Gap Inc. Privacy Policy

September 25, 2019

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1. Introduction

At Gap Inc., we strive every day to build the world’s most popular, authentic and iconic brands. Trust is the cornerstone of a great brand and respecting the privacy rights of our customers is an integral part of building that trust. This privacy policy explains how we collect and use your personal information to serve you.  

The basic terms of this policy cover all of Gap Inc.’s consumer facing operations in the United States, Canada, the United Kingdom and European Union. You can click on the geographic regions below to see additional terms that apply specifically to our customers in those regions. The region-specific terms of this policy only apply to the Gap companies that are in those geographic locations, or as applicable law requires.

United States
Gap Inc.’s affiliated brands in the United States include Gap, Banana Republic, Old Navy, Gap Factory, Banana Republic Factory, Athleta, Intermix, Hill City, and Janie and Jack.

Canada
Gap Inc’s affiliated brands in Canada include Gap, Old Navy, Banana Republic, Gap Factory, Intermix and Banana Republic Factory.

United Kingdom and European Union
Gap Inc.’s subsidiaries in the United Kingdom and European Union include Gap, Old Navy, Banana Republic, Gap Factory, Gap Outlet, Gap Stock, Banana Republic Factory and Athleta.

For a complete list of our companies, click here. To contact the customer service department that serves your region, please see the “Have questions or concerns” section of this policy. 

 

2. Your Right to Control How Your Personal Information is Used

You have the right to make requests regarding your personal information. You can:

  • Review the personal information we have about you or request a copy of it
  • Ask us to update or correct personal information if it is inaccurate
  • Request that we delete your personal information
  • Opt-out of sharing your personal information with third parties for some purposes
  • Object to certain types of uses of your personal information
  • Make choices about receiving email marketing 
  • Tell us which cookies you want us to use when you shop online by clicking on the on our Canadian websites, or using the cookie banners on our UK or EU websites

These rights vary depending on where you reside. But we will make reasonable efforts to honor your request, even if your country or state does not require us to do so.  If you ask us to delete or stop using your personal information, we may not be able to honor that request if the information is required to process your payments or returns; fulfill your order; or comply with tax, audit or regulatory requirements. Please contact us to exercise one or more of these rights.

California Privacy Rights
California Civil Code Section 1798.83 permits customers of Gap Inc. who are California residents to request certain information regarding and/or opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:

Gap Inc. - California Privacy Rights
Legal Department
2 Folsom Street
San Francisco, CA 94105

California Minor Content Removal
If you are a resident of California, under 18 and a registered user of our services, you may ask us to remove content or information that you have posted to these services by contacting us. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

California Do Not Track Disclosure
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals. For information about Do Not Track, please visit: www.allaboutdnt.org.

 

3. Types of Information We Collect

We collect information about you such as your contact information, payment information, demographic information, shopping preferences and information about the devices you use to shop online. 

We do not knowingly collect personal information directly from children under the age of 13 (16 in the UK/EU) without parental consent. Our websites are general audience sites and are not specifically targeted to or intended for use by children.

We need to collect personal information in order to provide the products and services you request.  If you do not provide the information requested, we may not be able to provide you with these products and services.

  • Contact information, such as name, email address, postal address, phone number
  • Payment information, such as credit card number, bank card numbers, cheque, and other payment details
  • Order and refund history
  • Demographic information, such as age, estimated income, household information, and occupation
  • Information about your interests, preferences, and purchase history
  • As part of applying for credit, or processing a return, you may be asked to provide government issued identification numbers, such as social security number, national identification number, and/or driver’s license number
  • To help ensure our employees’ and customers’ security and safety, we use CCTV cameras in our stores
  • Information may be collected from you if you interact with us on social media sites, such as Facebook, Instagram, and Snapchat
  • Device and browser information including location information, MAC addresses, IP addresses, Cookies, and other online identifiers
  • If you disclose any personal information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy

 

4. How We Collect Your Information

We collect information about you in a variety of different ways:

4.1 Information you provide to us, such as while making a purchase or signing up for a loyalty or rewards program.

4.2 Information we collect while you interact with our websites, mobile or other apps, social media sites, and other products and services.  This often involves information about your device such as IP addresses and MAC addresses, as well as information collected through cookies. 

