subsidiaries and affiliated companies (collectively, “Brooks,” “we,” or “us”)
collect when you access or use our websites, mobile applications, and other online products and services that link
in our stores, at an event, through our customer feedback programs or customer support channels, including Ask a Guru, or on social media pages. We may
provide different or additional notices of our privacy practices with respect to certain products, services or
the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a
to stay informed about our information practices and the choices available to you.
Collection of Information
Use of Information
Targeted Advertising and Analytics
Disclosures of Information
Your Privacy Rights and Choices
Transfers of Information to the United States and Other Countries
Additional Disclosures for Individuals in California
Additional Disclosures for Individuals in Europe
COLLECTION OF INFORMATION
The information we collect about you depends on how you interact with us or use our Services. In this section, we
describe the categories of information we collect and the sources of this information.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you
make a purchase, create an account, fill out a form, submit a product review or post content through our Services,
participate in a survey, contest, promotion or event, request customer support, or otherwise communicate with us.
The types of information that we collect include your name, email address, postal address, phone number, birth date,
payment method information, photos and videos (such as in connection with a product review or product feedback),
social media handles, and any other information you choose to provide. If you make a purchase from us, we work with
a third-party payment processor to collect and process your payment information.
If you choose to participate in certain programs, such as wear testing, customer surveys, research studies, or to use
our Run Signature tool, we may collect additional information to advise you on product selection and help improve
our products. This includes demographic information like your age and sex, information about your running habits and
other exercise activities, foot width, weight, BMI, pronation, information about injuries you’ve experienced,
and running assessment data. You may also choose to provide scans of your feet to help us provide shoe
recommendations. If you participate in some of our initiatives to improve our products, we may also give you the
option to provide additional demographic information, such as data about your race/ethnicity, where you live (e.g.,
urban or rural), and your household income range. See the Your Privacy Rights and
Choices section below to learn more about the options you have with respect to such information.
Information We Collect Automatically
We automatically collect certain information about your interactions with us or our Services, including:
- Transactional Information: When you make a purchase or return, we collect information about the transaction,
such as product details, purchase price, and the date and location of the transaction.
- Device and Usage Information: We collect information about how you access our Services, including data about the
device and network you use, such as your hardware model, operating system version, mobile network, IP address,
unique device identifiers and browser type. We also collect information about your activity on our Services,
such as items you place in your cart and products you click on.
- Audio and Video Recordings, Photos, and Chat Content: We capture photographs and video recordings in our stores
for security and loss prevention purposes. If you contact customer service through our chat feature or by phone,
we may monitor and retain those conversations, including for training purposes.
- Information Collected by Cookies and Similar Tracking Technologies: We use tracking technologies, such as
cookies and pixels to collect information about your interactions with the Services. These technologies help us
improve our Services and your experience, see which areas and features of our Services are popular, and count
visits. For more information about the cookies and other tracking technologies we use, and the choices available
Information We Collect from Other Sources
We obtain information from other sources. For example, we may collect information from identity verification
services, advertising networks, data analytics providers, and running event sponsors. This information includes race
data (e.g., the name of a race you ran in), your contact information (such as postal address), and information about
previous purchases and product preferences. We also obtain information from our partners and third parties who
purchase products from us wholesale, sponsor events that we participate in, or who otherwise engage with us. For
example, if you participate in a November Project event, we may receive information, such as your clothing size and
your address, in order to send you running gear for that event.
We also receive information from PWR Lab, Inc. when individuals choose to share the data collected from their
wearable devices and technologies (such as fitness tracking devices) with us to help improve our products,
experiences, and services. Depending on your account settings with PWR Lab, we may receive data that you direct PWR
Lab to share with us, which may include metrics about how and where you run, such as mileage, duration, heart rate,
precise running routes (including precise geolocation data), ground reaction force, and speed (collectively,
“PWR Lab Data”). We only collect PWR Lab Data with your consent. You may withdraw your consent at any
time by logging into your account with PWR Lab and updating your settings.
Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make
inferences about your approximate location based on your IP address or infer that you are looking to purchase
certain products based on your browsing behavior and past purchases.
