Privacy

SBxx Privacy Policy - Your Privacy Rights

SBxx Privacy Policy

December 27, 2022

At Sbxx, we believe in the power of truth, authenticity, and transparency. Sbxx LLC and its affiliates (“Sbxx”, “we”, “our” and/or “us”) provide this Privacy Policy so that our users understand what data we collect from them, how we use that data, and how we protect that data.

In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual and “Services” mean our website, https://www.theshoeboxxclub.com, (“Site”), our mobile apps (“Apps”), and other services that link to this Privacy Policy.

This Privacy Policy does not cover the practices of companies we don’t own or control, or people we don’t manage. By using the Services, you acknowledge you have read and understood this Privacy Policy.

Biometric Data Policy 

California Notice at Collection and other privacy information for California residents 

Summary of Key Points

What information does Sbxx collect? We collect Personal Information you provide to us directly such as your contact information and purchase details. We collect Personal Information automatically when you use the Services such information about your browser or device, the products you view, and your navigation on the Site. We also collect Personal Information from other parties to support our business operations and marketing efforts. Learn more about what information we collect.

How does Sbxx use this information? We use your Personal Information to provide the Services, enhance the Services and market the Services. This includes delivering your products, maintaining your account with us, communicating with you about our Services, developing new features or new product offerings, personalizing your experience on the Services, and meeting our legal and compliance obligations. Learn more about how we use your Personal Information.

Does Sbxx use Cookies and targeted advertising? Yes, our Services use Cookies and other tracking technologies to help provide you with an efficient and personalized experience on our Site and Apps. We use the Personal Information gathered through Cookies to help us market Sbxx through targeted advertising. You may choose to not allow Cookies and opt-out of our targeted advertising. Learn more about our use of Cookies and targeted advertising.

To whom does Sbxx disclose my information? We disclose Personal Information to service providers who help us provide the Services to you, such as cloud providers and payment processors. We also disclose Personal Information to advertising partners and may disclose it to other business partners such as affiliates. Finally, we disclose Personal Information to governmental authorities when under an obligation to do so. Learn more about our sharing of information.

Do I have any privacy rights concerning my information? You may, depending on where you live. But Sbxx has extended certain data choices to all Sbxx consumers, regardless of where you live. You may request that we delete your information, correct your information, or provide access to your information. Learn more about your privacy rights 

What else is contained in this Privacy Policy? We explain that your Personal Information will be transferred to the United States and possibly other jurisdictions, provide information about our security practices and data retention, and provide our Privacy Team’s contact details. Review additional information.

Does Sbxx have additional information for users in certain regions? Yes, there are sections of the Privacy Policy relating to California, the European Economic Area (EEA) and the United Kingdom (UK), Mexico, South Korea, and Japan.

  • Personal Information we collect about you

We collect and process Personal Information about you or your devices from various sources described below.

 Personal Information you provide to us

This is Personal Information about you that you provide directly to Sbxx and our service providers, including:

  • Region and language. When you visit our Sites or Apps, we may ask you to select your region and language to provide you with the relevant Services.
  • Registration and profile information. When you create an account on our Services, we will collect your name, email address, and a password. You may also provide optional profile information such as your shoe size and products you’re following. When you bid, ask or complete a transaction on the Services, that information will be tracked in your account. If you choose to apply two-factor authentication to your account, we will collect your mobile phone number.
  • Marketing information. When you sign up to receive SMS marketing messages from us, you provide us with your mobile phone number. Our SMS program is subject to the terms and conditions found here.
  • Purchase information. When making a purchase via our Services, we collect your shipping address, payment information and billing address. Payment information is collected through a third-party payment gateway and we do not store payment card information. Depending on your jurisdiction, you may also need to provide additional information related to customs and taxes, for example a VAT ID.
  • Seller information. Sellers must provide payout information including date of birth, address, and bank account, bank card, or digital payment services account information (e.g., Paypal, Venmo). This information is collected through a third-party payment gateway and we do not store payment card information. We may additionally require a government identification number (e.g., VAT ID, SSN) to satisfy tax or information reporting obligations. 
  • Identity Verification Information. Under certain circumstances, we may need to verify the identity of a buyer or seller on the Services. To do this, we may request that you provide government photo identification, and a live photo to our identity verification provider, which can confirm a match between your live photo and your government identification. This process may employ the use of biometric data, which you can read more about here: Biometric Data Policy.
  • Communications. When you contact us via a contact form, email, phone, or other means (e.g., to submit a query, or to report a problem with our Services), you may provide us with Personal Information, such as your name and contact details, language, and the content, date, and time of our communications.
  • Contests and sweepstakes. If you enter a contest or sweepstakes sponsored by us, you may provide us with your name, date of birth, mailing address and e-mail address if you enter via postal mail. If you enter through a social media platform, you will provide your social media handle and potentially other Personal Information as part of your entry.
  • Surveys and reviews. If you have chosen to receive marketing messages from us, we may contact you to participate in surveys about the Services or provide product or Services reviews. If you decide to participate, you may be asked to provide Personal Information.
  • Career information. If you apply for a job with us directly, you may provide us with your resume, name and contact details, and any other information that you submit to us. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the information you make available to us through such a third-party platform. Please see the Career page for the privacy practices that apply to job candidates.