4.3 Information we collect about you from other sources, such as credit card issuers and data analytics firms.

4.4 Information we create ourselves after we analyze the information we collected about you, such as your shopping preferences.  

4.1 Information You Provide to Us

Online Order Information
When you make a purchase from our websites or mobile apps, we ask you to provide us with information about your purchase such as your name, email address, shipping address, phone number, and payment information.

In-Store
When you visit one of our stores, we may ask you for certain information, such as at the point of sale or while interacting with one of our team members. This may include payment information, product information (such as clothing size), and other information about your purchase, including your name, email address, shipping address, and phone number.

Online Accounts
If you sign up for an online account through our websites or mobile applications, we may ask you to provide your username, password, email address, phone number, payment card information, product preferences, past purchases, or gender. You do not have to create an online account to make a purchase.

If you connect your social media account to your online account, you will share certain personal information from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be accessible to us when you connect your social media account to your online account.

Marketing Communications
If you would like to receive marketing communications from us, you may do so by signing up on our websites, mobile applications, or in our stores. We will ask you to provide your email address or phone number so we can send you marketing materials.

Communicating with us
When you contact us about a customer service issue, or to make other inquiries, we collect the content of those communications, and any additional information about the method of communication such as phone, SMS, email, chat, or through social media platforms. For example, if you email us, we will collect your email address, if you send us a text message, we will collect your phone number, and so on.

Loyalty & Rewards Programs
If you enroll in a loyalty or rewards program such as BRIGHT, we collect information such as your name, email, telephone number, or mailing address in order to track your rewards and allow you to redeem them across our brands.

Credit Card Programs
In certain countries, we may provide you with the opportunity to apply for an offer of credit from a payment card issuer in our stores or online. To create a more convenient application process, we may provide information from your customer account to a payment card issuer in order to generate a pre-approved credit offer and/or pre-populate your online credit card application with information from your customer account. By submitting a credit card application either in store or online, you acknowledge and agree that Gap Inc. may provide your information to the payment card issuer in accordance with the terms and conditions of the application. For information about the privacy practices associated with your credit card application, please contact the payment card issuer.

4.2 Information We Collect Through Your Interactions With Us

Websites and Mobile Apps
When you visit one of our websites or use our mobile apps we may collect your device identifier such as IP address or MAC address, as well as browser and settings information, shopping preferences, and information about how you interact with our websites and other digital products.

In-Store Wi-Fi
If you choose to connect to our in-store Wi-Fi services, we will receive information about you and your device. This may include your device’s MAC address, IP address, received signal strength indicators (RSSI), and technical details about your device such as its operating system, device type, device name, and technical capabilities. We may also receive information about the store location you visit, the areas of the store you visit, the names and/or Internet addresses of the websites you visit and the applications you use, and how long you interact with such sites or applications.

If your mobile device is configured to search for available Wi-Fi networks, we may receive information about your device even if you choose not to connect to our Wi-Fi Services.

You can opt out of the auto-reconnect feature at any time by visiting http://www.smart-places.org.

For full details about our in-store Wi-Fi practices, please see our Wi-Fi Terms of Use which are available upon signup.

In-Store Cameras, RFID, and other tracking technologies
We use a variety of technologies in our stores for a variety of reasons. We may use video and RFID tracking to protect against theft and fraud in our stores. We also collect and aggregate data to track and analyze how our customers move through the store, so that we can make changes to the layout and optimize their experience.

4.3 Other Sources

Investigations
We may collect information about you in connection with investigations into fraudulent or criminal activities on our websites, mobile apps, and in our stores.

Other Sources
We may also collect information from other sources, including for example, joint marketing partners, data analytics firms, public databases, publicly available social media pages, and other third parties we work with.

4.4 Information We Aggregate and Derive

Aggregated information
We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose. For example, we may calculate the percentage of our site users who have a particular telephone area code.

