Last Updated: March 15, 2022

Introduction

Please read this Privacy Policy carefully so that you can understand how we treat and process your personal information. By using this website, you acknowledge and agree to be bound by the terms of this policy. If you do not agree to this policy, do not access or use this website.

Scholl's Wellness Co. ("Scholls" or "we" or "us" or "our") is an American footwear and orthopedic foot care company founded in 1906 by Dr. William Mathias Scholl under the brand name, Dr. Scholl's RR. Scholls maintains the website "drscholls.com", all associated sub-domains, stand-alone and/or self-serve sites for kiosks and apps, and various related social media sites at LinkedIn, Facebook, Twitter, Pinterest and others (collectively "the Sites"). The purpose of the Sites is to provide Scholl's visitors and customers ("customer(s)" or "user(s)" or "you" or "your") with electronic access related to its offerings.

Scholls reserves the right, in its sole discretion and without any obligation, to change the terms of this Privacy Policy at any time. You are responsible for regularly reviewing this Privacy Policy for any such changes. Continued use of the Sites, including after any such changes have been posted, shall constitute your agreement to such changes.

Collected Information

Information Automatically Collected

Use of the Sites causes servers to automatically gather and store certain information about your visit. This information may not identify you personally, except in situations where you have logged into the Sites using provided login credentials. This information may include, but is not limited to, your IP address, browser and computer metadata, mobile device metadata, geo-location information, domain names, access times and other navigational data (the pages which you visit within the Sites and referring website addresses, if applicable). This information may be used by Scholls for the operation of the Sites, to maintain quality of the Sites and to provide general statistics regarding use of the Sites.

Scholls may use cookies as a method of this information gathering and storage. Cookies are small files that your web browser places on your storage device for record-keeping purposes. Cookies may be used to track user trends and patterns, or to enhance your browsing experience by preventing you from having to re-enter your preferences on certain areas of the Sites when you have entered preference information before. You have the ability to accept or decline cookies at any time through your browser preference options, however, some functionality of the Sites may not work as intended with cookies disabled.

Information You Provide to Us

Any personal information provided either while on or through the Sites, through a Scholls function, in responding via email, completing a survey in connection with a feature provided on the Sites, subscribing to newsletters, members only live or on-demand videos and RSS feeds, or participating in message boards, forums, feedback forms, CME testing and/or chat rooms, will be used to respond to your message and to help us provide you with the information that you request. Scholls does not capture any such personal information without your knowledge or consent. This information may include, but is not limited to, demographics, first name, last name, address, telephone number(s), billing information and email address(es).

Any information which you choose to share through participation in message boards, forums and/or chat rooms (including Protected Health Information ("PHI") and Personally Identifiable Information ("PII")), is by design open to the public as these are public services not a private, secure service. Careful consideration should be used before disclosing any PHI or PII in any public forum. What you have written may be seen, disclosed to or collected by third parties and may be used by others.

Information Collected by Third Parties Not Acting on Scholls' Behalf

The inclusion of a link on the Sites does not imply endorsement of the linked site or service by us. Sponsors or advertisers on Scholls may use their own cookies, web beacons or other online tracking technologies in the banner advertisements served on Scholls and in emails, special promotions or newsletters we send you. Some advertisers use companies other than Scholls to serve their ads and to monitor users' responses to ads, and these companies ("Ad Servers") may also collect information through the use of cookies or web beacons on the Sites. In certain situations, information collection may be facilitated by momentarily directing your browser to the web site of an Ad Server or other third party acting on behalf of the sponsor, partner, or advertiser before re-directing your browser to its selected destination (e.g., back to Scholls to show the ad, or to the advertiser's website); this re-direction process will not be apparent to you. Certain Ad Servers allow you to prevent them from collecting data through the use of cookies. In order to do so, you must opt-out of such data collection with each individual site. Currently, you can ppt-out of cookies for several Ad Servers by visiting the Network Advertising Initiative gateway opt-out site. This website will also allow you to review the Ad Server's privacy policies.

