CCPA Privacy Policy for California Consumers





This Privacy Policy for California Residents (“CCPA Privacy Policy”) supplements and incorporates the information contained in Clarks’ Privacy Policy (available at clarksusa.com/privacy-policy) and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.


How to Contact Us
We have a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any comments, questions or requests in relation to this notice or how we handle your personal information, or would like to exercise your rights under the CCPA, please email us at: privacy@clarks.com or call Customer Service at 1-800-211-5461. If you would like to make a “Do Not Sell My Info” request, as discussed below, you may do so via the link on our homepage (available at www.clarksusa.com/consumer-privacy-act) or click here.


Personal Information We Collect and Use
Our business, including our brick and mortar stores, our website at www.clarksusa.com (“website”) and our Customer Service department, collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).

We have collected the following categories of personal information from our consumers within the last twelve (12) months:

Category of Personal Information: Name and contact details (such as email address, telephone number and postal address)
Purpose for Collection & Use:
  • Deliver your purchase to you
  • Send you emails or call you with order updates
  • Provide you information by email, mail or phone about our products or services
  • Assist with Customer Service inquiries
  • Fraud prevention and detection
  • To register you for a Clarks account
  • To register you for the Clarks in-store Rewards Program
  • Make decisions about what Clarks ads are shown to you, as you browse the web or apps,
  • Make decisions about what Clarks ads are sent to you via email or mail

Category of Personal Information: Purchase information/history
Purpose for Collection & Use:
  • Maintain records of your purchases with us
  • Deliver your purchase to you
  • Allow you to return a prior purchase
  • Assist with Customer Service inquiries
  • Send you transactional emails such as order updates and shipment confirmations
  • Send you information by email, mail, or phone about our products or services
  • Fraud prevention and detection
  • Make decisions about what Clarks ads are shown to you as you browse the web or apps
  • Assist with Customer Service inquiries
  • Accrue in-store Rewards Points

Category of Personal Information: Date of birth information & gender preferences
Purpose for Collection & Use:
  • Fraud prevention and detection
  • To send you treats on your birthday
  • To conduct market research
  • Send you information by email or mail about our products or services
  • Make decisions about what Clarks ads are shown to you as you browse the web or apps, or are sent to you via email or mail

Category of Personal Information: Online payment information
Purpose for Collection & Use:
  • Take payment and give refunds
  • Fraud prevention and detection
  • Note: to facilitate future transactions online, we retain your name, the last 4 digits on your card and expiration date on your credit card

Category of Personal Information: In-store payment information
Purpose for Collection & Use:
  • Take payment and give refunds
  • Fraud prevention and detection
  • Note: we retain only masked credit card numbers

Category of Personal Information: Contact history with Clarks, e.g. over the phone, mail, email, chat, or on social media
Purpose for Collection & Use:
  • Provide customer service and support
  • Train our staff
  • Make decisions about what Clarks ads are shown to you, or sent to you via email or mail

Category of Personal Information: Information you provide when entering a sweepstakes or contest, playing games and completing surveys (including contact details and your actual entry)
Purpose for Collection & Use: To facilitate your participation in the sweepstakes or contest

Category of Personal Information: Device information; internet information or other similar network activity including cookies; information about your computer, phone or other device you use to view the website such as device type, operating system, hardware version, browser type, unique device identifier, IP and MAC address and advertising ID; log information; information about how you use our website, such as the types of content you view or engage with, the frequency and duration of your activities, access times, language, click stream data, your IP address and pages you visit before or after navigating away from the website. Note: Device and log information will not be associated with you as a named individual unless you are logged into your account

Purpose for Collection & Use:
  • Improve our website and set default options for you (such as language and currency)
  • Make decisions about what Clarks ads are shown to you, or are sent to you via email or mail
  • Fraud prevention and detection
  • Make sure the website display and function correctly on your device (e.g. make sure pages load correctly on your device and that the displayed language and currency are correct for the country you are in)
  • Provide us with analytical information about the use of the website
  • Make the website secure
  • Make decisions about the pages, images and ads to display to you on our website
  • Make decisions about the ads you see on websites and apps that are not owned by Clarks
  • Associate different devices you use with each other so that the pages, images and offers you see across devices are consistent

Category of Personal Information: Geolocation data from web beacons in store capturing MAC address. Note: Device information will not be associated with you and is not used for marketing purposes
Purpose for Collection & Use: Track anonymous foot traffic in store

Personal information does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Clarks obtains the categories of personal information listed above either directly from you, for example through our website, in person in store, over the telephone, or in an email, or indirectly from you, for example by observing your actions on our website.


Who We Share Your Personal Information With
In the preceding twelve (12) months, we have disclosed your personal information for a business purpose with the following categories of companies as part of being able to provide our services to you:

  • Members of the Clarks group of companies, where they assist us in providing our services to you
  • Companies that help us get your order to you, such as payment service providers, warehouses operators and delivery companies
  • Marketing service providers, such as marketing agencies and advertising partners who help us market our business, serve you personalized ads, and tailor marketing messages to you
  • Companies that assist us in administration of sweepstakes and contests
  • Technology service providers, such as companies that support our IT function, help us analyze and store the data we hold, send communications to our customers and help us develop and host our website
  • Professional advisors, such as companies that provide us with legal or financial advice
  • Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud and other unlawful activities
  • Companies approved by you, such as social media sites
The categories of personal information that we have shared with third parties for a business purpose in the preceding twelve (12) months include:
  • name
  • address
  • phone number
  • email
  • masked credit card information
  • gender
  • birth date
  • purchase history
  • cookies, including your device detail and IP and MAC address


“Do Not Sell” Rights & Requests
The CCPA provides California residents with specific rights regarding their personal information. First, you have the right to opt out of the sale of your personal information to third parties.

Importantly, please note that Clarks does not sell your personal information for monetary consideration to third parties. We do, however, work with third parties with whom we share or disclose your personal information, and under the CCPA, “sell” may mean “share” under certain conditions when the third-party supplier receives valuable consideration from such sharing, even if not monetary. This is why you see us using the language “Do Not Sell My Info” on our homepage. This language is required by the CCPA.

If you do not wish to have your personal information shared with third parties who receive value out of your personal information and utilize it for purposes unrelated to our business, please click the “Do Not Sell My Info” link on our homepage (available at www.clarksusa.com/consumer-privacy-act) or click here to complete the Do Not Sell request form, or call Customer Service at 1-800-211-5461 (“Do Not Sell Request”). We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.


Access & Deletion Rights & Requests
The CCPA also provides you with certain access and deletion rights. You have the right to request that Clarks disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (“Access Request”). Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The personal information we collected about you.
  • Our business purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
You also have the right to request that Clarks delete any of your personal information that we collected from you and retained, subject to certain exceptions (“Deletion Request”). Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Please note that with respect to cookies, you are responsible to delete the cookie from your browser history and settings after each visit to our Site. If you do not take that step, the cookie will continue to serve you Clarks advertisements.


We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either emailing us at privacy@clarks.com, or calling Customer Service at 1-800-211-5461. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.


Making a Verifiable Consumer Request
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.


Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.


Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.


Children 16 and Under
Clarks does not knowingly collect, solicit, or share personal information from children under the age of 16. If we obtain knowledge that a child under 16 has submitted personal information in violation of this policy, we will delete that information as soon as possible. If you believe Clarks may have obtained information in violation of this policy, please email us at privacy@clarks.com, or call Customer Service at 1-800-211-5461.


Changes to This Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.