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 * California Notice


CALIFORNIA NOTICE

California Notice

Effective Date: July 1, 2023

Version 5.0

California Consumer Privacy Act of 2018 (CCPA) / California Privacy Rights Act
of 2020 (CPRA)

California residents have the following rights under the CCPA/CPRA:

 * Right to Know and Access. You have the right to confirm whether or not we are
   processing your personal information and to know what personal information
   the business has collected about you. While our table in section 7.h. below
   describes the personal information we collect about you, you have the right
   to make a request to know and get access to information that is specific to
   you, should we have any.
 * Right to Delete. You have the right to request that we delete personal
   information we have collected from you or obtained about you, subject to
   certain exceptions. For example, we will not delete any personal information
   required to provide our existing services to you or that we must maintain to
   comply with our legal/financial obligations.
 * Right to Correct. You may request that we correct inaccurate information we
   maintain about you, subject to some exceptions and, if necessary, independent
   verification.
 * Right to Opt-Out of the Sale/Sharing. If we have sold or shared personal
   information about you, you have the right to opt out of the sale or sharing
   of that personal information.
 * Right to Non-Discrimination. You have the right not to be discriminated
   against if you exercise any of these rights.  Please note that a legitimate
   denial of a request to know or access, delete, correct, or opt out is not
   discriminatory, nor is charging a fee for excessive or repetitive consumer
   requests as permitted by the CCPA/CPRA.

To exercise the rights applicable to you, see instructions below in section How
to Exercise Your Privacy Rights.

Authorized Agent:

You may designate an authorized agent to exercise your rights under the
CCPA/CPRA on your behalf. You must provide the authorized agent written
permission to exercise your rights under the CCPA/CPRA on your behalf and we may
deny a request from an agent on your behalf if we cannot verify that they have
been authorized by you to act on your behalf. Even if you use an authorized
agent to exercise your rights under the CCPA/CPRA on your behalf, pursuant to
the CCPA/CPRA we may still require that you verify your own identity directly to
us. This provision does not apply if you have provided a power of attorney under
the California Probate Code.

Opt-Out Signal:

An opt-out preference signal may be sent by certain platforms, technologies, or
mechanisms on your behalf to communicate your choice to opt out of the
sale/sharing of your personal information.  Opt-out preference signals will opt
you out of the selling/sharing of personal information at the browser level.

Metrics:

The following section describes consumer rights submission metrics for requests
we received from January 1, 2022 through December 31, 2022 for Company business
units (not limited to California residents):

Disclosure Requests

Number of Requests Received

13

Number of Requests Denied

0

Number of Days to Resolve Requests (Mean)

43

Deletion Requests

Number of Requests Received

116

Number of Requests Denied

0

Number of Days to Resolve Requests (Mean)

32

Do Not Sell My Personal Information Requests

Number of Requests Received

3533

Number of Requests Denied

0

Number of Days to Resolve Requests (Mean)

8

Minors:

We do not knowingly share or sell the Personal Information of children under 16
years of age.

Notice of Financial Incentive:

We may provide price discounts, coupons, services, and other perks to our
customers and for members of our loyalty programs. Through these offerings, you
may provide us with Personal Information depending on how you choose to interact
with us when and after you opt-in to our programs. There is no obligation to
opt-in, and you may opt-out at any time. The details of the programs are
contained in the program offerings. We offer these programs, among other things,
to enhance our relationship with you so you can enjoy more of our
products/services at a lower price. While we invest in our marketing and brands,
consumer data is more valuable to our business when it is combined with a
sufficient amount of other consumer data and after it is enhanced by our efforts
described in this Privacy Notice. The value to our business of any individual
consumer’s data is dependent on several factors, including, for example, whether
and to what extent you take advantage or opt out of any offerings and whether we
are able to enhance the data through our efforts described in this Privacy
Notice. While we do not calculate the value of consumer data in our accounting
statements, we provide this good faith summary for California residents. To the
extent we create overall business value from our programs that could be directly
or reasonably related to the value of consumer data, the method for calculating
the value would include: a) costs related to maintaining the program including
but not limited to IT infrastructure, delivery of offers, and marketing
activities to enhance consumer data; b) whether the sales generated by the
program exceeds the cost to us of offering the program including value of
discounts to consumer; and c) value of the insights we are able to create based
upon aggregate data.

