This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information under this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under these conditions. These definitions shall have the same meaning whether or not they appear in singular or in plural.

Definitions

FOR THIS PRIVACY POLICY:

Account means a uniqueaccount created for You to access our Service or parts of our Service.

Business, for the CCPA(California Consumer Privacy Act), calls the Company the legal entity that collects Consumers` personal information and determines the purposes and means of the processing of Consumers` personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers` personal information, that does business in the State of California.

Company “the Company“, “We“, “Us“ or “Our“ in this Agreement) refers to FootDirectClub, LLC., 1805Riverway Drive, Pekin, IL 61554.

For the GDPR, theCompany is the Data Controller.

Consumer, for the CCPA(California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

Cookies are small files placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Data Controller, for the GDPR (General Data Protection Regulation), calls the Company the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Do Not Track (DNT) is a concept promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Facebook Fan Page is a public profile named FootDirectClub Facebook Page specifically created by the Company on the Facebook social network, accessible fromhttps://www.facebook.com/FootDirectClub

Personal Data is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the CCPA, Personal Data means any information that identifies, relates to, describes or can be associated with, or could reasonably be linked, directly or indirectly, with You.

Sale, for the CCPA(California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer`s personal information to another business or a third party for monetary or other valuable  consideration.

Service refers to the Website.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the GDPR, Service Providers are considered Data Processors.

Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data refers to data collected automatically, either generated by the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website refers to FootDirectClub, accessible from www.footdirectclub.com

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service.

Under GDPR (GeneralData Protection Regulation), You can be called the Data Subject or as the Useras you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

PERSONAL DATA

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can contact or identify You. Personally identifiable information may include, but is not limited to:

·  Email address

·  First name and last name

·  Phone number

·  Address, State, Province, ZIP/Postal code,City

·  Usage Data

USAGE DATA

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device`s Internet Protocol address (e.g. IP address),browser type, browser version, the pages of our Service You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company may allow You to create an account and log in to use the Service through the following Third-party Social Media Services:

·  Google

·  Facebook

·  Twitter

If You register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data already associated with Your Third-Party Social Media Service`s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service`s account. If You provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

·  Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not use parts of our Service. Unless you have adjusted Your browser setting so it will refuse Cookies, our Service may use Cookies.

·  Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for BrowserCookies. For more information on how You can delete Flash Cookies, please read“Where can I change the settings for disabling, or deleting local sharedobjects?” available athttps://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

·  Web Beacons. Certain sections of our Serviceand our emails may contain small electronic files known as web beacons (alsocalled clear gifs, pixel tags, and single-pixel gifs) that permit the Company,for example, to count users who have visited those pages or opened an email andfor other related website statistics (for example, recording the popularity ofa certain section and verifying system and server integrity).

Cookies can be“Persistent” or “Session” Cookies. Persistent Cookies remain on Your personalcomputer or mobile device when You go offline, while Session Cookies aredeleted as soon as You close Your web browser.

We use both Session and Persistent Cookies forthe purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookiesare essential to provide You with services available through the Website and toenable You to use some of its features. They help to authenticate users andprevent fraudulent use of user accounts. Without these Cookies, the servicesYou have asked for cannot be provided, and We only use these Cookies to provideYou with those services.

Cookies Policy / Notice Acceptance Cookies

Type: PersistentCookies

Administered by: Us

Purpose: These Cookiesidentify if users have accepted the use of cookies on the Website.

Functionality Cookies

Type: PersistentCookies

Administered by: Us

Purpose: These Cookiesallow us to remember choices You make when You use the Website, such asremembering your login details, language preference, or tracking cart activity.The purpose of these Cookies is to provide You with a more personal experienceand to avoid You having to re-enter your preferences or add items to your cartevery time You use the Website. The Website uses cookies to help keep track ofitems you put into your shopping cart including when you have abandoned yourcart and this information is used to determine when to send cart remindermessages via SMS.

TRACKING AND PERFORMANCE COOKIES

Type: PersistentCookies

Administered by:Third-Parties

Purpose: These Cookiesare used to track information about traffic to the Website and how users usethe Website. The information gathered via these Cookies may directly orindirectly identify you as an individual visitor. This is because theinformation collected is typically linked to a pseudonymous identifierassociated with the device you use to access the Website. We may also use theseCookies to test new pages, features or new functionality of the Website to seehow our users react to them.