USE OF INFORMATION
We use the categories of information we collect to process your orders, respond to your requests, market our products
to you, and administer your online account. We also use the information we collect to:
- Provide, maintain, and improve our products and services;
- Personalize your experience with us;
- Send you technical notices, security alerts, support messages and other transactional or relationship messages;
- Communicate with you about products, services, and events offered by Brooks and others and provide news and
information that we think will interest you (see the Your Privacy Rights and Choices section below for
information about how to opt out of these communications at any time);
- Provide and administer any loyalty programs we offer, including the Brooks Run Club and the Sports Medicine
- Monitor and analyze trends, usage, and activities in connection with our products and services;
- Target advertisements to you on third-party platforms and websites (for more information and to opt out, see the
Your Privacy Rights and Choices section below);
- Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
- Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal
activity and help protect the rights and property of Brooks and others; and
- Comply with our legal and financial obligations.
TARGETED ADVERTISING AND ANALYTICS
We engage others to provide analytics, serve advertisements, and perform related services across the web and in
collect information about your use of our Services and other websites and mobile apps, including your IP address,
web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion
information. This information is used to deliver advertising targeted to your interests on other companies’
sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better
understand your activity. In addition, some of our advertising partners enable us to translate your email address or
phone number into an identifier that cannot be used to identify you personally. Our advertising partners then use
that unique identifier to show ads that are more relevant to you across the web and in mobile apps. Some of the
activities described in this section may constitute “targeted advertising,” “sharing,” or
“selling” under certain privacy laws. To learn more about the choices available to you with respect to
these practices, or to opt out of having your information used in this way, see the Your Privacy Rights and Choices
You can also learn more about interest-based ads or opt out of having your web browsing information used for
behavioral advertising purposes by companies that participate in the Digital Advertising Alliance by visiting
www.aboutads.info/choices, or, if you reside in the European Union, by visiting www.youronlinechoices.eu.
DISCLOSURES OF INFORMATION
In certain circumstances, we disclose (or permit others to directly collect) information about you. We disclose the
categories of personal information described above in the following circumstances and as otherwise described in this
- We disclose personal information to vendors, service providers, contractors and consultants that need this
information to provide services to us, such as companies that assist us with web hosting, shipping and delivery,
payment processing, fraud prevention, customer service, and marketing and advertising.
- If you provide a product review or otherwise post content on our Services, such information will be available
publicly on our Services and may appear on other sites that sell our products.
- We disclose personal information if we believe that disclosure is in accordance with, or required by, any
applicable law or legal process, including lawful requests by public authorities to meet national security or
law enforcement requirements.
- We disclose personal information if we believe that your actions are inconsistent with our user agreements or
policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights,
property, and safety of Brooks, our users, the public, or others.
- We disclose personal information to our lawyers and other professional advisors where necessary to obtain advice
or otherwise protect and manage our business interests.
- We disclose personal information in connection with, or during negotiations of certain corporate transactions,
including the merger, sale of company assets, financing, or acquisition of all or a portion of our business by
- Personal information is disclosed between and among Brooks and our parents, affiliates, subsidiaries, and other
companies under common control and ownership.
- We disclose personal information when we have your consent, or you direct us to do so.
We also disclose aggregated or de-identified information that cannot reasonably be used to identify you. Brooks
processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify
such information, except as permitted by law.
YOUR PRIVACY RIGHTS AND CHOICES
Access, Correction, Deletion
Depending on where you reside, you may have the right to (1) request to know more about and access the personal
information we collect, use, and disclose about you, (2) request deletion of your personal information, and (3)
request correction of inaccurate personal information.
To request access, correction, or deletion of your personal information, please email us at firstname.lastname@example.org
or call our toll-free number at 1-855-427-6657. You can also access, update, or correct certain information stored
within your online account at any time by logging into your account and updating your preferences.
We may verify your request by asking you to provide information related to your recent interactions with us, such as
your relationship to Brooks, recent account activity (such as product purchases), or account registration
information. If we deny your request, you may appeal our decision by contacting us at email@example.com. If
you have concerns about the results of an appeal, you may contact the attorney general in the state where you
Opting Out of Targeted Advertising, Sharing, Sales
As described in the Targeted Advertising and Analytics section above, we process certain personal information to
understand and improve your experience with our Services and to help target ads to you on non-Brooks properties.
