NOTICE TO RESIDENTS OF U.S. STATES WITH COMPREHENSIVE PRIVACY LAWS
Last Updated: 9/10/2026
*For California Residents please refer to the California Privacy Notice
Numerous U.S. states have enacted comprehensive consumer data privacy laws that require us to provide residents of those states with a privacy notice describing our practices for collecting, using, disclosing, and selling personal data, as well as the rights available to those residents in relation to their personal data. This Notice applies solely to residents of the following states:
· Virginia — Virginia Consumer Data Protection Act (VCDPA), effective January 1, 2023
· Colorado — Colorado Privacy Act (CPA), effective July 1, 2023
· Connecticut — Connecticut Data Privacy Act (CTDPA), effective July 1, 2023
· Utah — Utah Consumer Privacy Act (UCPA), effective December 31, 2023
· Texas — Texas Data Privacy and Security Act (TDPSA), effective July 1, 2024
· Oregon — Oregon Consumer Privacy Act (OCPA), effective July 1, 2024
· Montana — Montana Consumer Data Privacy Act (MCDPA), effective October 1, 2024
· Iowa — Iowa Consumer Data Protection Act (ICDPA), effective January 1, 2025
· Delaware — Delaware Personal Data Privacy Act (DPDPA), effective January 1, 2025
· New Hampshire — New Hampshire Privacy Act, effective January 1, 2025
· New Jersey — New Jersey Data Privacy Act, effective January 15, 2025
· Nebraska — Nebraska Data Privacy Act (NDPA), effective January 1, 2025
· Tennessee — Tennessee Information Protection Act (TIPA), effective July 1, 2025
· Minnesota — Minnesota Consumer Data Privacy Act, effective July 31, 2025
· Maryland — Maryland Online Data Privacy Act (MODPA), effective October 1, 2025
· Indiana — Indiana Consumer Data Protection Act, effective January 1, 2026
· Kentucky — Kentucky Consumer Data Protection Act, effective January 1, 2026
· Rhode Island — Rhode Island Data Transparency and Privacy Protection Act, effective January 1, 2026
If you are not a resident of one of these states, this Notice does not apply to you and should not be relied upon. California residents should refer to our separate Notice to California Residents.
Under these state privacy laws, “personal data” (or, in some states, “personal information”) generally refers to information that is linked or reasonably linkable to an identified or identifiable individual. Personal data does not include deidentified data, publicly available information, or aggregate data.
PERSONAL DATA WE COLLECT
We currently collect and, in the 12 months prior to the date of posting of this Notice, have collected the following categories of personal data:
· Personal identifiers (name, email address, telephone number, postal address, Internet Protocol (IP) address);
· Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology);
· Internet or other electronic network activity information (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement);
· Geolocation data;
· Commercial information (products purchased, coupon or promotion usage);
· Sensory data (foot assessment from our Custom Fit Kiosk, lifestyle questions, and shoe size); and
· Inferences (from the information described above to create a profile reflecting a consumer’s preferences, characteristics, behaviors, and attitudes for the purpose of delivering targeted advertising).
SOURCES OF PERSONAL DATA
We collect personal data about you from the following sources:
· Directly from you;
· Third party sources, including retail and distribution partners and advertising partners;
· Service providers.
· Please note, we do not collect all categories of personal data from each source.
HOW WE USE PERSONAL DATA
We collect your personal data for the following business and commercial purposes:
· To measure and improve how our ads perform, including understanding how many people see them and where they appear;
· To help keep our systems and your information safe and secure;
· To find and fix technical issues so our Sites work properly;
· To support short-term uses like showing you ads based on what you are doing on our Sites at that moment;
· To provide our services, including managing your account, answering your questions, processing orders, and storing or analyzing information;
· To support our advertising and marketing efforts, while honoring your opt-out choices and not combining your information with data from other sources when you have opted out;
· To conduct internal research and improve our technology;
· To maintain and improve the quality, safety, and performance of our products and services; and
· To promote our business and help connect you with products or services that may interest you.
SALE, TARGETED ADVERTISING, AND DISCLOSURE OF PERSONAL DATA
State comprehensive privacy laws generally define “sale” as the exchange of personal data for monetary or other valuable consideration. Some states, such as Virginia, Colorado, Connecticut, and others, define the concept broadly to include exchanges for “other valuable consideration” (not limited to money). Utah defines “sale” more narrowly to require monetary consideration only. Unlike the CCPA, most state laws do not have a separate concept of “sharing,” but instead address “targeted advertising” as a distinct opt-out right.
Targeted advertising generally means displaying an advertisement to a consumer where the advertisement is selected based on personal data obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict the consumer’s preferences or interests. It does not include advertisements based on activities within the controller’s own website or in response to a consumer’s request.