5. Cookies and Similar Technologies

Cookies are little bits of computer code that collect data by tagging along with you while you browse. Most websites, including ours, wouldn’t work very well without certain cookies. They allow us to prevent crashes, display information, fix bugs, and ensure the security of our site (and your account). These types of cookies are often called “strictly necessary” cookies. Because they are needed for our site to work, we don’t provide you with an ability to opt-out of these cookies. But you can remove them by using your browser settings. Keep in mind that certain features of our site may not be available to you.

Some cookies provide important services but are not strictly necessary for our website to work. These cookies use information about your interactions with us so we can suggest clothes and special offers for you. If your shopping is interrupted, they remember where you left off and send you reminders that you truly deserve that new outfit. These reminders might be sent to you in an email, on social media or while you’re browsing another website or on another device. We think these cookies are useful and will make it easier for you to shop with us. But you might disagree. If so, you can tell us not to use certain cookies by using the opt-out tools we have placed on our ecommerce websites.  These options vary by geographic region. 

US
You can visit the Digital Advertising Alliance to learn more about opting out of certain cookies on our .com websites.

Canada
You can click on the in the upper right hand side of our .ca websites to opt-out of certain cookies on those sites. We follow the Digital Advertising Alliance of Canada (DAAC) self-regulatory principles for Online Behavioral Advertising on our .ca websites. You can learn more by visiting the DAAC: http://youradchoices.ca/choices.

EU & UK
You can click on the “Cookie Options” link on the bottom of our .eu and .uk websites to opt-out of certain cookies on those sites. You can also learn more by visiting EU Digital Advertising Alliance: http://www.edaa.eu/.

We also use cookies and similar technologies to gather information about the success of our ad campaigns and use of our products and services. These technologies include Google Analytics, Adobe Analytics, Adobe Flash and others. You can opt-out by visiting Google Analytics Opt-out Browser Add-on and Adobe Your Privacy Choices. You can also adjust your privacy settings for Adobe Flash player by visiting the Website Storage Settings Panel and the Global Storage Settings Panel.

6. How We Use Your Information

We use your personal information to provide you with our products and services and to operate our business. We often use the information we collect for multiple purposes. For example, if you make a purchase on our website, we collect several types of data from you and use it in multiple ways: First, we use your shipping address to make sure that our products arrive at your door. We may also use your contact information to send you a receipt of purchase. We may look at your experience on our website to make improvements to it and try to tailor it to your needs. We will also analyze the data you provide us and your behavior on our website to ensure that the activity is not fraudulent. Finally, we use your purchase information for other business-related purposes like accounting and financial reporting.

We may also combine information we collect from you with information we obtain from other sources. This may include your online and in-store purchase transactions and other interactions you have with us and our partners.  

We often obtain your consent to use your information. But sometimes, obtaining your consent is not needed because we may use your information for our own legitimate interests, to fulfill a contract with you, or to comply with legal obligations imposed on us. For example, when you make purchases online, we process your information to fulfill our contractual obligations. When you visit our websites, we have a legitimate interest in using your browsing data to improve our site’s usability, and when you engage with us online, we have a legal obligation to ensure that you are not attempting to defraud, us or our customers.

Providing you with Products and Services
We use your information to process, fulfill and communicate with you about your orders, respond to your customer service inquiries, allow you to use in-store and online technologies, enroll you in rewards and loyalty programs, allow you to apply for offers of credit from a payment provider, and to inform you of policy or product changes that may impact you. When we use information in this way, we do so for the purpose of fulfilling a contract with you, or to comply with a legal obligation.

For Marketing Communications and Promotions
We use your personal information to send you marketing communications about our products and services, contests, and promotions. We may send you emails, postal mail, text messages, phone calls, or social media messages that we believe you would be interested in. We will do this either with your consent or because we have a legitimate interest to do so.

For Business Reporting and Providing Personalized Services and Ads
We use your personal information to analyze or predict our customer preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our products and services. We also use personal information to better understand you and your preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests. We use information in this way with your consent or because we have a legitimate interest to do so.

