Privacy Policy

Footwear Industries Ireland Ltd (Company Registration No: 789613) (“Steel Blue”, “we” or “our” or “us”) is committed to respecting your personal data .

This Privacy Policy explains how we handle our (prospective) clients personal data that we process through the following channels (here and after, each a Collection Channel):

• our online properties (here and after, each a Website) , including;

• our websites, including, but not limited to, www.steelblue.com and www.howlerboots.com;

• any related Steel Blue website, social media page, internal website, intranet and any Steel Blue mobile or tablet applications;

• any website, social media page, internal website, intranet, and any mobile or table applications relating to any Steel Blue product or range as may exist from time to time as stated on www.steelblue.com, www.howlerboots.com or elsewhere; and

• any other means through which an individual provides personal data to Steel Blue, including either physically or electronically.

SUMMARY FOR USERS

Steel Blue respects your privacy and is committed to protecting your personal data. Here’s what you need to know:

1. What we collect:

We may collect your name, contact details, purchase history, preferences, and any other information you provide, including sensitive information if you choose to share it.

2. How we use your data:

Your data may be used to:

• Process orders and provide products or services;

• Communicate with you about your account, purchases, promotions, or events;

• Improve our products, services, and Website;

• Comply with legal obligations.

3. Legal basis (for EU/EEA users):

We process your data based on contract, legal obligation, consent, or legitimate (business) interests.

4. Sharing your data:

We may share your data with trusted third parties like payment processors, delivery services, and IT providers. We never sell your personal information.

5. Your rights:

You have the right to access, correct, delete, or restrict the processing of your data. EEA users also have rights to data portability, objection to processing, and to lodge complaints with a data protection authority.

6. Cookies and tracking:

We use cookies and tracking technologies to improve your experience. You can manage your preferences in your browser or on our website.

7. Security:

We take appropriate measures to protect your data from misuse, loss, or unauthorized access.

8. Contact us:

For questions or to exercise your rights, contact our Privacy Officer. Please allow 30 days for any request to be processed.

PERSONAL DATA IS IMPORTANT TO STEEL BLUE

1. Steel Blue is committed to safeguarding personal privacy. It recognises that you have a right to control how your personal data is collected and used. Providing personal data is an act of trust and it is taken seriously. Unless given consent to do otherwise, Steel Blue will only collect and use personal data as set out below.

2. Throughout this Privacy Policy, we refer to your 'personal data', which means information or data which identifies you as an individual or which renders you reasonably identifiable. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal data. Personal data may also include information we may collect about your individual preferences or cultural or social identity.

3. Steel Blue has developed and implemented its Privacy Policy with respect to personal data to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the General Data Protection Regulation (EU) 2016/679 (GDPR).

4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time. If material changes are made to this Privacy Policy, we will notify you via email (if available) or by displaying a banner on our website(s).

• For users outside the European Economic Area (EEA ): Your continued use of our Collection Channel(s) after such changes indicates your acknowledgment of and agreement to the updated Privacy Policy.

• For users within the EEA: If the changes affect processing based on your consent or introduce new types of processing, we will obtain your explicit consent before applying the changes. For other updates, continued use indicates acknowledgment of the updated Privacy Policy.

5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

ANONYMITY AND PSEUDONYMITY

6. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below.

ACCOUNTABILITY AND PROTECTION

7. With the principle of accountability as a starting point, Steel Blue always acts in accordance with the GDPR. Steel Blue carries out its duties with the utmost care and also takes appropriate technical and organizational measures to secure personal data against loss, misuse, unauthorized access, and unlawful processing.

8. In the case of a personal data breach that is likely to result in a risk to the rights and freedoms of natural persons, Steel Blue will without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with the GDPR. Furthermore, if the above-mentioned case occurs Steel Blue will communicate the personal data breach to the data subject without undue delay.

KINDS OF PERSONAL DATA THAT STEEL BLUE COLLECTS AND HOLDS

9. Personal data that may be processed includes:

• contact information such as your full name, telephone number, mobile telephone number, current and valid email address, residential address, region, suburb and postcode;

• your gender;

• testimonials about our products or services;

• complaint details;

• information regarding your employment including your company;

• information about your employment history and future plans, and documents relating to your employment;

• information regarding your education and qualifications;

• information about your experience with our products or services or third party products or services listed on a Website. This information is requested in order to tailor our subsequent communications to you and continuously improve our products and services;

• the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Steel Blue and used for the purposes set out in this policy (which may include using their details for marketing purposes);

• Information obtained via cookies regarding your browsing behaviour, and

• any other personal data which you provide directly to Steel Blue. Where you provide us with unsolicited personal data, we will retain this information where it falls within our primary purposes for collection of personal data (as stated in this Privacy Policy).