Some of this information is considered “sensitive personal information” under some laws. Where we collect sensitive personal information, we do so either with your consent or because it is necessary to provide the Services to you (e.g., seller payout information), to fulfill a legal requirement (e.g., tax reporting), or to prevent and detect fraud on the platform. In some cases, provision of your Personal Information may be necessary to provide you with our Services. In these cases, if you fail to provide certain Personal Information when requested, we may be required to suspend your access to our Services.

 Personal Information collected automatically from your use of the Services

Like most websites, when you use our Services or open our marketing messages, we automatically collect certain information via automated means such as cookies, pixels, beacons, invisible tags, and similar technologies (collectively “Cookies”). These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you.

We may collect the following types of information via Cookies:

  • The type of device or browser you’re using, time zone setting, browser plug-ins and operating system information
  • Your IP address (from which we may approximate your geographic location)
  • Your browsing behavior while on the Services, including your login information, products viewed or searched for, time spent on the Services, page response times, download errors and page interactions
  • The URLs of the websites you visited immediately before visiting our Services
  • Unique numeric identifiers associated with your device or browser
  • Interactions with our marketing messages, such as when you click on a link in an email or SMS message
  • Interactions with our advertising partners, including the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase

You can learn more about how to control what Personal Information we collect via Cookies in the How We Use Cookies and Targeted Advertising section below.

 Personal Information we collect from third parties

We also collect Personal Information about you from other sources and third parties. We may add this information to the information we have already collected from you via our Services. This third-party information includes:

  • Social networks. We may collect Personal Information about you when you sign up or log in to our Services via third party platforms (such as Google, Facebook, Apple or Twitter). This information may include your social media user ID and email address. You may also post photos, comments, or reviews on our pages available through third-party platforms. You may also be able to post products from the Services through third-party social networks. If you do so, we and other users on those third-party platforms may be able to view the Personal Information you make available in your posts.
  • Data Partners. We receive additional Personal Information about you (such as approximate geographic location, demographic information, and mail order responses for categories of interest) from third parties that provide information about you based on your IP address, unique online identifier, or other data points you have provided to us. 
  • Fraud Prevention and Identity Services. We may receive Personal Information about you from our third-party service providers that we engage to confirm users’ identities and prevent fraud on the Services.
  • How we use your Personal Information

We use your Personal Information to:

  • Provide you with our Services, including to administer your account with us, process transactions, and notify you about changes to our Services.
  • Conduct internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
  • Ensure that content from our Services is presented in the most effective manner for you and for your computer, including personalizing the content presented to you on our Services based on your past interactions with the Services, your location, or other information.
  • Perform marketing analysis and provide you with promotional updates and information about our products we feel may interest you. You can opt-out of further marketing at any time by managing your account settings or selecting the “unsubscribe” link at the end of our marketing and promotional update communications to you. 
  • Deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
  • Keep our Services safe and secure (including fraud prevention via third-party identity verification services).
  • Analyze and improve our Services and develop new products and services.
  • Enforce our legal rights and maintain compliance with applicable laws and regulations.
  • How we use Cookies and Targeted Advertising

Our Use of Cookies. As explained above, we use Cookies to automatically collect data from you and your devices when you use the Services. Cookies enable you to be remembered when using a specific computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content. Certain Cookies also enhance our ability to serve you targeted advertising on websites and platforms other than the Services.