For more informationabout the cookies we use and your choices regarding cookies, please visit ourCookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for thesepurposes:

·  To provide and maintain our Service,including to monitor the usage of our Service.

·  To manage Your Account: to manage Yourregistration as a user of the Service. The Personal Data You provide can giveYou access to different functionalities of the Service available to You as aregistered user.

·  For the performance of a contract: the development,compliance and undertaking of the purchase contract for the products, items orservices You have purchased or of any other contract with Us through theService.

·  To contact You: To contact You by email,telephone calls, SMS, or other equivalent forms of electronic communication,such as a mobile application`s push notifications regarding updates orinformative communications related to the functionalities, products orcontracted services, including the security updates, when necessary or reasonablefor their implementation.

·  To provide You with news, special offers andgeneral information about other goods, services and events which we offersimilar to those that you have already purchased or enquired about unless Youhave opted not to receive such information.

·  To manage Your requests: To attend and manageYour requests to Us.

·  To deliver targeted advertising to You: Wemay use Your information to develop and display content and advertising (andwork with third-party vendors who do so) tailored to Your interests and/orlocation and to measure its effectiveness.

·  For business transfers: We may use Yourinformation to evaluate or conduct a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or all of Ourassets, whether as a going concern or as part of bankruptcy, liquidation, orsimilar proceeding, in which Personal Data held by Us about our Service usersis among the assets transferred.

·  For other purposes: We may use Yourinformation for other purposes, such as data analysis, identifying usagetrends, determining the effectiveness of our promotional campaigns and toevaluate and improve our Service, products, services, marketing and yourexperience.

We may share Your personal information inthese situations:

·  With Service Providers: We may share Yourpersonal information with Service Providers to monitor and analyze the use ofour Service, to advertise on third party websites to You after You visited ourService, for payment processing, to contact You.

·  For business transfers: We may share ortransfer Your personal information in connection with, or during negotiationsof, any merger, sale of Company assets, financing, or acquisition of all or aportion of Our business to another company.

·  With business partners: We may share Yourinformation with Our business partners to offer You certain products, servicesor promotions.

·  With Affiliates: We may share Yourinformation with Our affiliates, in which case we will require those affiliatesto honor this Privacy Policy. Affiliates include Our parent company and anyother subsidiaries, joint venture partners or other companies We control orthat are under common control with Us.

·  With other users: when You share personalinformation or otherwise interact in the public areas with other users, suchinformation may be viewed by all users and may be publicly distributed outside.If You interact with other users or register through a Third-Party Social MediaService, Your contacts on the Third-Party Social Media Service may see Yourname, profile, pictures and description of Your activity. Similarly, otherusers can view descriptions of Your activity, communicate with You and viewYour profile.

·  With Your consent: We may disclose Yourpersonal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company willretain Your Personal Data only for as long as is necessary for the purposes setout in this Privacy Policy. We will retain and use Your Personal Data to theextent necessary to comply with our legal obligations (for example, if we mustretain your data to comply with laws), resolve disputes, and enforce our legalagreements and policies.

The Company will alsoretain Usage Data for internal analysis purposes. Usage Data is generallyretained for a shorter period, unless this data is used to strengthen thesecurity or to improve the functionality of Our Service, or We are legallyobligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information,including Personal Data, is processed at the Company`s operating offices andwhere the parties involved in the processing are located. It means thisinformation may be transferred to — and maintained on — computers locatedoutside of Your state, province, country or other governmental jurisdictionwhere the data protection laws may differ than those from Your jurisdiction.

Your consent to thisPrivacy Policy followed by Your submission of such information represents Youragreement to that transfer.

The Company will takeall steps reasonably necessary to ensure that Your data is treated securely andunder this Privacy Policy and no transfer of Your Personal Data will take placeto an organization or a country unless adequate controls in place include thesecurity of Your data and other personal information.

Disclosure of YourPersonal Data

Business Transactions

If the Company isinvolved in a merger, acquisition or asset sale, Your Personal Data may betransferred. We will provide notice before Your Personal Data is transferredand becomes subject to a different Privacy Policy.

Law enforcement

Under certaincircumstances, the Company may have to disclose Your Personal Data if requiredto do so by law or in response to valid requests by public authorities (e.g. acourt or a government agency).