Scholls Use of Cookies

We use cookies for two main purposes: (1) cookies to facilitate technical aspects or special features on the Sites, without which the functionality of the Sites would be reduced, and (2) cookies for analytics and marketing purposes. Technical cookies aid site functionality and facilitate navigation and settings, including anonymous identification of a session (website visit), language preferences, mobile or desktop site version settings, or shopping cart sessions. The lifespan of these cookies range from deletion at the end of a browser session to up to 60 days for preference settings, and some cookies may persist for up to one year, or longer.

The data collected via a cookie may be used to gather statistical information or technical information like day and time of your visit as well as device type or browser used to access the Sites. We also collect basic user information like pages visited and user preferences that can be used to improve future web experiences when you return to one of the Sites. The preference data we collect could include information like region, language or user name to be able to provide you a more personalized experience and deliver content more relevant to your interests. While we do leverage the information we collect in aggregate to deliver more relevant advertisements and offers to you on other third party websites as you navigate the Internet, we do not share your personal data with any third party vendor or website owner for their own marketing purposes. We may also include a cookie on promotional offers/communications (email) to be able to measure performance and deliver more relevant offers/content based on preferences.

Analytics and Marketing

Through the use of cookies and other technologies described above, we, and our third party service providers on our behalf, may analyze how you use the Sites to develop insights to optimize use and improve personalized experiences, communications and marketing. Our analytics, for marketing and other purposes, is based on technical or other anonymous or aggregate information. You may delete or opt-out of this anonymous tracking and analysis at any time by altering your cookie settings and/or deleting cookies. More information on these opt-outs is provided below.

We may also use personal data for analytics and marketing purposes, including analyzing your use of the Sites and your activity on other websites, including coupon redemption, with your express consent. If you chose to create an account on the Sites, you may elect to participate in certain analytics, communications and marketing programs, including coupon programs and other special offers. If you opt-in, we may collect such personal data from you as demographic, contact and preference information from your account profile, as well as from your interactions on the site, such as through quiz responses or other interactive features. This information could include PII such as name, address, email or other data that could be used to identify you as an individual. We may also enhance or merge this data with the cookie data we collect or possibly merge data from third parties to create a more complete profile for a more customized user experience. This information would be stored in a secure database within the Scholls environment and would not be shared with any third party without your prior consent. You may control your preferences directly on your account and revoke consent to future participation in these analytics or marketing programs at any time.

Google Analytics

The Sites use third party service providers, including Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States ("Google").

Scholls and its service providers will analyze your use of the Sites. To this purpose, we use, among others, the Cookies described in above. The information collected within the Google Analytics platform in connection with your use of the Sites (e.g. the referring URL, which of our webpages you visit, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the U.S., where it will be stored and analyzed; the respective results will then be made available to us in an anonymized form. In this process, your usage data will not be connected to your full IP address. We have activated on our website the IP anonymizing function offered by Google, so that the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address are deleted.

You may withdraw your consent to the use of web analysis at any time either by downloading and installing a Browser Plugin offered by Google or by configuring your browser to delete and reject cookies. Both options will prevent the use of web analysis only if you use the browser on which you installed the plugin.

For further information on Google Analytics please refer to the Google Analytics Terms of Service, the Google Analytics security and privacy principles, and the Google Privacy Policy.

Text Message Marketing Communications

From time to time, Scholls may engage in text message marketing campaigns, such as for text-based coupons or promotional materials. Scholls shall only send you text messages with your prior express consent at the phone number that you have provided to participate in the text message marketing campaign. You may opt-out of ongoing or subscription texts at any time by responding to the opt-out instructions in such texts. Please note that if you opt-out of future text messages, this opt-out list is separate from our email preferences and opt-out lists.

Information Collected by Third Party Content Providers

Certain information may be collected by third party content providers that utilize the Scholls platform. By choosing to opt-in, subscribe, submit or otherwise transmit or grant permission to transmit information to these third-party content providers you agree that this will result in the transfer of PII from Scholls and/or oneself to the third party content provider. Any information sent in this way is subject to the terms and conditions of the privacy policy of the third party content provider. Scholls is not responsible for information transferred in this manner.