Data Retention:

We retain all categories of your personal information for as long as is
necessary, even if you are no longer an active customer, to provide the goods
and services and to fulfill the transactions you have requested of us, and to
support other necessary purposes such as:

 * providing related business processes (such as returns or exchanges),
 * resolving disputes and enforcing our agreements,
 * fulfilling our legitimate interests (such as improving our products and
   services),
 * responding to any questions, complaints or claims made by you or on your
   behalf,
 * preventing fraud, and
 * complying with our legal obligations.

In determining how long to retain information, we may consider various criteria
such as the amount, nature and sensitivity of the information, and the potential
risk of harm from unauthorized use or disclosure of the information. 

The purposes and criteria for which we process the data may dictate different
retention periods for the same types of information.  For example, we retain
your email address as an authentication credential (where applicable) as long as
you have an account with us and an additional period of time after that for our
legitimate interests and for our fraud and legal compliance purposes.  We may
also retain cached or archived copies of your information.

De-identified Data:

In instances where we de-identify your Personal Information to prevent it from
being linked to you as an individual, we will maintain and use it in a
de-identified format and will not attempt to re-identify the Personal
Information.

Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA/CPRA Rights
and we will not deny you goods or services, charge you a different price, or
provide you with a lesser quality of goods or services if you exercise any of
your CCPA/CPRA Rights.

As an additional resource, you may also contact us at
ConsumerRightsRequest@Staples.com for any additional questions related to the
rights granted under the CCPA/CPRA.

If you are a data controller with a consumer rights request for us, please
contact us at ConsumerRightsRequest@Staples.com.

 


DISCLOSURES ABOUT HANDLING CATEGORIES OF PERSONAL INFORMATION

For California residents, the following section describes:

 1. Categories of Personal Information We Collect and Process
 2. Examples of Specific Personal Information that may be Collected
 3. Categories of Sources from which Personal Information is Collected
 4. Purpose of Collecting/Processing the Personal Information
 5. Categories of Other Parties to whom Personal Information may be Disclosed
 6. Categories of Third Parties to whom Personal Information is Sold/Shared* and
    the Purpose of Sale/Sharing*

*Share/Shared/Sharing as defined by California law.

While this information is provided throughout this Privacy Policy, we provide
the supplemental information below pursuant to requirements under the law.

Not all categories or examples of specific Personal Information may be collected
about you depending on how you interact with us.

Categories of Personal Information We Collect/Process

Examples of Specific Personal Information that may be Collected

Categories of Sources from which Personal Information is Collected

 

Purpose of Collecting/ Processing Personal Information

 

Categories of Other Parties to whom Personal Information may be Disclosed

 

Categories of Third Parties to whom Personal Information is Sold/Shared and the
Purpose of Sale/Sharing

Identifiers

Names, Account/Loyalty Program IDs, Emails, Addresses, Phone Numbers, IP
Addresses, Other Device Identifiers, Tax Exempt Numbers, Driver’s License

From You, Your Devices (when you visit our sites or use our apps), Service
Providers (e.g., data brokers, fraud prevention companies), Business Partners,
Social Networks

To identify you in support of business activities such as fulfilling a
transaction, communicating with you (order notification, etc.), personalizing
your experience, fraud prevention, administering programs

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, payment processing companies, fraud prevention
companies, delivery companies, CA recycling partners, and product manufacturers

Advertising Networks for the purpose of Marketing and improving their products
and services

Commercial Information

Products or Services Purchased, Price or Service Quotations, Credit Card or
other Financial Information, Chat Sessions, Feedback/Survey Responses,
Copy/Print Materials, Website Account Credentials, Communications Entrusted to
Us

From You (when you transact with us or participate in any of our programs)

To support a business transaction, communicating with you (surveys about your
purchase, customer service, order notification, etc.), improve our products and
services, to provide services you request of us

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, fraud prevention companies, payment processing
companies, delivery companies, and product manufacturers

Advertising Networks for the purpose of Marketing and improving their products
and services

(We do not sell credit card or other financial information.)