Some of these activities may be considered “sales” or “sharing” of your personal information
or “targeted advertising” under the law that applies to you.
Depending on where you reside, you may opt out of targeted advertising, sharing, and sales of your personal
information, by clicking here and follow the instructions on the page. You can also opt out of certain sharing and
sales by visiting our website with a legally recognized universal choice signal enabled (such as the Global Privacy
Control). Please note that, depending on which opt-out preference signal you use and whether you are logged into
your account with us, our processing of the signal may be limited to the specific browser or device that you are
using. You may need to renew your opt-out if you use a different browser or device to access our Services.
Consent, Objection, and Related Rights
Depending on where you reside, you may have the right to (1) object to certain processing, (2) withdraw your consent
where we process your information on that basis, and (3) request we restrict certain processing. To exercise any of
these rights, please contact us at firstname.lastname@example.org. In addition, if you choose to disclose data to us
through PWR Lab, you may change these settings at any time via your PWR Lab account. If you participate in our wear
testing program or similar customer feedback programs and wish to withdraw from the program or prefer that we no
longer use your information for that program, please contact us email@example.com.
We will not discriminate against you if you exercise your privacy rights.
Cookies and Similar Technologies
are interacting with our marketing communications. Most web browsers are set to accept cookies by default. If you
prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing
or rejecting cookies could affect the availability and functionality of our Services. For more information, please
You may opt out of receiving text messages or promotional emails from Brooks by following the instructions in those
communications. If you opt out, we may still send you non-promotional emails, such as those about your account or
our ongoing business relations.
TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
Brooks is headquartered in the United States, and we have operations and vendors in the United States and other
countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or
access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home
jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance
with applicable law, such as by executing Standard Contractual Clauses. Where relevant, you may request a copy of
these Standard Contractual Clauses by contacting us at firstname.lastname@example.org.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN CALIFORNIA
The California Consumer Privacy Act (“CCPA”) requires us to explain some information using definitions
and categories set out under the CCPA. If you reside in California, this section applies to you.
Based on how you interact with us, in the preceding 12 months, we have collected the following categories of personal
information and sensitive personal information: identifiers, characteristics of protected classifications under
California or U.S. law, commercial information, internet or other electronic network activity information,
geolocation data, audio and visual data, professional or employment-related information, inferences, and certain
data deemed “sensitive” under California law, including precise geolocation information, and information
about racial or ethnic origin. For details about the precise data we collect and the categories of sources of such
collection, please see the Collection of Information section above. We collect, use, and disclose personal
information for the business and commercial purposes described in the Use of Information section above. For
information about how long we retain each category of personal information collected, see the Data Retention section
above. In the preceding 12 months, we have disclosed the following categories of personal information for business
purposes to the following categories of recipients who help us provide and improve our products and services:
Your Privacy Rights
You have the right to opt out of sharing and sales at any time by clicking here.
We do not knowingly sell or share personal information about consumers under the age of 16.
Please see the Your Privacy Rights and Choices section above for more information about your privacy rights, how to exercise them, and how we will verify your requests.
If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify their own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please contact us at email@example.com.
Notice of Financial Incentives
We offer various financial incentives. For example, if you participate in Brooks Run Club we may provide you with early access to limited edition shoes, unique running content, and chances to win exciting prizes. We may also provide discounts, coupons, or other benefits to customers who join membership programs or sign up to receive our marketing emails or text messages. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your email address or phone number), commercial information (like your purchase preferences and interests or purchase history), inferences drawn about your preferences, and other categories of personal data that relate to or are reasonably capable of being associated with you. You can opt into a financial incentive by following the sign-up or participation instructions provided, and, for any ongoing benefits, you can opt-out at any time, such as by following the unsubscribe instructions in the applicable program’s terms and conditions, promotional emails, or text messages, or contacting us at firstname.lastname@example.org. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.
ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have the rights outlined in the Your Privacy Rights and Choices section above, and this section also applies to you.
When we process your personal data, we will do so in reliance on the following lawful bases:
To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
- When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
- To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
- When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:
For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html