prospects (email or catalogue requests made) – Explicit Consent

  • Direct Mail – Legitimate interest with option to opt out

In order to do this, we use the legal basis of ‘Legitimate Interest’ which allows collection of data where these circumstances apply:

  • We obtained the contact details in the course of a sale of a product or service to that person;

  •We are only marketing our own products or services; and

  •We gave the customer a simple opportunity to refuse or opt out of the marketing, both when first collecting the details and in every message after that.

Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 18/05/2018.

How to contact us
If you want to request information about our privacy policy you can email us or write to:

Mark Adamson,
Data Protection Officer,

Hotter Shoes
2 Peel Rd,
Skelmersdale,
Lancashire,
WN8 9PT