Other legal requirements

The Company maydisclose Your Personal Data in the good faith belief that such action isnecessary to:

·  Comply with a legal obligation

·  Protect and defend the rights or property ofthe Company

·  Prevent or investigate possible wrongdoingwith the Service

·  Protect the personal safety of Users of theService or the public

·  Protect against legal liability

Security of Your Personal Data

The security of YourPersonal Data is important to Us, but remember that no method of transmissionover the Internet, or method of electronic storage is 100% secure. While Westrive to use commercially acceptable means to protect Your Personal Data, Wecannot guarantee its absolute security.

Detailed Information on the Processing of YourPersonal Data

The Service ProvidersWe use may have access to Your Personal Data. These third-party vendorscollect, store, use, process and transfer information about Your activity onOur Service under their Privacy Policies.

Email Marketing

We may use YourPersonal Data to contact You with newsletters, marketing or promotionalmaterials and other information that may interest You. You may opt-out ofreceiving any, or all, of these communications from Us by following the unsubscribelink or instructions provided in any email We send or by contacting Us.

We may use EmailMarketing Service Providers to manage and send emails to You. We currently useKlaviyo for this purpose. Their Privacy Policy can be viewed athttps://www.klaviyo.com/legal/privacy-policy.

Payments

We may provide paidproducts and/or services within the Service. There, we may use third-partyservices for payment processing (e.g. payment processors).

We will not store orcollect Your payment card details. That information is provided directly to Ourthird-party payment processors whose use of Your personal information isgoverned by their Privacy Policy. These payment processors adhere to thestandards set by PCI-DSS as managed by the PCI Security Standards Council,which is a joint effort of brands like Visa, Mastercard, American Express andDiscover. PCI-DSS requirements help ensure the secure handling of paymentinformation.

We currently useStripe for this purpose. Their Privacy Policy can be viewed at: https://stripe.com/privacy

Behavioral Remarketing

The Company usesremarketing services to advertise to You after You accessed or visited ourService. We and Our third-party vendors use cookies and non-cookie technologiesto help Us recognize Your Device and understand how You use our Service so Wecan improve our Service to reflect Your interests and serve You advertisementslikely to interest You.

These third-partyvendors collect, store, use, process and transfer information about Youractivity on Our Service under their Privacy Policies and to enable Us to:

·  Measure and analyze traffic and browsingactivity on Our Service

·  Show advertisements for our products and/orservices to You on third-party websites or apps

·  Measure and analyze the performance of Ouradvertising campaigns

Some of thesethird-party vendors may use non-cookie technologies that may not be affected bybrowser settings that block cookies. Your browser may not permit You to blocksuch technologies. You may be able to use the following third-party tools todecline the collection and use of information to serve You interest-basedadvertising:

·  The NAI`s opt-out platform:http://www.networkadvertising.org/choices/

·  The EDAA`s opt-out platformhttp://www.youronlinechoices.com/

·  The DAA`s opt-out platform:http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of allpersonalized advertising by enabling privacy features on Your mobile devicesuch as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android).See Your mobile device Help system for more information.

We may shareinformation, such as hashed email addresses (if available) or other onlineidentifiers collected on Our Service with these third-party vendors. Thisallows Our third-party vendors to recognize and deliver You ads across devicesand browsers. To read more about the technologies used by these third-partyvendors and their cross-device capabilities please refer to the Privacy Policyof each vendor listed below.

THE THIRD-PARTY VENDORS WE USE ARE:

·  Google Ads (AdWords)

·  Google Ads (AdWords) remarketing service isprovided by Google Inc.

You can opt-out ofGoogle Analytics for Display Advertising and customise the Google DisplayNetwork ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommendsinstalling the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. GoogleAnalytics Opt-out Browser Add-on provides visitors with the ability to preventtheir data from being collected and used by Google Analytics.

For more informationon the privacy practices of Google, please visit the Google Privacy & Termsweb page: https://policies.google.com/privacy

Facebook

Facebook remarketingservice is provided by Facebook Inc.

You can learn moreabout interest-based advertising from Facebook by visiting this page:https://www.facebook.com/help/516147308587266

To opt-out fromFacebook`s interest-based ads, follow these instructions from Facebook:https://www.facebook.com/help/568137493302217

Facebook adheres tothe Self-Regulatory Principles for Online Behavioural Advertising establishedby the Digital Advertising Alliance. You can also opt-out from Facebook andother participating companies through the Digital Advertising Alliance in theUSA http://www.aboutads.info/choices/, the Digital Advertising Alliance ofCanada in Canada http://youradchoices.ca/ or the European Interactive DigitalAdvertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-outusing your mobile device settings.