The types of Cookies we use can be classified as follows:

  • Strictly necessary cookies. These Cookies are required for the operation of our Services and under our terms with you. They include, for example, Cookies that enable you to log into secure areas of our Services, use a shopping cart, or make use of e-billing services.
  • Functional cookies. These Cookies are used to recognize you when you return to our Services and provide enhanced functionality. This enables us to personalize our content, and remember your preferences (for example, your choice of language or region).
  • Performance cookies. These Cookies allow us to recognize and count the number of users and to see how users move around our Services. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.
  • Targeting cookies. These Cookies record your visit to our Services, the pages you have visited and the links you have followed. We will use this information to make our Services and our advertising more relevant to your interests (as further set forth below). We may also disclose this information to third parties for this purpose.

Where required by applicable law, we will obtain your consent to use Cookies that do not fall in the Strictly Necessary category. Several Cookies we use last only for the duration of your session and expire when you close your browser or exit the App. Others are used to remember you when you return to the Services and will last longer.

Cookie preferences. You may change your Cookie preferences at any time to prevent the further collection of your information through the Performance, Targeting or Functional Cookies on the Services.

  • Cookie settings on the Services. Use the Your Privacy Choices link at the bottom of our website to turn on or off the different categories of Cookies. Your selection will be remembered on the specific device or browser you are using until you clear Cookies.
  • Browser settings. Most web browsers automatically accept Cookies, but if you prefer, you can change your browser settings to prevent cookies. How you can do this will depend on the browser you use (see your browser help screen for details).

You may not be able to take full advantage of our Services if you disable certain Cookies. The effect of disabling Cookies depends on which Cookies you disable but in general, the Services may not operate properly if all Cookies are switched off. Depending on your jurisdiction, we may separately prompt you regarding our use of Cookies on the Services.

Our use of targeted advertising. We use online advertising to keep you aware of our brand and help you to find and see our products. We partner with platforms such as Google, Meta, and similar digital advertising partners. Targeting Cookies help us and the advertising partners we work with gather information about the content you visit on our Services and other websites. This may result in you seeing Sbxx banners and ads when you are on other websites, apps and social media platforms.

We may also target ads using Personal Information we have collected when you create an account on the Services. We may disclose certain pseudo-anonymized (hashed) portions of your Personal Information (typically your email address) to social media and internet platforms. If you have an account on one of these platforms, you may be shown Sbxx marketing messages while you are using the social media or internet platform. 

Targeted advertising preferences. You may opt-out of us using your Personal Information for targeted advertising by changing your Cookie preferences. Use the “Your Privacy Choices” link at the bottom of our website and select toggle the “Targeted Advertising Opt-Out” button so that it is off.

If you are using a web browser with Global Privacy Control enabled, we will recognize that signal as a request to opt-out of Targeting Cookies, just as if you had turned off Targeting Cookies in the Your Privacy Choices center.

Additionally, our advertising partners may participate in programs that provide simple ways to opt out of ad targeting across the internet. You can opt out of such targeted advertising through the following programs:

We may disclose Personal Information we collect from or about you as described below or as otherwise disclosed to you at the time of collection.

  • Sbxx group. Any member of our group, which includes our subsidiaries, our ultimate holding company, and its subsidiaries, who support our processing of Personal Information.
  • Service providers. We also disclose your Personal Information to service providers (“processors”) that perform services on our behalf (e.g., cloud providers, shipping carriers, software services providers, identity verification services, etc.). This includes payment processing providers who provide secure payment processing services. Note that we do not have access to your payment card details.
  • Other selected third parties. Our selected third parties may include:
  • Analytics and search engine providers that assist us in the improvement and optimization of our Services.
  • Advertising Partners that we work with to show you ads that we think may interest you and provide ad measurement services to us. In “Targeted advertising preferences” above, we describe options for opting out of the sharing of your data for these purposes.
  • Business partners who jointly with us provide Services to you.
  • Other parties at your direction, including:
  • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services).
  • Social media services (if you intentionally interact with them through your use of the Services).
  • Third-party business partners that you access through the Services.
  • Other parties authorized by you.
  •  Merger, sale, or other asset transfers. In connection with the consideration, negotiation, or completion of a corporate transaction in which we sell or transfer all or a portion of our business or assets, but only to the extent that your Personal Information is necessary for such transactions, in which case we will comply with applicable legal requirements when processing your Personal Information.
  • As required by law and similar disclosures. If we are under a duty to disclose your Personal Information in order to comply with any legal obligation, regulation, process or governmental request, or in order to enforce or apply our terms and other agreements with you; or to protect the rights, property, or safety of Sbxx, our customers, or others. This includes exchanging information with other companies and organizations, including law enforcement agencies, for the purposes of fraud protection, tax reporting, and to prevent cyber or other suspected or alleged crime.
  • With your consent. We may also disclose Personal Information from or about you or your devices with your permission obtained in accordance with applicable law.