In addition to the personal data sharing disclosed in our main website Privacy Policy, the table below identifies the categories of personal data that we have sold or disclosed to third parties, as well as the categories of third parties with whom that data was sold or disclosed:
|
Category of Personal Information |
Categories of Third Parties |
|
Personal Identifiers (name, postal address, IP address, email address) |
Advertising networks; data analytics providers; social media networks; distribution and retail providers; website operation provider |
|
Unique Personal Identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology) |
Advertising networks; data analytics providers; social media networks; website operation provider |
|
Internet Activity (browsing history; search history; and information regarding consumer’s interaction with website, application, or advertisement) |
Advertising networks; data analytics providers; social media networks; website operation provider |
|
Commercial Information (records of products or services purchased, obtained, or considered; consuming histories or tendencies) |
Advertising networks; data analytics providers; social media networks; joint marketing partners |
|
Inferences from Other Data |
Advertising networks; data analytics providers; social media networks; joint marketing partners |
|
Geolocation Data |
Advertising networks; data analytics providers; social media networks; joint marketing partners; website operation provider |
|
Sensory Data (foot assessment from our Custom Fit Kiosk, lifestyle questions, and shoe size) |
Retail and distribution providers; advertising networks; data analytics |
Our use of third-party advertising cookies and sharing of personal identifiers with advertising partners for targeted advertising and lookalike audience purposes may constitute a “sale” of personal data and/or processing for “targeted advertising” under applicable state privacy laws. You have the right to opt out of such processing as described below.
RETENTION OF PERSONAL DATA
We retain your personal data for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
YOUR RIGHTS
Depending on your state of residence, you may have some or all of the following rights under applicable state privacy law:
Right to Access/Know
You have the right to confirm whether we are processing your personal data and to access the specific personal data we hold about you, including the categories and specific pieces of personal data collected, the categories of sources, the purposes for processing, and the categories of third parties to whom we disclose it.
Right to Delete
You have the right to request that we delete personal data we have collected from or about you, subject to certain exceptions provided by law. Please note that we may retain certain information, such as order history, as necessary to maintain records of past transactions or to comply with legal obligations.
Right to Correct
You have the right to request correction of inaccurate personal data we maintain about you, taking into account the nature and purposes of the processing. This right is available in all states listed above except Iowa and Utah.
Right to Data Portability
You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
Right to Opt Out of Sale
You have the right to opt out of the “sale” of your personal data. As described above, certain disclosures to advertising partners may qualify as a sale under applicable state law. You may exercise this right by completing the privacy request form on our Site or by contacting us using the information in the “Contact Us” section below. Please note that the definition of “sale” varies by state, some states require monetary consideration while others include any valuable consideration.
Right to Opt Out of Targeted Advertising
You have the right to opt out of the processing of your personal data for purposes of targeted advertising. This right is available in all states listed above except Utah. You may exercise this right by completing the privacy request form on our Site, by contacting us, or by using a universal opt-out mechanism (such as Global Privacy Control) where recognized by applicable law.
Right to Opt Out of Profiling
You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. This right is available in most states listed above (it is not available in Iowa or Utah). We do not currently engage in profiling that produces legal or similarly significant effects.
Right to Non-Discrimination
We will not discriminate against you for exercising any of your privacy rights. This means we will not deny you goods or services, charge different prices, provide a different level or quality of services, or suggest that you may receive different treatment because you exercised your rights.
Sensitive Data
Most state privacy laws require that we obtain your opt-in consent before processing sensitive personal data (which may include data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data, children’s data, and precise geolocation data). Utah requires only an opt-out mechanism for sensitive data processing. Maryland prohibits the sale of sensitive data entirely. We do not knowingly process sensitive personal data except as necessary to provide our services and in compliance with applicable law.
Universal Opt-Out Mechanisms
Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Nebraska, Minnesota, and Maryland require that businesses recognize universal opt-out mechanisms, such as the Global Privacy Control (GPC) signal. If your browser or a browser extension sends a GPC or similar universal opt-out signal, we will treat that signal as a valid request to opt out of the sale of personal data and targeted advertising for that browser and device.
HOW TO SUBMIT YOUR REQUEST
To exercise any of the rights described above, you may submit a verifiable consumer request by:
· Completing the privacy request form available on the Site;
· Emailing us at drscholls.care@drscholls.com; or
· Calling us at 866-360-3226, Monday through Friday, 9AM–5PM Central Standard Time.
When you submit a request, we will take steps to verify your identity before processing your request. We will collect your name, email address, and state of residence to verify your identity. We endeavor to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require additional time (up to an additional 45 days), we will inform you of the reason and the extension period in writing.
Some states permit you to designate an authorized agent to submit a request on your behalf. If you use an authorized agent, we may require that you provide the authorized agent with written permission to act on your behalf and that you verify your own identity directly with us.
RIGHT TO APPEAL
If we decline to take action on your privacy rights request, you have the right to appeal our decision. Most state privacy laws (including those of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island) require that we provide a mechanism for you to appeal a denial of your request.
To submit an appeal, please contact us at drscholls.care@drscholls.com with the subject line “Privacy Rights Appeal” or call us at 866-360-3226. Please include your original request and the reason you believe the denial was in error.
We will respond to your appeal within the timeframe required by applicable law (generally 60 days). If your appeal is denied, we will provide you with information on how to contact the attorney general in your state (or other applicable regulatory authority) to submit a complaint, including:
· Virginia: Office of the Attorney General, https://www.oag.state.va.us
· Colorado: Office of the Attorney General, https://coag.gov
· Connecticut: Office of the Attorney General, https://portal.ct.gov/AG
· Texas: Office of the Attorney General, https://www.texasattorneygeneral.gov
· Oregon: Department of Justice, https://www.doj.state.or.us
For other states, we will provide the applicable contact information in our appeal response.
CONTACT US
If you have any questions or comments about this Notice or our privacy practices, please contact us using the below referenced contact information:
Scholl’s Wellness Co.
Consumer Affairs
138 E. Main St.
Suite 201
Kent, OH 44240
Email: drscholls.care@drscholls.com
Phone: 866-360-3226 Monday through Friday 9AM-5PM Central Standard Time