For more informationon the privacy practices of Facebook, please visit Facebook`s Data Policy:https://www.facebook.com/privacy/explanation

Usage, Performance and Miscellaneous

We may use third-partyService Providers to better improve our Service.

INVISIBLE RECAPTCHA

We may use aninvisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.

The reCAPTCHA servicemay collect information from You and from Your Device for security.

The informationgathered by reCAPTCHA is held under the Privacy Policy of Google:https://www.google.com/intl/en/policies/privacy/

GOOGLE PLACES

Google Places returnsinformation about places using HTTP requests. It is operated by Google

Google Places servicemay collect information from You and from Your Device for security.

The informationgathered by Google Places is held under the Privacy Policy of Google:https://www.google.com/intl/en/policies/privacy/

GDPR PRIVACY

Legal Basis forProcessing Personal Data under GDPR

We may processPersonal Data under these conditions:

·  Consent: You have given Your consent forprocessing Personal Data for one or more specific purposes.

·  Performance of a contract: Provision ofPersonal Data is necessary for the performance of an agreement with You and/or forany pre-contractual obligations thereof.

·  Legal obligations: Processing Personal Datais necessary for compliance with a legal obligation to which the Company issubject.

·  Vital interests: Processing Personal Data isnecessary to protect Your vital interests or of another natural person.

·  Public interests: Processing Personal Data isrelated to a task carried out in the public interest or in exercising officialauthority vested in the Company.

·  Legitimate interests: Processing PersonalData is necessary for the legitimate interests pursued by the Company.

The Company willgladly help to clarify the specific legal basis that applies to the processing,and in particular whether the provision of Personal Data is a statutory orcontractual requirement, or a requirement to enter into a contract.

YOUR RIGHTS UNDER THE GDPR

The Company undertakesto respect the confidentiality of Your Personal Data and to guarantee You canexercise Your rights.

You have the rightunder this Privacy Policy, and by law if You are within the EU, to:

·  Request access to Your Personal Data. Theright to access, update or delete the information We have on You. Whenever madepossible, you can access, update or request deletion of Your Personal Datadirectly within Your account settings section. If you cannot perform theseactions yourself, please contact Us to assist You. This also enables You toreceive a copy of the Personal Data We hold about You.

·  Request correction of the Personal Data Wehold about You. You have the right to have any incomplete or inaccurateinformation We hold about You corrected.

·  Object to processing of Your Personal Data.This right exists where We are relying on a legitimate interest as the legalbasis for Our processing and there is something about Your particularsituation, which makes You want to object to our processing of Your PersonalData on this ground. You may also object where We are processing Your PersonalData for direct marketing purposes.

·  Request erasure of Your Personal Data. Youmay ask Us to delete or remove Personal Data when there is no good reason forUs to continue processing it.

·  Request the transfer of Your Personal Data.We will provide to You, or to a third-party You have chosen, Your Personal Datain a structured, commonly used, machine-readable format. This right onlyapplies to automated information which You initially provided consent for Us touse or where We used the information to perform a contract with You.

·  Withdraw Your consent. You have the right towithdraw Your consent on using your Personal Data. If You withdraw Yourconsent, We may not provide You with access to certain specific functionalitiesof the Service.

EXERCISING OF YOUR GDPR DATA PROTECTIONRIGHTS

You may exercise Yourrights of access, rectification, cancellation and opposition by contacting Us.We may ask You to verify Your identity before responding to such requests. IfYou make a request, We will try our best to respond to You soon.

You have the right tocomplain to a Data Protection Authority about Our collection and use of YourPersonal Data. For more information, if You are in the European Economic Area(EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

DATA CONTROLLER FOR THE FACEBOOK FANPAGE

The Company is theData Controller of Your Personal Data collected while using the Service. Asoperator of the Facebook Fan Page https://www.facebook.com/FootDirectClub theCompany and the operator of the social network Facebook are Joint Controllers.

The Company hasentered into agreements with Facebook that define the terms for the FacebookFan Page, among other things. These terms are mostly based on the FacebookTerms of Service: https://www.facebook.com/terms.php

Visit the FacebookPrivacy Policy https://www.facebook.com/policy.php for more information abouthow Facebook manages Personal data or contact Facebook online, or by mail:Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA94025, United States.

FACEBOOK INSIGHTS

We use the FacebookInsights function in connection with the operation of the Facebook Fan Page andbased on the GDPR, to obtain anonymized statistical data about Our users.