We do not sell your Personal Information, in so far as the term “sale” is commonly understood to be an exchange for monetary consideration. However, under the California Consumer Privacy Act (CCPA), our sharing of information for targeted advertising uses could be considered a “sale” of Personal Information.

  • Your rights

Depending on your jurisdiction and under certain circumstances, you may have the following rights with respect to your Personal Information:

  • to be provided with a copy of your Personal Information (right of access), including the right to have your Personal Information provided in a commonly used and machine-readable format (right of portability) ;
  • to request the correction of your Personal Information;
  • to request the deletion of your Personal Information;
  • to request that we restrict the processing of your Personal Information;
  • to object to the further processing of your Personal Information, including the right to object to marketing communications;
  • to provide instructions about your Personal Information after death; and
  • to opt-out of sharing your personal information with third parties for some purposes, notably targeted advertising, which may be defined as a sale under applicable laws.

You may also have the right to appeal a decision we make regarding your rights.

These rights vary depending on where you reside, but we make efforts to honor requests for access/portability, deletion, and correction from all Sbxx users, regardless of where they live. You may exercise these rights by submitting a form through our Trust Center portal.

You may also opt out of receiving marketing emails from us at any time through your Account Settings or by clicking the unsubscribe link at the bottom of our marketing emails. You can opt out of receiving promotional text messages by responding “STOP” to one of our text messages.

To exercise other rights, ask questions about your rights, or to appeal a decision we have made about your rights, please contact us at dpo@Sbxx.com. We will not discriminate against you because you have exercised your rights.

  • How we transfer your Personal Information

Sbxx has its headquarters in the United States. Information we collect about you will be processed in the United States and depending upon the nature of your interaction with us, may be further processed in other countries. For example, if your goods are being shipped from a country other than where you are located, your Personal Information will be disclosed to a carrier in that country as part of our shipping process.

We comply with applicable legal requirements when transferring Personal Information to countries other than the country where you are located. If you are located in the EEA or the UK , we will transfer Personal Information to countries for which adequacy decisions have been issued, use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses or their equivalent under applicable law, or rely on other data transfer mechanisms where applicable. Depending on your country, you may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of your jurisdiction.

  • How we protect your Personal Information

We take steps to secure the Personal Information you provide through the Services, although no method of data transfer or storage on networks is 100 percent secure. All information you provide to us is stored on our secure servers. We implement appropriate technical and organizational measures to protect it from unauthorized access, loss, destruction or alteration.

You have a role to play in protecting your information, too. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to disclose a password with anyone, and to use a unique password on the Services.

We do not collect or store the credit or debit card or other payment information that you provide in the context of the Services. Payments made on the Services using a credit or debit card are made directly through a third-party payment gateway provider. We do not collect or store Personal Information that you may provide to our identity verification service providers.  Personal Information that you supply to third parties is not within our control and is subject to those third parties’ privacy policies and terms of service.

  • How long we keep your Personal Information

We will retain Personal information for the period necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, unless a longer retention period is required by law. We delete your Personal Information or keep it in a form that does not identify you when this retention period is over.

When determining the retention period, we consider various criteria, such as the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on our ability to provide you with certain features of our Services if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services. You cannot be identified from aggregate information retained or used for these purposes.

  • Personal Information of children

We do not knowingly collect or solicit Personal Information from children under 16; if you are a child under 16, please do not attempt to register on or otherwise use the Services or send us any Personal Information. If we learn we have collected Personal Information from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us with their Personal Information, please contact us as indicated in the “Contact us” section below.