SENSITIVE INFORMATION

10. “Sensitive information” includes personal data regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life, or criminal record, or other information which might cause harm to its owner if inadvertently released into the public domain or to an unauthorised third party.

11. Steel Blue only collects sensitive personal data when you voluntarily provide us with this information and consent to its use, or where such information is required or permitted to be collected by law. Where you provide us with any sensitive information in connection with what is requested by a Collection Channel, we will only use this information for the purposes stated on the Collection Channel. We do not retain this information in our database.

12. Please use your discretion when providing sensitive information to Steel Blue, and under any circumstances, do not provide sensitive information to Steel Blue, unless you thereby consent to Steel Blue’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in Steel Blue’s databases and the databases of its advisors and contractors.

13. Please note that Steel Blue only ordinarily receives sensitive personal data from employees for occupational health and safety purposes, and is therefore not intended to collect sensitive personal data through other channels such as social media or general enquiries. If sensitive personal data is nevertheless provided, Steel Blue will handle it in accordance with applicable privacy laws. If you have any questions about whether the provision of sensitive information to Steel Blue is, or may be, necessary or appropriate for particular purposes, please contact [email protected].

HOW STEEL BLUE COLLECTS AND HOLDS PERSONAL DATA

14. Steel Blue’s Collection Channels will only process any personal data about you, which may have been provided to us lawfully by third parties, as provided in this Privacy Policy. Personal data is processed through either active or passive information collection.

15. No one is obligated to provide personal data. However, failure to do so may result in Steel Blue being unable to facilitate or provide you with certain content, products or services, products or services information, upcoming promotion, competition, offer or event information or accept competition entries (where applicable).

ACTIVE INFORMATION COLLECTION

16. Personal data may be collected (and combined) via our Collection Channels if you:

• have previously provided us with personal data prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;

• sign-up and/or register to become a member of any Collection Channel;

• purchase a product or make an order via a Collection Channel;

• subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;

• complete and submit any forms to us;

• contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;

• participate in any offers, promotions or marketing activities;

• provide us with any testimonial;

• interact with a Website for a specific purpose; or

• interact with or browse a Website generally.

PASSIVE INFORMATION COLLECTION

17. We may use passive information collection and tracking technologies in HTML emails that we send to our visitors for a number of purposes including: to determine whether our visitors have opened or forwarded those emails and/or clicked on links in those emails; to customise the display of banner advertisements and other messages after a visitor has closed an email; and to determine whether a visitor has made an enquiry or a purchase in response to a particular email.

18. We may also use cookies and other tracking technologies for passive data collection. We use cookies on our Collection Channels (websites, apps, and social media) to improve your experience, remember preferences, and analyze usage.

19. We use the following types of cookies:

• Essential: Necessary for website functions like login and shopping cart.

• Performance: To help us improve site performance and user experience.

• Functional: To remember your preferences, like language or region.

• Marketing/Advertising: Track interactions for personalized promotions.

• Third-party cookies: Some cookies are set by trusted providers for analytics, advertising, or social media.

20. For individuals located in the European Economic Area (EEA), non-essential cookies will only be placed after obtaining your consent. You may withdraw your consent at any time using our cookie management tool or by adjusting your browser settings.

21. You can manage, block, or delete cookies through your browser settings or device preferences. Please note that disabling cookies may affect the functionality of our Collection Channels.

22. For a detailed list of cookies used on our Collection Channels and their purposes, please visit [website] or the relevant cookie page on any of our Collection Channels.

PURPOSES FOR WHICH STEEL BLUE COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL DATA

23. Personal data is processed on one or more of the following legal bases:

• to perform a contract: For example, if you order a pair of Steel Blue boots online, we process your name, address, payment details, and order history to fulfill your order. Without this processing, the contract (sale and delivery of products) cannot be completed.

• to comply with legal obligations: For example, we maintain records of sales, employee information, and tax details to comply with applicable laws, such as tax regulations or employment laws.

• for Steel Blue’s legitimate business interests: For example, we may analyze purchase patterns to improve our products, tailor promotions, or enhance our websites and services. This processing balances our business interests with your privacy.

• based on your consent (where required): For example, if you subscribe to our newsletter, we process your email address to send marketing communications, but only because you have explicitly consented. You can withdraw this consent at any time.

24. Personal data is requested in order to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), marketing materials, newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Steel Blue or third party products, services, offers, competitions or events which may be of interest.

25. Personal data collected will be used for the following primary purposes:

• For the purposes for which it was collected, such as the fulfillment of your orders.

• For the purposes stated in a privacy collection statement on a particular Collection Channel.

• To fulfil obligations in respect of any upload terms of use, sale and purchase contract and/or any other contract between you and Steel Blue;

• To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), content, services and products, to provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.

• To maintain our relationship with you.

• To render services related to Steel Blue (such as enquiries).

• To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.

• To respond to customer enquiries and/or complaints;

• To obtain opinions or comments about products and/or services.

DATA SHARING AND DISCLOSURE

26. For the purposes described above, personal data may be shared with Steel Blue group companies, Steel Blue promotional partners and other trusted third parties (and their directors, servants and agents) either in the EU, Australia or elsewhere. Failure to provide personal data may result in Steel Blue being unable to provide you with certain content, information, upcoming promotion, event or product information and/or accept promotion entries (where applicable).

27. In order to operate a Website or deliver a service (including for example, processing of credit card payments or delivery of promotions), personal data may also be shared with Steel Blue group companies, selected service providers and/or other trusted third parties either in the EU, Australia or elsewhere. Steel Blue group companies, selected service providers and/or other trusted third parties may be engaged by Steel Blue to perform a variety of functions, such as data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our Websites. These companies may have access to personal data if needed to perform such functions.

28. Steel Blue recognises the trust with which you provide personal data, and except as stated in this Privacy Policy, such information will not be used or disclosed for any other purposes without your consent. However, Steel Blue reserves the right to use or disclose any information, including personal data, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Steel Blue, any member of the Steel Blue group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

29. In some cases, Steel Blue may disclose your personal data to overseas recipients. Where required by applicable data protection laws, Steel Blue will take steps to ensure that personal data transferred overseas is protected. Steel Blue employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal data held by Steel Blue. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Steel Blue will not be held responsible for events arising from unauthorised access to personal data.

CHILDREN

30. Personal data will not be collected by any person who is known by Steel Blue to be under the age of fifteen (15) without the consent of a parent or legal guardian. Persons under age fifteen (15) may only use our Websites with the involvement and consent of a parent or legal guardian.

ABILITY OF OTHERS TO VIEW INFORMATION

31. Steel Blue may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. Steel Blue is not responsible for the conduct of others who may read, collect and use this information.

YOUR RIGHTS

32. You have the right to access and review your personal data that may be recorded on the Steel Blue database. Information may be reviewed by contacting Steel Blue’s privacy officer via email: [email protected] or telephone: 08 9209 3322. Please allow 30 days for this request to be processed.

33. If you are located in the European Economic Area (EEA), you may also have the right to withdrawn your consent, restrict processing of your personal data, request data portability, object to certain types of processing (including direct marketing), and not be subject to automated decision-making where it produces legal or similarly significant effects. You may exercise your rights by contacting Steel Blue’s privacy officer via email: [email protected] or telephone: 08 9209 3322. Please allow 30 days for any request to be processed. In addition, you may have the right to lodge a complaint to with your local data protection supervisory authority.

CHANGING AND DELETING THE INFORMATION WE HAVE ABOUT YOU

34. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting Steel Blue’s privacy officer via email: [email protected] or telephone: 08 9209 3322. Please allow 30 days for this request to be processed.

35. In the same way, a request may be made to delete personal data, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in Steel Blue being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.

36. We are not responsible for removing your personal data from the lists of any third party who has previously been provided your information in accordance with this policy.

STORAGE AND SECURITY OF PERSONAL DATA

37. Steel Blue will endeavour to take all reasonable steps to keep secure any personal data recorded (including your credit card details), and to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases, these facilities may be overseas.

STEEL BLUE AND LINKS TO OTHER WEBSITES

38. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third-party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Steel Blue is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.

RELATED STEEL BLUE WEBSITES

39. All Websites operated by Steel Blue will adhere to this Privacy Policy.

SALE OF THE COMPANY

40. If Steel Blue merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal data may be disclosed to our advisers and any prospective purchaser’s adviser and may be among the assets transferred. The foregoing applies only to the extent that such disclosure is in compliance with this Privacy Policy.

CONTACT BY STEEL BLUE

41. Steel Blue group companies (and their directors, servants and agents), Steel Blue promotional partners or trusted third parties (and other selected service providers and other non-Steel Blue companies or professionals) either in the EU, Australia or elsewhere, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal data as stated above.

42. Steel Blue may send advertising or marketing information in accordance with this Privacy Policy. If you receive communications from Steel Blue which you do not wish to receive, you may remove your name from the database either by utilising the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting Steel Blue via email: [email protected] or telephone: 08 9209 3322. Please allow 30 days for this request to be processed.

PROBLEMS OR QUERIES

43. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal data, please contact our privacy officer via one of the following channels:

44. Please allow 30 days for this request to be processed. If you do not receive a satisfactory response from Steel Blue to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page.

45. If you are located in the European Economic Area (EEA), you may have the right to lodge a complaint with your local data protection supervisory authority.

Last revised: April 30, 2026.