How the Information is Used

Scholls uses the information collected from you to provide the Sites, respond to you regarding the reason you contacted us and to provide, maintain, protect and improve our products and services, to develop new ones and to protect Scholls, its affiliates, partners, visitors and customers. We may also use this information to offer you tailored content.

When you contact Scholls, we may keep a record of your communication to help solve any issues you might be facing. We may use your email address or other contact information to keep you informed about our services, such as letting you know about upcoming products, services, changes or improvements.

When you opt-in to receive recurring informational or promotional information via email the information you provided during that opt-in, such as your name and email address, Scholls may use that information to send you information.

We may use information collected from cookies and other technologies to improve your user experience and the overall quality of our products and services.

Scholls cannot control and is not responsible for any use of the information you have written or submitted.

Except as otherwise provided in this Privacy Policy, any information you submit will not be shared with, disclosed or distributed to third-parties, except where necessary to fulfill the underlying or associated services, improve the user experience, introduce and/or market new or existing products or services, or where required to do so by law. Otherwise, Scholls will only use that personal information within its organization to respond to your specific request or email, to inform you of various programs, activities or services and to fulfill service-related functions. Scholls will store this personal information in its secure database and will take industry-appropriate measures to safeguard this information against unauthorized disclosure or use.

Access and Correction

To keep your PII accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update, remove or correct PII in our possession that you have previously submitted via the Sites.

Notice to International Users

Scholls processes PII on servers located in the United States ("US").

If you are a non-US user of the Sites, know that utilizing features of the Sites and providing Scholls with personal data, you acknowledge and agree that your personal data may be processed for the purposes identified in this Privacy Policy. In addition, your personal data may be processed in the country in which it was collected and in other countries, including the US, where laws regarding processing of personal data may be less stringent than or otherwise differ from the laws of the country in which you reside or are located when using our services. By providing your personal data, you consent to such transfers.

Children's Privacy

The Sites provided by Scholls are not directed at children under the age of 13. We operate the Sites in compliance with the Children's Online Privacy Protection Act ("COPPA") and will not knowingly collect personally identifiable information from anyone under 13. However, we will accept, store and use data on minors as part of the contact information that is required in order to provide the underlying or associated services. You consent to the use of your minor children's information when you input the information into our system. However, we may request the parent's consent in any way the law allows. For example, if the child's personal information will be used only by us, we may also ask for the parent's consent by email. If the child's personal information will be shared with a third-party, we may verify that the person providing consent is the parent by asking for proof of the relationship. Parents have the option to consent to the collection and use of their children's information without consenting to the disclosure of that information to third-parties, except to the extent that disclosure of such information is a necessary part of the activity for which parental consent is given.

Opt-Out Policy

You have the option to opt out of being contacted by or receiving non-transactional information from Scholls, its sponsors, affiliates and/or partners, and the option to choose how Scholls uses your personal information. You may, at any time, also review, update and correct your personal information. If you wish to exercise these options please send an email with your request to drscholls.care@drscholls.com.

Exceptions

Scholls' obligations under this Privacy Policy do not apply to any information or data that:

• was known to Scholls prior to its gaining access to the information or data;
• is or becomes entirely in the public domain;
• is not uniquely identifiable as yours (i.e., PII);
• received lawfully from a third-party through no breach of any obligation of confidentiality owed to you; and/or
• created by Scholls independently of its access to, or use of, your personal information.

Security

Scholls has put in place written Information Technology Policies and Procedures in accordance with industry best practices to safeguard and help prevent unauthorized access to data, to maintain data security and ensure correct use of the information we collect online. However, as no Internet transmission can be guaranteed to be 100% secure or error-free, caution should be observed with regard to what information is transmitted to us, especially via insecure e-mail. Additionally, where passwords, ID numbers, or other special access features are used on this site, it is your responsibility to safeguard and secure that information against loss, theft, or unintentional use.

Links to Other Websites

The Sites provided by Scholls may include links to other websites. The inclusion of a link on the Sites does not imply endorsement of the linked site, service or product. When following one of these links, once you leave the Sites, you are subject to the privacy policy of the new website.