  • Third parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

  • Changes to this Privacy Policy

Any changes we make to our Privacy Policy in the future will be posted on this page. If we make material changes to this Privacy Policy or the ways in which we use or disclose personal information previously collected from you, we will notify you by email or other communication.

  • Contact us

You may find additional information and tips in our Help Center. If you cannot find the information you are looking for in the Help Center, you may contact us at DPO@Sbxx.com.

The entity responsible for the processing of your Personal Information is:

Sbxx LLC

1046 Woodward Avenue,

Milwaukee, MI 48226 USA

Email: dpo@Sbxx.com

Fax: 1-800-332-9360

  • Biometric Data Policy

We may collect your Biometric Data under certain circumstances to identify and authenticate you for purposes of security and fraud prevention. Biometric Data in this context consists of facial recognition data, as well as mathematical representations of your facial geometry. We will seek your consent to collect your Biometric Data.

We collect this Biometric Data through our third-party service provider of identity verification services, Persona. Persona captures a photo of your ID and your face and compares the facial geometry extracted from the photos of your ID and your face to verify your identity.

Persona does not use your Biometric Data for any purpose other than to verify your identity and to improve its verification services. It does not disclose your Biometric Data to us or any other third party. We can however view a copy of the photographs of your face and ID.

You can read more about Persona’s biometric privacy practices, including the applicable retention period here.

  • Region-specific sections
  • California Notice at Collection and Other Information

This Notice at Collection provides specific information for California residents as required by the CCPA.

The following chart details the categories of Personal Information that we collect and have collected over the past twelve (12) months. Throughout this Privacy Policy, we will refer back to the categories of Personal Information listed in this chart (for example, “Category A. Personal identifiers”).

Category of Personal Information

Personal Information Collected

Purpose of Collection

Data Shared?

Personal identifiers

 

Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number.

To provide the Services, marketing and advertising activities, analytics and personalization of the Services, security and fraud prevention, fulfill our legal obligations and support core business functions. We only collect sensitive personal information such as your social security number when it is required for legal purposes.

Yes

Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))

Name, address, telephone number, social security number, bank account number, credit card number, debit card number, or any other financial information

To provide the Services, marketing and advertising activities, analytics and personalization of the Services, security and fraud prevention, fulfill our legal obligations and support core business functions. We only collect sensitive personal information such as your social security number when it is required for legal purposes.

No

Commercial information

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

To provide the Services, marketing and advertising activities, analytics and personalization of the Services, security and fraud prevention.

Yes

Internet or other similar network activity information

Browsing history, search history, or information on a consumer's interaction with a website, application or advertisement.

To provide the Services, marketing and advertising activities, analytics and personalization of the Services, security and fraud prevention.

Yes

Biometric information

Facial scans extracted from photos and photo IDs

To verify the identity of buyers and sellers on the Services

No

Inferences drawn from any of the information above to create a consumer profile

Profile reflecting a person’s preferences, characteristics, predispositions, behavior, and attitudes these relate to that person’s interaction with the Services.

To provide the Services, marketing and advertising activities, analytics and personalization of the Services, security and fraud prevention.

No

In the chart above, the column indicating whether or not Personal Information has been “shared” indicates that certain data has been disclosed to advertising and social media partners for the purpose of targeted advertising. Under California law, such sharing may be considered a “sale” of information. We offer the ability to opt-out of the sharing of data for this purpose, by clicking on the “Your Privacy Choices” link at the bottom of our website.

We will retain the Personal Information identified above for the period necessary to fultill the purposes for which it has been collected unless a longer retention period is required by law or our business requirements. When determining the retention period, we consider various criteria, such as the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on our ability to provide you with certain features of our Services if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

Other California Privacy Policy Information

The information below supplements our general Privacy Policy with information required by the CCPA.

