Privacy Notice

This Privacy Notice is provided by Clarks Americas, Inc., C. & J. Clark America, Inc. and C. & J. Clark Retail, Inc., including each of its parent companies, subsidiaries and affiliates, (collectively “Clarks”, “Company,” “we”, “us”, “our”) to our current and former staff (“Employees”), job applicants, contractors, temporary or agency workers, occasional workers, freelancers, volunteers and apprentices working in any of our facilities who are residents of the United States (“you”, “yours”). This Notice describes the categories of personal information that we collect and their purposes for use in the course of your engagement with us.

For the purpose of this Notice only, contractors, temporary or agency workers, occasional workers, freelancers volunteers and apprentices are referred to collectively as “Contingent Workers” and their engagement may be included in references that use the term “employment” although they do not meet the definition of employees any purpose and as defined by the Company. Nothing in this Notice shall be interpreted to create a relationship of employment where one does not otherwise exist at law.

Categories and Types of Personal Information We Collect
We may collect the following categories and types of personal information:

• Contact Information: your first and last name, postal address, email address, and phone number;
• Other identifying information: social security number, drivers’ license number or state identification card number, passport number, other identification provided for I-9 purposes, IP address, passwords and other security information for authentication and access, medical information, signature;
• Financial Information: bank account information;
• Demographic information: gender, ethnicity, age, marital status;
• Geolocation data: badge swipes at offices and device tracking;
• Data related to internet, device/phone, IP address, or other electronic activity: your email, browsing and click history, including information about how you navigate the internet;
• Employment information: Resume/CVs, cover letters, employment history and education, notes from employment interviews, membership in professional organizations, professional certifications; and
• Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude
• Criminal record/history.

Categories of Use
We use your personal information for the following purposes.

• Employment Purposes: We use your contact information, financial information, and commercial information to:
  • Recruit and hire you
  • Determine eligibility to work
  • Employ you
  • Perform investigations and background checks
  • Provide HR services
  • Provide payroll and benefits
  • Perform performance evaluations
  • Provide discipline
• Analytical Purposes: We use your other identifying information, internet activity and browsing history, demographic information, and geolocation data to analyze preferences, trends and statistics.
• Maintenance and Improvement of Services: We use your contact information, and internet activity and browsing history to monitor and improve the services we provide to you
• Security and Fraud Prevention: We use your contact information, other identifying information, financial information, employment information, geolocation data, internet activity and browsing history, and inferences to protect you, our company, and others and property and to prevent fraud, theft and misconduct.
• Legal: We use your contact information, other identifying information, financial information, geolocation data, internet activity and browsing history, and inferences to:
  • Comply with our legal obligations
  • Defend our company in and protect our company, property, and others through legal proceedings
• Corporate Transactions: We use your contact information, other identifying information, financial information, employment information, geolocation data, internet activity and browsing history, and inferences to complete a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information is among the assets transferred.

Questions?
If you have any questions about this Notice, please contact privacy@clarks.com.

Last Updated: June 26, 2024