For this purpose,Facebook places a Cookie on the device of the user visiting Our Facebook FanPage. Each Cookie contains a unique identifier code and remains active for twoyears, unless it is deleted before the end of this period.

Facebook receives,records and processes the information stored in the Cookie, especially when theuser visits the Facebook services, services provided by other members of theFacebook Fan Page and services by other companies that use Facebook services.

For more informationon the privacy practices of Facebook, please visit Facebook Privacy Policyhere: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy noticesection for California residents supplements the information in Our PrivacyPolicy and it applies solely to all visitors, users, and others who reside inthe State of California.

Categories of Personal Information Collected

We collect informationthat identifies, relates to, describes, references, can be associated with, orcould reasonably be linked, directly or indirectly, with a particular Consumeror Device. The following is a list of categories of personal information whichwe may collect or may have been collected from California residents within thelast twelve (12) months.

The categories andexamples provided in the list below are those defined in the CCPA. This doesnot mean that all examples of that category of personal information were infact collected by Us, but reflects our good faith belief to the best of ourknowledge that some of that information from the applicable category may be andmay have been collected. For example, certain categories of personalinformation would be collected only if You provided such personal informationdirectly to Us.

CATEGORY A: IDENTIFIERS.

Examples: A real name,alias, postal address, unique personal identifier, online identifier, InternetProtocol address, email address, account name, driver`s license number,passport number, or other similar identifiers.

Collected: Yes.

CATEGORY B: PERSONAL INFORMATIONCATEGORIES IN THE CALIFORNIA CUSTOMER RECORDS STATUTE (CAL. CIV. CODE §1798.80(E)).

Examples: A name,signature, Social Security number, physical characteristics or description,address, telephone number, passport number, driver`s license or stateidentification card number, insurance policy number, education, employment,employment history, bank account number, credit card number, debit card number,or any other financial information, medical information, or health insuranceinformation. Some personal information in this category may overlap with othercategories.

Collected: Yes.

CATEGORY C: PROTECTED CLASSIFICATIONCHARACTERISTICS UNDER CALIFORNIA OR FEDERAL LAW.

Examples: Age (40years or older), race, color, ancestry, national origin, citizenship, religionor creed, marital status, medical condition, physical or mental disability, sex(including gender, gender identity, gender expression, pregnancy or childbirthand related medical conditions), sexual orientation, veteran or militarystatus, genetic information (including familial genetic information).

Collected: No.

CATEGORY D: COMMERCIAL INFORMATION.

Examples: Records andhistory of products or services purchased or considered.

Collected: Yes.

CATEGORY E: BIOMETRIC INFORMATION.

Examples: Genetic,physiological, behavioral, and biological characteristics, or activity patternsused to extract a template or other identifier or identifying information, suchas, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke,gait, or other physical patterns, and sleep, health, or exercise data.

Collected: Yes.

CATEGORY F: INTERNET OR OTHER SIMILARNETWORK ACTIVITY.

Examples: Interactionwith our Service or advertisement.

Collected: Yes.

CATEGORY G: GEOLOCATION DATA.

Examples: Approximatephysical location.

Collected: Yes.

CATEGORY H: SENSORY DATA.

Examples: Audio,electronic, visual, thermal, olfactory, or similar information.

Collected: No.

CATEGORY I: PROFESSIONAL OREMPLOYMENT-RELATED INFORMATION.

Examples: Current orpast job history or performance evaluations.

Collected: No.

CATEGORY J: NON-PUBLIC EDUCATIONINFORMATION (PER THE FAMILY EDUCATIONAL RIGHTS AND PRIVACY ACT (20 U.S.C.SECTION 1232G, 34 C.F.R. PART 99)).

Examples: Educationrecords directly related to a student maintained by an educational institutionor party acting on its behalf, such as grades, transcripts, class lists,student schedules, student identification codes, student financial information,or student disciplinary records.

Collected: No.

CATEGORY K: INFERENCES DRAWN FROM OTHERPERSONAL INFORMATION.

Examples: Profilereflecting a person`s preferences, characteristics, psychological trends,predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes.

Under CCPA, personal information does notinclude:

·  Publicly available information fromgovernment records

·  Deidentified or aggregated consumerinformation

·  Information excluded from the CCPA`s scope,such as:

·  Health or medical information covered by theHealth Insurance Portability and Accountability Act of 1996 (HIPAA) and theCalifornia Confidentiality of Medical Information Act (CMIA) or clinical trialdata

·  Personal Information covered by certainsector-specific privacy laws, including the Fair Credit Reporting Act (FRCA),the Gramm-Leach-Bliley Act (GLBA) or California Financial Information PrivacyAct (FIPA), and the Driver`s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categoriesof personal information listed above from these categories of sources:

·  Directly from You. For example, from theforms You complete on our Service, preferences You express or provide throughour Service, or from Your purchases on our Service.