California Privacy Rights

Under the California Consumer Privacy Act ("CCPA"), California residents have a right to request that we disclose the categories of personal information we have collected, used, disclosed, and sold. We call this a "categories" request. California residents also have the right to request that we disclose the specific pieces of personal information that we have collected about you, which we call a "specific pieces" request. These are referred to collectively as "Right to Know" requests under the CCPA.

California residents also have a right to delete the personal information we've collected about them. The "Right to Delete" is subject to several legal exceptions, such as when we are required by another state or federal law to retain your information.

The CCPA provides California residents with the right to opt-out of the sale of their personal information. The CCPA defines a "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration.

While we do not sell personal information for monetary value, we may disclose personal information to third parties, as described elsewhere in this Notice, and that disclosure may be considered a "sale" of personal information under the CCPA. To direct us to stop the sale of your personal information if you are a California resident, click Do Not Sell My Info to submit your request, or email us at drscholls.care@drscholls.com .

We do not sell personal information of minors who we know are under 16 years of age.

California residents have a right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To protect against fraud, identity theft, and the unauthorized disclosure or deletion of personal information, we require that California residents submitting requests under the CCPA first verify their identity. This may include a combination of SMS (text message) verification, email verification, and one or more questions regarding the California resident's particular interaction or transaction with our Services. If the California residents fails to verify their request via these methods, or the information provided by the California residents otherwise does not match our existing records, we will deny the request.

Authorized Agent

A California resident may designate an authorized agent to make a request under the CCPA on the California resident's behalf. If a California resident wishes to authorize another person to act as an authorized agent on the California resident's behalf, the California resident must provide the authorized agent permission to do so. To help prevent fraudulent requests, we reserve the right to deny a request from an agent that does not submit proof that he or she has been authorized by the California resident to act on the resident's behalf.

As proof that the agent has been duly authorized by the California resident to submit a CCPA request, the agent will be required to upload either (1) power of attorney signed by the California resident, or (2) other signed permission from the California resident. Pursuant to California Probate Code Sections 4300 to 4310, if an agent provides a power of attorney signed by the California resident ("principal") that purports to give the agent authorization to submit the request on the principal's behalf, we may require that the agent provide information reasonably necessary or appropriate to identify the agent and principal and to facilitate the request. This includes, but is not limited to, identification of the agent and principal and the current and permanent residence addresses of the principal. If the agent provides some other signed permission from the California resident, we may require that the resident (1) verify his/her identity directly with us through a combination of SMS (text message) verification, email verification, and one or more questions regarding the resident's particular interaction or transaction with our dealership and (2) confirm that he or she provided the authorized agent permission to submit the request.

Nevada Privacy Rights

Pursuant to Nevada Revised Statutes Sections 603A.300-360 we are required to disclose to Nevada residents information related to the sale of personal information. We do not sell customer information as covered by the above statute. A Nevada resident may submit a request for his/her information not to be sold by submitting a request to drscholls.care@drscholls.com.

Right of Access and Correction

You have the right to review and amend any personal data in your account profile and, where applicable, personal account preferences, stored in our system if you believe it may be out of date or incorrect. Please contact Scholls via the information provided in this Privacy Policy, or where applicable, log in to your account to update your information and/or preferences.

Right of Cancellation

You have the right at any time to withdraw your consent to the use of your personal data in the future. Again, just send an e-mail to the address given in the imprint or contact Scholls via the information provided in this Privacy Policy. Where applicable, you may also log in to your account to update your preferences, which may include revoking consent to certain communication outreach and marketing uses.

Data Retention

We retain personal data for as long as necessary consistent with the purposes of use and in a manner consistent with our records management policies or as otherwise required by law (e.g., in connection with pending litigation).

Contacting Scholls

If you and/or any resident of California has any questions or comments about this Privacy Policy, please contact us using the below referenced contact information or: drscholls.care@drscholls.com

Scholl's Wellness Co.
Consumer Affairs
138 E. Main St.
Suite 201
Kent, OH 44240
Email: drscholls.care@drscholls.com
Phone: 866-360-3226 Monday through Friday 9AM-5PM Central Standard Time.