Privacy Policy

This Privacy Policy (“Privacy Policy”) was last updated on April 29, 2021


Background:

Welcome to The Renewal Workshop privacy policy. The Renewal Workshop BV – a company subject to the direction and coordination of The Renewal Workshop Inc. - with registered office in Distelweg 78A Amsterdam, NL 1031HH, VAT number NL8604.06.854.B01, company Register Number 75817977 (“TRW”) operates the The North Face® ("TNF") Renewed product website that offers renewed, eco-friendly apparel from premium outdoor clothing brands and related services (the “Website”). 

When you use the Website or its services, information and personal data about you is collected. For this reason, in accordance with the provisions of the General Data Protection Regulation no. 2016/679 ("GDPR") and applicable national legislation (collectively, "Privacy Legislation"), TRW, acting as data controller, has created this Privacy Policy for the purpose of describing what personal data we collect, the purposes and methods of its processing and the security measures used to protect it.

You may contact TRW following the details in Contacting TRW section below.

Scope:

This Privacy Policy applies only to Personal Information and other information that we collect from or about visitors, users as well as customers collected or generated through the Website (“Customer Data”). This Privacy Policy does not apply to publicly available information or any information you post to any public areas of the Website, such as any suggestions, comments, ideas, and other unsolicited submissions (collectively, “Submissions”). Your Submissions may be read, collected and used by third parties and as a result, you may be contacted by such third parties whom we do not control.

Information We Collect:

When you engage with the Website, we may collect information that alone or in combination with other information could be used to identify you as described below.

In addition, with your consent, which is optional, we may share some of your Personal Information, notably name, surname and email address, with our partner VF International Sagl so that they may check whether you're a registered customer and to send you marketing newsletter about VF International Sagl , their products and promotions.

Personal Information: When you register for an account with TRW or place an order through the Website, we will ask you to create an account password and provide us with your:

  • Full name
  • Email address
  • Telephone number
  • Postal address
  • Payment information

We may collect Personal Information when you interact with customer service; in this case, we will collect the information necessary to provide you with the service requested.

We may also collect your Personal Information when you post comments on our blog or Reviews - in this case, we will collect only the information necessary to have your comments published on our blogs or Reviews.

Should you collect, process and disclose information about third parties to us, you must do so in accordance with the provisions of the Privacy Policy and applicable Privacy Legislation, therefore, you must provide them with prior notice of the processing and, if necessary, you must obtain their free and express consent before carrying out the processing.

Other Information:

  • IP Addresses; Device IDs: When you visit the Website, some information is automatically collected. For example, we may collect your computer's operating system, Internet Protocol (IP) address, access times, browser type and language, and referring website addresses. This information may be used for various purposes, including to analyze and report upon visits to and usage of the Website, to diagnose and prevent service or technology problems affecting the Website and to monitor and prevent fraud and abuse. If you access the Website from a mobile device, we may also collect information about the type of mobile device you use, your device's unique ID, the type of mobile Internet browsers you use and may also request access to your settings information for similar purposes. We also collect information about your usage of and activity on the Website. By visiting and using the Website, you are consenting to the collection of IP addresses and device identifiers.
  • Demographic Information: When you engage with the Website we may ask you to provide certain demographic information, such as whether you fall into a certain age range.  This information on its own cannot identify you.  If we combine it with information that can identify you we will treat it as Personal Information.
  • Automatically Collected/Non-Personal Information: When you interact with TRW through the Website, we use various technologies, such as cookies and web beacons or gifs to passively collect information from you that, on its own, does not identify you personally.  This information includes the browser or operating system you use to access the Internet, your IP address, the date and time you may have viewed certain pages on the Website. TRW may collect and store this information, or this information may be collected by and included in databases owned and maintained by our agents or service providers. If we combine Automatically Collected/Non-Personal Information with Personal Information, we will treat the combination like Personal Information. For more information on cookies and other tracking technologies, please see our Cookie Policy.

 Purposes and legal bases of the processing:

We use Personal Information for the following purposes and based on the following legal grounds: 

Purpose

Legal bases

Type of Personal Information

Website browsing.

Legitimate interest of allowing customers to browse the Website.

 

IP address; Device IDs; Demographic information; Aggregated Information.

Security of the Website.

Legitimate interest and compliance with the legal obligation of offering an adequate level of technical and organizational security while using the Website.

 

IP address; Device IDs; Aggregated Information.

Creation of registered account.

Contractual relationship with the customer.

 

Customer's ID, address and contact details; payment solution.

Purchase of TRW products.

Contractual relationship with the customer and compliance with any applicable legal obligation.

 

Customer's ID, address and contact details; payment solution.

Prevent frauds and other unlawful activities.

Compliance with any applicable law and legitimate interest of TRW.

 

Personal Information involved in the fraud / unlawful activity.

Manage disputes and/or complaints.

Compliance with any applicable law and legitimate interest of protection TRW's legal position.

 

Personal Information concerning the dispute / complaints.