Biometrics

 

N/A

N/A

N/A

None

None

Characteristics of Protected Classifications

 

Demographic information such as age ranges, marital status, etc.

From You and Service Providers (e.g., data brokers, survey vendors, fraud
prevention companies)

To protect against fraud, enable you to apply for a company credit card,
demographically understand our customers to improve our products and services

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and marketing/sales analytics companies

None

Internet or Other Electronic Network Activity

Browsing activity, searches, and other interactions on our websites or mobile
apps (such as text entered, pages visited, links clicked, keystrokes/ cadence,
and mouse movements), your interactions with our ads

From You, Your Devices (when you access our websites or mobile apps) and fraud
prevention companies

To send marketing to you, improve our products and services, fraud prevention,
etc.

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, fraud prevention companies, and eCommerce
analytics companies

Advertising Networks for the purpose of Marketing and improving their products
and services

Geolocation Data

Location based on IP address or mobile device location information

From You, Your Devices (when you access our websites or mobile apps), Service
Providers (e.g., data analytics providers, fraud prevention companies)

To personalize your experience, display store locations near you, fulfill your
orders, analyze web/app traffic, fraud prevention

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and eCommerce functionality vendors

None

Recordings/ Electronic Communications  (e.g., audio, visual, chat, etc.)

Voice, Video, Chat, and CCTV Recordings

From You (calls with customer service or sales, or when you visit some of our
locations), Service Providers (e.g., chat service providers, call recording
software providers)

For quality assurance, training and analysis purposes, to improve our products
and services, fraud prevention

Service Providers/Business Partners such as cloud service providers and customer
service call recording companies

None

Professional or Employment-Related Information

Employer Name and Job Title

 

                       

From You (e.g., when you inquire about our programs), Service Providers (e.g.,
data brokers), Business Partners

To send you marketing, personalize your experience, enroll you in certain
programs at your request

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and program administrators

None

Education Information

School Affiliations

From You (when you participate in certain programs such as Classroom Rewards)

To administer certain programs

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and program administrators

None

Inferences

Product and Service Preferences

From You (when you tell us what products and service are of interest), by
analyzing other data we have about you, Service Providers (e.g., advertising
networks, fraud prevention companies), Social Networks

To provide you personalized experiences and marketing, group you into segments
with other similar customers, improve our products and services

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and marketing/ eCommerce analytics companies

None

Sensitive Personal Information*

Driver’s License Number, Passport Number, Contents of Mail, Precise

Geolocation

From you, postal mail that you requested we receive/process, your mobile device

To fulfill the services you requested of us

Returns Processing Vendor, Passport Processing Vendor, Mail Service Vendor,
Store Locator Service

None

The above categories are intended to encompass the Personal Information
described in subdivision (e) of Section 1798.80 of the California Civil Code.

*We do not collect, process, or share Sensitive Personal Information for the
purpose of inferring characteristics about you. 

How to Exercise Your Privacy Rights:

Residents may submit a Right to Know/Access request by either:

 1. Submitting an online request here: Data Disclosure Request
 2. Submitting a phone request by calling 1-800-333-3330

Residents may submit a Data Correction or Data Deletion request by either:

 1. Submitting an online request here: Data Correction/Deletion Request
 2. Submitting a phone request by calling 1-800-333-3330

Residents may submit a request to Opt-Out of Targeted Advertising,
Selling/Sharing with Third Parties, or Profiling by either:

 1. Submitting an online request here: Do Not Sell/Share My Personal Information
 2. Clicking the “Do Not Sell/Share My Personal Information” button on our
    website

We will take reasonable steps to verify your above request prior to fulfilling
it by requiring a response to a confirmation email sent to the email address on
the request. For purposes of verifying your identity, we will request that you
provide personal information we already have on file including your first and
last name, email address, and phone number. We may also request mailing address
and, if applicable, your account number, login ID for our websites, and
rewards/loyalty number to ensure that we have a verified match.  We will respond
to your request and let you know if we need additional information.

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