In the preceding twelve months since this notice was last updated, we disclosed your Personal Information to the following categories of third parties:

  • Vendors: Vendors and service providers.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information, Professional or employment-related information.
  • Advertising Providers: Advertising technology companies, such as advertising networks.
  • Personal Information we disclose: Personal identifiers, Internet or other similar network activity information. Under CCPA, this disclosure may be considered a “sale” of Personal Information.
  • Analytics Providers.
  • Personal Information we disclose: Personal identifiers, Internet or other similar network activity information.
  • Payment Service Providers:
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information.
  • Business Partners: Business partners who jointly with us provide Services to you.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information.
  • Government: Government entities, such as customs and duties officials.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information.
  • Social Networks.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law. Under CCPA, this disclosure may be considered a “sale” of Personal Information.
  • Affiliates.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information. Under CCPA, this disclosure may be considered a “sale” of Personal Information.
  • Integrated Third Parties: Third parties integrated into our services.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Internet or other similar network activity information. Under CCPA, this disclosure may be considered a “sale” of Personal Information.
  • Third Parties as Legally Required: Third parties as required by law and similar disclosures.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information, Professional or employment-related information.
  • Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information, Professional or employment-related information.
  • Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
  • Personal Information we disclose: Personal identifiers, Customer records identified by state law, Commercial information, Internet or other similar network activity information, Professional or employment-related information.

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

  • You
  • Our third party service providers
  • Social Networks
  • Third party data providers

Notice of financial incentive. When you sign up to receive text messages from Sbxx in the context of a promotional offer (for example, a discount), you provide your mobile number for our marketing use. Because signing up involves the collection of Personal Information, it might be considered a “financial incentive program” under California law. When you participate in a financial incentive, you agree to the terms of that incentive, and may revoke your participation depending on the incentive (e.g., by opting out of emails). For more information on the SMS program, please see the SMS terms and conditions. You can opt out of receiving promotional text messages from us at any time by texting STOP in response to a message you receive from us. To the extent we can determine the value of your information, we consider the value of providing you with a more personalized experience as well as the expenses we incur in providing the incentive to ensure the incentive is reasonably related to the value of your information.

  • EEA and UK residents

If you are located in the EEA or the UK, this section applies to you. This table sets out:

  • What Personal Information we process
  • For what purpose we process Personal Information
  • The legal basis for the processing

Purpose/Activity

Type of data

Legal basis for processing

Provide you with our Services, including to administer your account with us, notify you about changes to our Services, and allow you to participate in interactive features of our Services, when you choose to do so.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information about your activity related to purchases and sales on Sbxx

(c) Information collected via Cookies

(a) Performance of a contract with you (Art 6 (1) (b) GDPR)

For internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information about your activity related to purchases and sales on Sbxx

(c) Information collected via Cookies

(a) Performance of a contract with you (Art 6 (1) (b) GDPR)

(b) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: to operate and improve our Services)

(c) Consent (Art 6 (1) (a) GDPR)

Ensure that content from our Services is presented in the most effective manner for you and for your computer.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information collected via Cookies

(a) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: customize our Services to you)

Perform marketing analysis and provide you with promotional updates and information about our products we feel may interest you.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information about your activity related to purchases and sales on Sbxx

(c) Information collected via Cookies

(a) Consent (Art 6 (1) (a) GDPR)

(b) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: market our Services to you)

Deliver relevant  content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information collected via Cookies

(a) Consent (Art 6 (1) (a) GDPR)

(b) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: advertise our Services to you)

Keep our Services safe and secure.

Any Personal Information we collect about you, in particular:

(a) Account information

(b) Information about your activity related to purchases and sales on Sbxx

(c) Information collected via Cookies

(a) Performance of a contract with you (Art 6 (1) (b) GDPR)

(b) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: keep our Services safe)

For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations.

Any Personal Information we collect about you, in particular:

(a) Account information

(a) Necessary to comply with a legal obligation (Art 6 (1) (c) GDPR)

(b) Necessary for our legitimate interests (Art 6 (1) (f) GDPR: enforce our legal rights)

In exercising your data rights as explained above in this Privacy Policy, if your request or concern is not satisfactorily resolved by us, or you have another complaint regarding the Personal Information processing, please contact us at DPO@Sbxx.com so we may try to address your concern. You also have the right to contact your local data protection authority with your concerns.

For UK residents, contact: Information Commissioner’s Office, Wycliffe House, Water Lane, Wimslow, SK9 5AF. Tel: 0303 123 1113. Website: www.ico.org.uk.

For EU and EEA residents, a list of data protection authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en 

  • Mexican residents

If you are located in Mexico, this section applies to you.