·  Indirectly from You. For example, fromobserving Your activity on our Service.

·  Automatically from You. For example, throughcookies We or our Service Providers set on Your Device as You navigate throughour Service.

·  From Service Providers. For example,third-party vendors to monitor and analyze the use of our Service, third-partyvendors to deliver targeted advertising to You, third-party vendors for paymentprocessing, or other third-party vendors We use to provide the Service to You.

Use of Personal Information for BusinessPurposes or Commercial Purposes

We may use or disclosepersonal information We collect for “business purposes” or “commercialpurposes” (as defined under the CCPA), which may include these examples:

·  To operate our Service and provide You withour Service.

·  To provide You with support and to respond toYour inquiries, including to investigate and address Your concerns and monitorand improve our Service.

·  To fulfill or meet the reason You providedthe information. For example, if You share Your contact information to askabout our Service, We will use that personal information to respond to Yourinquiry. If You personally inform purchase a product or service, We will usethat information to process Your payment and facilitate delivery.

·  To respond to law enforcement requests and asrequired by law, court order, or governmental regulations.

·  As described to You when collecting Yourpersonal information or as otherwise set forth in the CCPA.

·  For internal administrative and auditingpurposes.

·  To detect security incidents and protectagainst malicious, deceptive, fraudulent or illegal activity, including, whennecessary, to prosecute those responsible for such activities.

The examples providedabove are illustrative and not intended to be exhaustive. For more details onhow we use this information, please refer to the “Use of Your Personal Data”section.

If We collectadditional categories of personal information or use the personal informationWe collected for materially different, unrelated, or incompatible purposes Wewill update this Privacy Policy.

Disclosure of Personal Information forBusiness Purposes or Commercial Purposes

We may use or discloseand may have used or disclosed in the last twelve (12) months these categoriesof personal information for business or commercial purposes:

·  Category A: Identifiers

·  Category B: Personal information categoriesin the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·  Category D: Commercial information

·  Category F: Internet or other similar networkactivity

The categories listedabove are those defined in the CCPA. This does not mean that all examples ofthat category of personal information were disclosed, but reflects our goodfaith belief to the best of our knowledge that some of that information fromthe applicable category may be and may have been disclosed.

When We disclosepersonal information for a business purpose or a commercial purpose, We enter acontract that describes the purpose and requires the recipient to both keepthat personal information confidential and not use it for any purpose exceptperforming the contract.

Sale of Personal Information

As defined in the CCPA,“sell” and “sale” mean selling, renting, releasing, disclosing, disseminating,making available, transferring, or otherwise communicating orally, in writing,or by electronic or other means, a consumer`s personal information by thebusiness to a third party for valuable consideration. This means We may havereceived some kind of benefit for sharing personal information, but notnecessarily a monetary benefit.

The categories listedbelow are those defined in the CCPA. This does not mean that all examples ofthat category of personal information were in fact sold, but reflects our goodfaith belief to the best of our knowledge that some of that information fromthe applicable category may be and may have been shared for value in return.

We may sell and mayhave sold in the last twelve (12) months these categories of personalinformation:

·  Category A: Identifiers

·  Category B: Personal information categoriesin the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

·  Category D: Commercial information

·  Category F: Internet or other similar networkactivity

Share of Personal Information

We may share Yourpersonal information identified in the above categories with these categoriesof third parties:

·  Service Providers

·  Payment processors

·  Our affiliates

·  Our business partners

·  Third party vendors to whom You or Youragents authorize Us to disclose Your personal information in connection withproducts or services We provide to You

The above excludestext messaging originator opt-in data and consent; this information will not beshared with any third parties.

Sale of Personal Information of Minors Under16 Years of Age

We do not knowinglycollect personal information from minors under the age of 16 through ourService, although certain third party websites we link to may do so. Thesethird-party websites have their own terms of use and privacy policies and weencourage parents and legal guardians to monitor their children`s Internetusage and instruct their children to never provide information on otherwebsites without their permission.

We do not sell thepersonal information of Consumers We actually know are less than 16 years ofage, unless We receive affirmative authorization (the “right to opt-in”) fromeither the Consumer who is between 13 and 16 years of age, or the parent orguardian of a Consumer less than 13 years of age. Consumers who opt-in to thesale of personal information may opt-out of future sales. To exercise the rightto opt-out, You (or Your authorized representative) may submit a request to Usby contacting Us.

If You have reason tobelieve that a child under the age of 13 (or 16) has provided Us with personalinformation, please contact Us with sufficient detail to enable Us to deletethat information.

Your Rights under the CCPA

The CCPA providesCalifornia residents with specific rights regarding their personal information.If You are a resident of California, You have the following rights:

·  The right to notice. You have the right to benotified which categories of Personal Data are being collected and the purposesfor which the Personal Data is being used.

·  The right to request. Under CCPA, You havethe right to request that We disclose information to You about Our collection,use, sale, disclosure for business purposes and share of personal information.Once We receive and confirm Your request, We will disclose to You:

·  The categories of personal information Wecollected about You

·  The categories of sources for the personalinformation We collected about You

·  Our business or commercial purpose forcollecting or selling that personal information

·  The categories of third parties with whom Weshare that personal information

·  The specific pieces of personal informationWe collected about You

·  If we sold Your personal information ordisclosed Your personal information for a business purpose, We will disclose toYou:

·  The categories of personal informationcategories sold

·  The categories of personal informationcategories disclosed

·  The right to say no to the sale of PersonalData (opt-out). You have the right to direct Us to not sell Your personalinformation. To submit an opt-out request please contact Us.

·  The right to delete Personal Data. You havethe right to request the deletion of Your Personal Data, subject to certainexceptions. Once We receive and confirm Your request, We will delete (anddirect Our Service Providers to delete) Your personal information from ourrecords, unless an exception applies. We may deny Your deletion request ifretaining the information is necessary for Us or Our Service Providers to:

·  Complete the transaction for which Wecollected the personal information, provide a good or service You requested,take actions reasonably anticipated within the context of our ongoing businessrelationship with You, or otherwise perform our contract with You.

·  Detect security incidents, protect againstmalicious, deceptive, fraudulent, or illegal activity, or prosecute thoseresponsible for such activities.

·  Debug products to identify and repair errorsthat impair existing intended functionality.

·  Exercise free speech, ensure the right ofanother consumer to exercise their free speech rights, or exercise anotherright provided for by law.

·  Comply with the California ElectronicCommunications 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 allother applicable ethics and privacy laws, when the information`s deletion maylikely render impossible or seriously impair the research`s achievement, if Youpreviously provided informed consent.

·  Enable solely internal uses reasonablyaligned with consumer expectations based on Your relationship with Us.

·  Comply with a legal obligation.

·  Make other internal and lawful uses of thatinformation compatible with the context in which You provided it.

·  The right not to be discriminated against.You have the right not to be discriminated against for exercising any of Yourconsumer`s rights, including by:

·  Denying goods or services to You

·  Charging different prices or rates for goodsor services, including the use of discounts or other benefits or imposingpenalties

·  Providing a different level or quality ofgoods or services to You

·  Suggesting You will receive a different priceor rate for goods or services or a different level or quality of goods orservices

Exercising Your CCPA Data Protection Rights

To exercise any ofYour rights under the CCPA, and if You are a California resident, You cancontact Us:

By email: info@footdirectclub.com

By visiting this pageon our website: https://footdirectclub.com/pages/privacy-policy

By mail: 1805 RiverwayDrive, Pekin, IL 61554

Only You, or a personregistered with the California Secretary of State You authorize to act on Yourbehalf, may make a verifiable request related to Your personal information.

Your request to Usmust:

·  Provide sufficient information that allows Usto reasonably verify You are the person about whom We collected personalinformation or an authorized representative

·  Describe Your request with sufficient detailthat allows Us to properly understand, evaluate, and respond to it

WE CANNOT RESPOND TO YOUR REQUEST ORPROVIDE YOU WITH THE REQUIRED INFORMATION IF WE CANNOT:

·  Verify Your identity or authority to make therequest

·  And confirm that the personal informationrelates to You

We will disclose anddeliver the required information free of charge within 45 days of receivingYour verifiable request. The period to provide the required information may beextended once by an additional 45 days when reasonable necessary and with priornotice.

Any disclosures Weprovide will only cover the 12-month period preceding the verifiable request`sreceipt.

For data portabilityrequests, We will select a format to provide Your personal information readilyuseable and should allow You to transmit the information from one entity toanother entity without hindrance.

Do Not Sell My Personal Information

You have the right toopt-out of the sale of Your personal information. Once We receive and confirm averifiable consumer request from You, we will stop selling Your personalinformation. To exercise Your right to opt-out, please contact Us.

The Service Providerswe partner with (for example, our analytics or advertising partners) may usetechnology on the Service that sells personal information as defined by theCCPA law. If you wish to opt out of the use of Your personal information forinterest-based advertising purposes and these potential sales as defined underCCPA law, you may follow the instructions below.

Any opt out isspecific to the browser You use. You may need to opt out on every browser Youuse.

Website

You may be able to optout of receiving ads personalized as served by our Service Providers byfollowing our instructions presented on the Service:

·  The NAI`s opt-out platform:http://www.networkadvertising.org/choices/

·  The EDAA`s opt-out platformhttp://www.youronlinechoices.com/

·  The DAA`s opt-out platform:http://optout.aboutads.info/?c=2&lang=EN

The opt out will placea cookie on Your computer unique to the browser You use to opt out. If youchange browsers or delete the cookies saved by your browser, You will need toopt out again.

Mobile Devices

Your mobile device maygive You the ability to opt out of the use of information about the apps Youuse to serve You ads targeted to Your interests:

·  “Opt out of Interest-Based Ads” or “Opt outof Ads Personalization” on Android devices

·  “Limit Ad Tracking” on iOS devices

You can also stop thecollection of location information from Your mobile device by changing thepreferences on Your mobile device.

“Do Not Track” Policyas Required by California Online Privacy Protection Act (CalOPPA)

Our Service does notrespond to Do Not Track signals.

However, some thirdparty websites do keep track of Your browsing activities. If You are visitingsuch websites, You can set Your preferences in Your web browser to informwebsites You do not want to be tracked. You can enable or disable DNT byvisiting the preferences or settings page of Your web browser.

Children's Privacy

Our Service addressesno one under the age of 13. We do not knowingly collect personally identifiableinformation from anyone under the age of 13. If You are a parent or guardianand You know Your child has provided Us with Personal Data, please contact Us.If We learn We have collected Personal Data from anyone under the age of 13without verification of parental consent, We try to remove that informationfrom Our servers.

If We need to rely onconsent as a legal basis for processing Your information and Your countryrequires consent from a parent, We may require Your parent`s consent before Wecollect and use that information.

Your CaliforniaPrivacy Rights (California`s Shine the Light law)

Under California CivilCode Section 1798 (California`s Shine the Light law), California residents withan established business relationship with us can request information once ayear about sharing their Personal Data with third parties for the thirdparties` direct marketing purposes.

If you`d like torequest more information under the California Shine the Light law, and if Youare a California resident, You can contact Us using the contact informationbelow.

California PrivacyRights for Minor Users (California Business and Professions Code Section 22581)

California Businessand Professions Code section 22581 allow California residents under the age of18 who are registered users of online sites, services or applications torequest and obtain removal of content or information they have publicly posted.

To request removal ofsuch data, and if You are a California resident, You can contact Us using thecontact information below, and include the email address associated with Youraccount.

Know Your request doesnot guarantee complete or comprehensive removal of content or informationposted online and that the law may not permit or require removal in certaincircumstances.

Links to Other Websites

Our Service maycontain links to other websites not operated by Us. If You click on a thirdparty link, You will be directed to that third party`s site. We strongly adviseYou to review the Privacy Policy of every site You visit.

We have no controlover and assume no responsibility for the content, privacy policies orpractices of any third party sites or services.

Changes to this Privacy Policy

We may update OurPrivacy Policy occasionally. We will notify You of any changes by posting thenew Privacy Policy on this page and, if we deem additional notice appropriate,by other means we deem appropriate. It is your duty to visit this page toreview any updates to the Privacy Policy.

We will let You knowvia email and/or a prominent notice on Our Service, before the change becomingeffective and update the “Last updated” date at the top of this Privacy Policy.

You are advised toreview this Privacy Policy periodically for any changes. Changes to thisPrivacy Policy are effective when posted on this page.

Contact Us

If you have questionsabout this Privacy Policy, You can contact us:

By email: info@footdirectclub.com

By visiting this pageon our website: https://footdirectclub.com/pages/privacy-policy

By mail: 1805 RiverwayDrive, Pekin, IL 61554