Manage customers' subscription to the Website, purchase of TRW products/services or manage their requests to TRW.

 

Legitimate interest of providing support to TRW's customers.

Customer's contact details and information contained in the registered account.

Providing Personal Information for the above purposes is necessary to carry out the above listed activities and any refusal by you to provide this information would still allow you to use the Website, but would prevent you from creating a registered account, making purchases and receiving the products ordered, using some of our services and receiving the requested information.
With specific reference to the purchase of TRW products, Personal Information shall be processed to fulfil the contractual relationship  and the provision of such data is a contractual obligation. If you do not provide Personal Information, it will not be possible to conclude or execute the agreement and your requests. This means that you will not be able to purchase TRW products and that it will not be possible to handle your requests.

Please note that we will send you non-promotional emails, such as emails about your accounts or our ongoing business relations, in order to manage your subscription to the Website, your purchase of our products/services (e.g. abandoned shopping cart) or to manage your requests to us. These communications are not of a marketing nature and therefore will be sent to you irrespective of whether you consent or not to  marketing activities from VF International Sagl, the parent company of The North Face, as below described.

We will also process Personal Information to fulfil legal obligations to which we are subject and to prevent and prosecute fraudulent activities, as well as for internal administrative purposes.

In addition, with your consent, which is optional and freely given, we may share your Personal Information with our partner  VF International Sagl with offices at Via Laveggio 5, 6855 Stabio (Switzerland).  VF International  Sagl will use your Personal Information to check whether you are or not a registered customer on VF International Sagl 's customer database and for their marketing purposes, notably to send you marketing newsletter about VF International Sagl , their products and promotions.

You may always withdraw your consent or opt out of receiving promotional communications from VF International Sagl.

Not providing Personal Information for the marketing purposes above identified will have no consequences on the possibility for you to register to the Website, to make purchases, to receive our services and replies to your requests.

Methods of data processing and data storage

Customer Data will be processed by electronic means and always in compliance with the security requirements of applicable legislation, with particular but not exclusive reference to art. 32 of the GDPR. Our security measures are designed to (i) ensure a reasonable level of security, availability and integrity of Customer Data; (ii) protect against threats or hazards to the security, availability or integrity of Customer Data; and (iii) prevent unauthorized access to Customer Data. They also include contractual arrangements with any contractor (e.g. service providers) or other party in order to protect the security and confidentiality of your personal data in accordance with the provisions of our Privacy Policy.

However, no Internet or email transmission is ever fully secure or error-free. In particular, email sent to or from the Website may not be secure.  Therefore, you should take special care in deciding what information you send to us when disclosing any Personal Information to TRW.

TRW will retain Customer Data until the purpose for their use is achieved according to our internal data retention policy. TRW will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data, unless particular regulatory or judicial obligations apply, for instance to protect our rights in case of legal claims.

Disclosure of Your Personal Information:

The duly authorized personnel of TRW may access your personal data on a need to know basis only. We may share your Personal Information with certain third parties without further notice to you, in the following circumstances:

Business Transfers and Changes: As we develop our business, we might sell or buy businesses or assets. If we are involved in a merger, acquisition, reorganization, bankruptcy, receivership, sale of all or a portion of company assets, financing, transition of service to another provider or a similar event, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

Agents, Vendors, Service Providers and Related Third Parties: TRW, like many companies, sometimes hires and works with other companies (including third party vendors, consultants, and other third-party service providers) to perform functions related to our business, including operation of the Website, mailing information, maintaining databases and processing payments. We may share any information we receive with vendors and service providers retained in connection with the provision of the Website. In doing so, we only provide these third parties with the information that they need to perform their specific function. These third parties will act as our data processors and will be bound by our instructions to process your Personal Information.

Legal Requirements: TRW may disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) protect and defend the rights or property of TRW; (iii) act in urgent circumstances to respond to an emergency or protect the personal safety of any person or the public or (iv) protect against legal liability.

Customer Data may be transferred abroad to third party recipients established within the European Economic Area. This is a free transfer as each EEA country guarantees an adequate level of data protection. For the purposes indicated above, we may also transfer your data in the US, to our parent company, for provision of services functional to the purposes above indicated, notably The Renewal Workshop Inc., a Delaware B Corporation, having its registered office and a place of business at 180 NE Herman Creek Lane Suite 172 Cascade Locks, OR 97014 USA, listed in the US trade register under number 81-0906386. We may also transfer your Personal Information to sub-processors located in the following countries: Canada, Australia, Israel, Latvia and Switzerland. The European Commission has recognised that Canada, Israel and Switzerland provide an adequate level of protection for data (see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en#:~:text=The%20European%20Commission%20has%20so,Uruguay%20as%20providing%20adequate%20protection.). In relation to the other third countries which do not guarantee the same level of data protection as set forth by the GDPR, the relevant data transfers will be made always in accordance with the GDPR requirements and they will be generally based on the then current version of the Standard Contractual Clauses as drafted by the European Commission and supplemented by additional technical/organisational/contractual measures, as necessary; other available mechanisms for a legitimate data transfers may be considered from time to time. The updated list of third countries where we can transfer your Personal Information. For any further information on data transfers to third countries and to ask for the updated list of third countries where your Personal Information may be transferred, please contact us as below indicated.

These external parties will process your Personal Data as independent data controllers or as data processors, regularly appointed by TRW in accordance with the legislation regulating data protection (depending on the role they have in relation to the processing).

Your Choices:

You can visit the Website without providing any Personal Information. However, if you choose not to provide any Personal Information, you may not be able to use certain portion of the Website and to use some of functionalities and services offered.

Children:

The Website is not intended to be used or accessed by children who are under the age of 13. TRW does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website. If you have reason to believe that a child under the age of 13 has provided Personal Information to TRW through the Service, please contact us, and we will endeavor to delete that information and take appropriate action.

Links to Third-Party Websites

This Privacy Policy applies only to the Website. The Website may contain links to other websites or services not operated or controlled by TRW. The policies, practices, and procedures described in this Privacy Policy do not apply to third-party websites or services. Any links from the Website to third-party websites or services do not imply that TRW endorses or has reviewed those sites or services. We suggest that you contact those sites or services directly for information on their data practices and privacy policies.

Cookies and other tracking technologies:

For more information about cookies and other tracking technologies, please see our Cookie Policy.


Do Not Track Signals: The Website do not respond to “Do Not Track” (DNT) signals and operate as described in this privacy policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this privacy policy.

Rights of the data subject

You may at any time exercise the rights acknowledged by the Privacy Legislation with regard to the specific processing of Customer Data.

Below is a general description of them and how to exercise them:

  • right of access to your personal data: you can obtain confirmation that your personal data is or is not being processed and, consequently, obtain access to your personal data and information about its processing. If you wish, you will be provided with a copy of your personal data;
  • right to rectification of your personal data: you can obtain the correction, modification or updating of any inaccurate or out-of-date information, as well as obtaining the supplementation of incomplete personal data, including by providing an additional statement;
  • right to withdraw your consent: you may at any time withdraw your consent to the processing of your personal data in connection with any activity for marketing purposes, including profiling. In this regard, please note that sending commercial and promotional communications, carrying out market research and surveys to measure satisfaction and tailoring commercial offers to your interests are considered marketing activities. On receipt of your request, the processing of your personal data based on such consent will cease, while different processing operations or processing based on other grounds will continue to be carried out in full compliance with applicable laws;
  • right to the deletion of your personal data (right to be forgotten) when your personal data, in particular, (i) is no longer necessary for the purposes for which it was collected or processed, or (ii) has been processed unlawfully, or (iii) must be deleted in order to comply with a legal obligation, or, lastly, (iv) you have objected to its processing (see "right of objection" below) and there is no overriding legitimate reason that would allow TRW to process your personal data in any way. Once we have received and reviewed your request, if it is lawful, your personal data will be deleted;
  • right to limit the processing of your personal data: you may request that the processing of your data be limited, i.e. that your personal data be stored but not used (with the exception of your requests and exceptions provided for by law):
    • when you challenge the accuracy of your personal data for the period necessary for TRW to verify the accuracy of such data;
    • when the processing is unlawful, but you object to the deletion of your data;
    • when, although your data is no longer needed by TRW for processing purposes, you need it to ascertain, exercise or defend your rights in legal proceedings;
    • when you object to the processing, pending verification of whether TRW have legitimate grounds to continue processing the data;
  • right to data portability: you may request to receive data that is processed based on your consent or on a contract entered into with you, in a structured format and readable by an automated device. If you wish, where this is not excessive and technically possible, we may, at your request, transfer your data directly to a third party indicated by you.
  • right of objection: you may at any time object to the processing of your personal data carried out based on a legitimate interest, explaining the reasons supporting your request. Unless there are reasons to prevent acceptance of the same as provided by law, we will cease the processing to which you have objected. You have the right to object at any time to the processing of your data for marketing and/or profiling purposes, as long as it is related to that purpose, without the need to specify the reason for your objection. In this case, the processing of your data will cease immediately;
  • right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

You have the right at any time to revoke your consent, if given, and to lodge a complaint to the competent Data Protection Authority. The contact details of your local Data Protection Authority can be found here

https://edpb.europa.eu/about-edpb/board/members_en.

To exercise the rights described above, to obtain the updated list of its external data processors, of the third parties with whom Customer Data is shared ad for information on data transfers::

The North Face Renewed Customer Service
Distelweg 78A Amsterdam, NL 1031HH

Other Terms and Conditions:

Your access to and use of the Website is subject to the Terms of Use, located at www.renewalworkshop.com/en/general/terms and https://www.thenorthfacerenewed.com/pages/terms-of-use, respectively.

Changes to Our Privacy Policy:

The Website and our business may change from time to time. As a result, TRW may change or modify this Privacy Policy at any time without prior notice. Please review this Privacy Policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your consent to TRW data practices as described in such revised Privacy Policy.