Primary and Secondary Purposes

The purposes indicated in the  “How we use your Personal Information” section are primary purposes, with the exception of the following purposes which qualify as secondary purposes: (i) perform marketing analysis and provide you with promotional updates and information about our products we feel may interest you; (ii) deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.

Exercising Your Rights

Your request must contain or be accompanied by: a) your full name and address, or other means to communicate the response to your request; b) compliance with any identity requests from our DSAR provider; c) a clear description of the right that you wish to exercise, and the Personal Information related to your request; and d) where appropriate, any other information or document that helps us locate your Personal Information. You may exercise some of the rights listed above by contacting us through our Trust Center portal.

We will answer your request within 20 (twenty) business days following the date it is received. If the request is complete and can be fulfilled, we will make it effective within 15 (fifteen) business days following the date on which we send our response. If the information and/or documentation provided in your request is incomplete, wrong and/or insufficient, or the documents necessary to prove your identity or the corresponding legal representation are not included, we will request additional information to be able to process your request. You will have 10 (ten) business days to provide us with the requested additional information; if you fail to provide the requested additional information, your request will be considered as withdrawn.

  • South Korean residents

If you are located in South Korea, this section applies to you.

We destroy your personal information pursuant to the following procedure and method.

Destruction procedure. We select the personal information which is required to be destroyed and destroy it under the approval of the personal information protection officer.

Method of destruction. We destroy personal information recorded and stored in the form of electronic files in a way that it cannot be recovered, and personal information recorded and stored in the form of paper by shredding or incineration.

Department in charge of handling complaints related to personal information

Name: Legal and Compliance Department

Contact Information: You may find additional information and tips in our Help Center available at https://www.theshoeboxxclub.com/. If you cannot find the information you are looking for in the Help Center, you may contact us at https://www.theshoeboxxclub.com/.

  • Japanese residents

Joint user of Personal Information. We may jointly use Personal Information with any member of our group, which includes our subsidiaries, our ultimate holding company, and its subsidiaries, and that supports our processing of Personal Information. The types of Personal Information that we would use jointly for the purposes described in Section 2 of this Privacy Policy are: name, contact information, and other Personal Information as described in Section 1 of this Privacy Policy. The name, address, and representative of the business operator responsible for the management of Personal Information are as follows: Sbxx LLC, Milwaukee WI 53215, USA, Representative: see https://www.theshoeboxxclub.com/.

Information security management. We will take all necessary and appropriate measures to prevent leakage, loss, or damage of Personal Information and to safely manage Personal Information. The safety management measures we will take include the following:

  • Development of rules on the handling of Personal Information. We have established rules on the handling of Personal Information that stipulate the handling methods with respect to Personal Information, the persons responsible for and in charge of the protection of Personal Information, and the duties of such persons.
  • Organizational measures. We have appointed a person responsible for the handling of Personal Information, clarified the scope of Personal Information handled by employees handling Personal Information, and established a system for reporting information to the person in charge in the event of any violation of the laws or rules on the handling of Personal Information or any evidence of such violation. We regularly conduct self-inspections of the status of the handling of Personal Information and our auditing department regularly conducts audits.
  • Security control measures involving Our Employees. We regularly train our employees on matters of concern regarding the handling of Personal Information. All of our employees owe confidentiality obligations regarding Personal Information.
  • Physical security control measures. In areas under our control, such as our business sites, where Personal Information is handled, we control the entry and exit of employees and restrict devices, etc. brought in, and take measures to prevent unauthorized persons from viewing Personal Information. We take measures to prevent the theft or loss of equipment, electronic media, and documents that handle or contain Personal Information, and take measures to prevent Personal Information from being easily detected when transporting such equipment, electronic media, etc., including transportation within our business sites.
  • Technical security control measures. Access control is implemented to limit the number of personnel in charge and Personal Information databases handled. We have introduced a mechanism to protect information systems that handle Personal Information from unauthorized access from outside sources or from unauthorized software.
  • External environments. When Personal Information is handled or transferred outside Japan, safety management measures are implemented in compliance with legislation on the protection of Personal Information in the relevant countries where Personal Information is stored. Please contact us using our contact details above if you require further details on this point.


United States | English | $ USD

Find Us on Social

©2023 Sbxx. All Rights Reserved.




Share by: