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APPLICANT PRIVACY POLICY

Last Updated: 16 May 2018

Gap, Inc. and our family of brands (Athleta, Banana Republic, Banana Republic Factory Stores, babyGap, Gap, GapKids, Gap Factory, Gap Outlet, Intermix, Weddington Way and Old Navy) and our global companies, affiliates and subsidiaries (together “Gap", "we", or "us") value your trust and are committed to the responsible management, use, and protection of personal information.

This Applicant Privacy Policy ("Policy") covers any personal information we collect when you apply or search for a position at Gap. Specifically, it describes our practices in connection with the information that we collect through our recruiting process. Such information may be collected through our recruiting website (http://www.gapinctalent.com) and other recruiting webpages, mobile sites, or recruiting processes, which we operate, and in which we post or provide a link to this Policy (“Careers Site(s)").

Personal information submitted elsewhere on Gap's web sites will be used in accordance with our general online Privacy Policy.

PERSONAL INFORMATION WE COLLECT

Information You Provide

Our Careers Site is designed to help you find and apply for job openings at Gap's global locations and guide you through the various steps of our recruitment and onboarding processes. You can generally navigate our Careers Site by providing us with little personal information, but if you choose to register for the Careers Site, apply for a position, interact with the Careers Site's features and/or take advantage of the Careers Site's many benefits, we will receive additional types of personally identifiable information.

If you apply through the Careers Site as part of the job application or job search process, the following information may be collected:

  • Name, and contact information;
  • Date of birth;
  • Account login information, such as your username and password;
  • National Insurance number or Tax Reference,;
  • Employee ID numbers and information about your work history with Gap, if you are an existing and/or former Gap employee, and any previous applications for employment with Gap;
  • Eligibility to work in country where job applied for is located, notice period, planned holidays, and available start date;
  • CV, résumé, cover letter, other supporting documents you submit, previous work experience, and education information;
  • Employment preferences, willingness to relocate, current salary, desired salary, and how you heard about the Careers Site;
  • Language and other relevant skills, motivations, and experience;
  • Professional and other work-related licenses, permits, visas, and certifications held;
  • Demographic information and marital status;
  • Awards and professional memberships;
  • Information relating to references;
  • Information from third party sites and social media platforms such as LinkedIn;
  • Details of your job search, including what roles, departments, and locations interest you; and
  • Any other information you elect to provide to us.

The information we request as part of the recruitment process may vary by job location and may change from time to time to facilitate our local offices and retail stores with their recruitment needs, and abide by local legal and regulatory requirements.

As discussed in the "Diversity" section below, in certain cases we will ask questions about race/ethnic origin, gender, and disability of our applicants, for monitoring equal opportunity. We can also inquire about criminal records, and will do so only where permitted by applicable law. Otherwise, we ask that you avoid submitting information which may qualify as sensitive information under applicable law, except where such information is legally required. Sensitive information includes race, religion, ethnicity, nationality or national origin, age, gender identity, sex life or practices or sexual orientation, marital status, medical or health information (including disability status), genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, veteran status, background check information, and judicial data such as criminal records or information on other judicial or administrative proceedings.

Any information you submit through the Careers Site must be true, complete and not misleading. Should the information provided be inaccurate, incomplete, or misleading, subject to applicable law, this may lead to a rejection of your application during the application process or disciplinary action up to and including immediate dismissal if you have been employed. In addition, it is your responsibility to ensure that information you submit does not infringe on any third party's rights and is not otherwise legally actionable by such third party.

If you intend to provide us with details of a reference or any other third party as part of your CV/résumé, it is your responsibility to obtain consent from that third party prior to passing their personal information to us.

Information from Other Sources

For the purpose of background check reports in connection with your application, and as permitted by applicable law, Gap may obtain information about you from other sources:

Other sources may include:

  • Your references;
  • Prior employers;
  • Educational institutions you attended;
  • Social media platforms including employment networking and recruiting websites and services.

USE OF INFORMATION

We collect and process information about you for one or more of these reasons:

  • Because you voluntarily provide this information and consent for us to process it;
  • Because this information is necessary to take steps at your request prior to entering into employment or an internship;
  • Because this information is of particular importance to us and we have a specific legitimate interest under law to process it;
  • To comply with a legal obligation; or
  • Where necessary to protect the vital interests of any person.

Where the collection or processing is based on your consent, you may withdraw your consent at any time to the extent permitted by applicable law. If you wish to do this, please email us at privacy@gap.com or write us at the address in the "Contact Us" section below.

The information that you submit on the Careers Site will be used for Gap's global personnel recruitment, management and planning purposes, as permitted by applicable law:

  • To allow you to register with the Careers Site and use its features, to allow you to search and apply for jobs at Gap locations, to manage your account, to tailor and improve the Careers Site and experiences to better suit your needs and the needs of our community, and to process your application. We may also provide you with recommendations about open positions which may interest you based upon your past searches and/or job applications. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
  • To assess your capabilities and qualifications for a job. We will engage in these activities to manage our prospective contractual relationship with you, based on our legitimate interests;
  • To conduct reference checks including collecting right to work information. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
  • To communicate with you and provide you with updates on the recruitment process, information you requested and information about Gap, to provide you with a job offer or an employment agreement, assist with any contract finalization and execution, to help you to register for Gap employment benefits, and to send you information regarding the Careers Site and changes to our terms and policies. We will engage in these activities to manage our prospective contractual relationship with you or based on our legitimate interests;
  • To comply with or monitor compliance with any applicable law or regulation. We will engage in these activities to comply with a legal obligation or based on our legitimate interests;
  • To conduct background checks if we offer you a position, as permitted by applicable law. We will engage in these activities to comply with a legal obligation or based on our legitimate interests; and
  • To preserve our other legitimate interests, for example, for Gap's administrative purposes, aggregate management reporting, documenting Gap's global recruitment goals, internal training, to manage, evaluate and improve Gap's recruiting and onboarding tools and processes, to protect the security and stability of the Careers Site, and as generally required to conduct our business within Gap and its affiliates.

The information about you will be added to Gap's international candidate database and may be retained and used to consider you for opportunities at Gap and its affiliates other than the one(s) for which you apply. If you do not wish us to do this, please email us at privacy@gap.com or write us at the address in the "Contact Us" section below.

If we elect to make you an offer, personal information you submit may be incorporated into our human resources system and used to manage the new-hire process. If you become an employee, any personal information that you submit may become part of your employee file and may be used for other employment/work-related purposes.

The provision of personal information on this Careers Site is voluntary. Please note, failure to provide sufficient information, however, may result in Gap being unable to consider your employment application or, if employment is offered, your subsequent promotion, transfer or relocation.

DISCLOSURE AND TRANSFER OF INFORMATION

In order for us to assist you with your job search needs through the recruitment and hiring process, and also to assist with managing our global workforce, we may share your information with affiliates that are involved in evaluating candidates for a given position. Gap, Inc. will remain responsible for personal information that is jointly used with affiliates. You can consult the list and location of our affiliates here.

We will limit access to personal information to personnel with a business need to know the information for the purposes described in this Policy, including personnel in the recruiting, human resources and information technology departments, and in the department responsible for the position for which you are applying.

Gap also shares personal information with our third-party service providers to facilitate services they provide to us, including hosting and operating the Careers Site, recruiting assistance, and background check processing. Third party service providers receiving personal information are expected to keep confidential the personal information received from us and not use it for any purpose other than to provide their services to us.

Disclosing your personal information can include transferring personal information to other countries, including the United States or any other country in which we or our service providers have operations. If you are located in the European Economic Area (the "EEA") this may include countries outside of the EEA. Some of these countries are recognized by the European Commission as providing an adequate level of protection according to EEA standards (the full list of these countries is available here. As for transfers to other countries, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your information. You may obtain a copy of these measures by contacting us at privacy@gap.com or write us at the address in the "Contact Us" section below.

OTHER USES AND DISCLOSURES OF INFORMATION

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law.
    • This can include laws outside your country of residence.
  • To respond to requests from public and government authorities.
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • For example, when we receive law enforcement requests and orders.
  • For other legal reasons.
    • To enforce our terms and conditions;
    • To protect the rights, privacy, safety or property, of Gap, its employees, agents, contractors and/or you or others, such as visitors to our web sites or other properties;
    • To permit us to pursue available remedies or limit the damages that we may sustain.
    • To permit us to pursue available remedies or limit the damages that we may sustain.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)

DATA RETENTION

We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods are: (i) the duration of the application process; (ii) as long as we have an ongoing relationship with you; (iii) as required by a legal obligation to which we are subject; (iv) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations); and (v) as required by published records retention schedules.

We may remove personal information for inactive accounts from our database, subject to any applicable legal or regulatory obligations. Furthermore, Gap can delete personal information about you (including your CV/résumé) from our database at any time and without providing any reason. Therefore, please retain your own copy of the personal information provided to us.

PASSIVE INFORMATION COLLECTION: COOKIES AND SIMILAR TECHNOLOGY

Like most websites, the Careers Site collects and/or logs internet protocol addresses, internet domain names, information about the web browser and operating system used to access our sites, your location, details about the pages you visit and the features you use, and the date and time of each visit.

Additionally, we and our service providers use cookies on some of our sites. Information collected by cookies (as described below) may be tagged to your personal information, including your contact information, device information, login information, and other personal information we receive from you.

Cookies are small amounts of data sent to your browser from a web server and stored on your computer's hard drive. Cookies can help a website recognize repeat users and allow the site to track web usage behavior. Cookies are useful because they allow a website to recognize a user's device and may be used in a variety of way to enhance and/or personalize your online experience. For example, we may use cookies to enable you to use certain website features, store your preferences, recognize you when you return to our site, enhance the security of our site, and to understand the aggregated demographic and traffic data of our site visitors.

You can set your browser to notify you when you are sent a cookie, and you may also elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of the website. For more information on how to adjust your browser settings to reject cookies or generally to learn more about cookies, please visit: http://www.allaboutcookies.org/manage-cookies. We do not currently respond to browser do-not-track signals.

CHOICES AND ACCESS

If you choose to register with the Careers Site, you may access, review, and change your personal information stored therein by logging into the Careers Site and updating your account information. The updated profile will be used as the default the next time you apply for a job using your account online. Please note that our recruitment teams may have the ability to see all the history of changes that you may make in your own profile. To change personal information that you have already submitted for consideration for a specific position, please edit your application for that position and include the updated personal information about you in the application. We encourage you to promptly update your personal information if it changes or is inaccurate. Upon your request, we will deactivate or remove your personal information from our active databases, although some information may be retained as permitted by law.

If you would like to subscribe or unsubscribe from, notifications about Gap recruitment activities, including notifications about jobs which may interest you, please go to gapinctalent.com, and log into your candidate profile, entering the credentials used when setting up your user account. To subscribe/unsubscribe from job notifications, access "My Account Options." The job notifications are located in the correspondence section. After checking or unchecking the box, click save.

You may, where permitted by applicable law, request to review, access, correct, update or delete your personal information; request that we cease using your personal information as permitted by applicable law; or request a copy of your personal information. You also have the right to provide instructions regarding the processing of your personal data in the event of your death. Please make your request by contacting us at privacy@gap.com or writing us at the address in the "Contact Us" section below. We will respond to your request consistent with applicable law.

In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you have provided to us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your personal information.

For your protection, we only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. Please note that certain personal information may be exempt from such requests pursuant to applicable data protection laws or other laws and regulations.

SECURITY

We are committed to taking reasonable efforts to secure the personal information that we receive from you. We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at privacy@gap.com or write us at the address in the "Contact Us" section below.

Gap hereby disclaims, as far as permitted by local laws, any liability for itself and its affiliates and contractors for any personal information we collect in connection with your application that is lost, misused, illegally accessed, disclosed, altered or destroyed or not integrally or timely delivered to our Careers Site.

LINKS TO THIRD-PARTY WEBSITES AND SERVICES

We may provide links to third-party websites for your convenience and information. If you access those links, you will leave Gap's websites. We do not control those sites or their privacy practices, which may differ from the terms of this Policy. We do not endorse or make any representations about third-party websites. The personal information you choose to give to unrelated third parties is not covered by this Policy. We encourage you to review the privacy notices and practices of any company before submitting your personal information. Some third-party companies may share personal information with Gap, that sharing is governed by that third-party company's privacy statement.

DIVERSITY

Gap is an equal opportunity employer, which means we offer equal treatment to all applicants. Gap does not discriminate, either directly or indirectly, on protected grounds, which include: race, sex, gender identity, sexual orientation, nationality, national origin, ethnic origin, religion, beliefs or creed, age, disability, marital status, veteran status, or genetic information, in any area of recruitment.

FORUMS, BLOGS AND SOCIAL MEDIA

Parts of our sites are designed to help you share your job opportunities with your friends, family and contacts who may be interested. You can use our sites to share content and opportunities through a variety of channels, including email and your personal social media accounts. Any information that is disclosed through these channels may become public information which could be read, collected or used by other users on a worldwide basis. You should exercise caution when deciding to disclose your personal information with others.

Additionally, our Careers Site may enable you to link your online application to certain social media platforms (such as LinkedIn) to enable you to auto-populate your online application with personal information taken from your relevant social media profile. Please note that you are wholly responsible for the content of any online application which you make via this Careers Site and it is your responsibility to ensure that any errors arising out of auto-population of online application fields are corrected. Similarly, it is your responsibility to ensure that any fields which are not auto-populated by such functionality are correctly completed. As described above in the Section "Links to Third-Party Websites and Services," we do not control the terms or privacy policies of third-party websites.

At your request, we may collect, store and/or share personal information about other people which you provide to us through the sites, including name, demographic information and/or their contact information. If you share personal information about others, you are responsible for ensuring that you have the proper authorization to use and share those persons' personal information.

LAW APPLICABLE TO JOB APPLICATION

The Careers Site allows you to apply for jobs world-wide, as a benefit of Gap's centralized global recruitment function. This Careers Site is operated from the United States. Accordingly, any personal information you submit to the Careers Site will be collected in the United States and will be subject to U.S. laws. However, if we share your personal information with an affiliate located in another country in its capacity as a potential employer, the affiliate will handle your personal information in accordance with this Policy. Any hiring or other employment-related decisions will be made by the hiring affiliate in accordance with the laws of the country where the job will be located.

ABOUT CHILDREN

The Careers Site is not targeted toward children under the age of 16, nor do we knowingly collect information directly from children under the age of 16.

CURRENT PERSONNEL OF GAP

If you currently work for Gap or one of our affiliates, you must be eligible to apply for a different position within Gap to use the Careers Site. If you accept such a position, your benefits programs and Human Resources policies may change. Please consult with the HR manager for the new position concerning application eligibility, benefit programs, and HR policies applicable to that position.

The Careers Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation.

CHANGES TO THE POLICY

We reserve the right to amend this Policy at any time in order to address future developments of Gap, the Careers Site or changes in industry or legal trends. The "Last Updated" legend at the top of this Policy indicates when this Policy was last revised. Any changes will become effective when we post the revised Policy on the Careers Site.

CONTACT US

For questions or concerns about the issues discussed in this Policy; or to report violations of this Policy please contact us at privacy@gap.com or Gap Inc., Legal Department, 2 Folsom Street, San Francisco, CA 94105.

You may also lodge a complaint with a Data Protection Authority for your country or region or in the place of the alleged misconduct.

Because email communications are not always secure, please do not include sensitive information in your emails to us.