Allowing you to participate in promotions and events
We may use your personal information to allow you to participate in local community events, promotions, and in-store experiences. Some of these may have additional rules containing information about how we will use and disclose your personal information. We use this information for the purpose of fulfilling a contract with you or because we have a legitimate interest to do so.

For other business purposes
We may use your personal information to learn more about our customer base, perform data analyses, address problems with our technology, improve our products and services or develop new ones, to investigate and prevent fraud or other illegal activity, to enforce our Terms of Sale and Use, and to provide a more consistent experience across our brands and channels. We may also use your information where we believe it is required to protect the rights, property, safety and security of Gap Inc., our employees, customers, and others. Finally, we may be required to use your personal information to comply with applicable law, for auditing purposes,or to respond to requests from government authorities.

We will engage in these activities to fulfill a contract with you, to comply with a legal obligation, and/or because we have a legitimate interest in doing so.

7. How We Share Personal Information

We may share your personal information with our affiliated companies and brands, with third parties who provide services to you or us, with promotional partners, with social media companies, or with other third parties as needed to carry out our business, or comply with a legal obligation.

Sharing between brands and affiliates
When you provide information to one of our brands, we may share it with our other brands such as Gap, Old Navy, Banana Republic, Intermix, Athleta, Hill City, and Janie and Jack. Our brands operate under a number of corporate subsidiaries and affiliates, which you can see here.

Public posting and social sharing
When you post public comments on our websites, through in-store technologies, on public forums like our social media sites, blogs, and online reviews, your comments are accessible by other members of the public.

Social media logins and other integrations
When you log into your customer account using your social media account credentials, or use other social media services with us, your personal information will be disclosed to the social media account provider in connection with your login. By doing so, you authorize us to facilitate this sharing of information, and you understand that this sharing is governed by the social media site’s privacy policy that you used to log into your account.

Gap Inc.’s service providers
Gap Inc. uses third parties to provide services to you or us. This includes managing customer information; fulfilling promotions; sending marketing communications; conducting surveys; hosting websites; analyzing data; processing payments; fulfilling and shipping orders; or providing network security, accounting, auditing, and other services. We do not authorize these service providers to use or disclose your information for purposes other than why we have retained them.

Third party partners
You ​may share information with other companies when we work with them to promote our products, services, offers, contests, or other promotions to our customers.

Script or Loyalty Programs
If you participate in third party scrip, loyalty, or similar programs that a Gap Inc. brand also participates in, we will share your information with them to facilitate the program. This may include sending your purchase information to credit card processors, so part of your purchase may be donated to participating schools or other non-profit organizations. If you participate in loyalty programs, we may send your information to the vendor administering the program. This information may include your name, email, credit card number, your purchase history, and other information you have provided to us through the program.

Once your information is provided to the third party it will be handled in accordance with their privacy policy. You should review the privacy policy before entering into a rewards, loyalty, or scrip program, so that you have a complete understanding of how your information is being used.

Direct Mail
If you purchase Athleta and Hill City brand products through our website or by placing a catalog order by phone or mail, we may share your name, postal address, and shopping history with other retailers so they can send you catalogs and offers by mail. We do not share email addresses for such purposes. If you would prefer that we not share information about you with these companies, please let us know by contacting Athleta and Hill City customer service as described in the section entitled, "Contact Information".

Payment card issuers
In certain countries, we may provide you with the opportunity to apply for an offer of credit from a payment card issuer. To create a more convenient application process, we may provide information from your customer account to a payment card issuer in order to generate a pre-approved credit offer or pre-populate your online credit card application with information from your customer account. By submitting a credit card application either in store or online, you acknowledge and agree that Gap Inc. may provide your information to the payment card issuer in accordance with the terms and conditions of the application. For information about the privacy practices associated with your credit application, please contact the payment card issuer.

To fulfill legal obligations and with government agencies
We may share information about you if necessary or appropriate, in our good faith judgment, to comply with laws or regulations, or in response to a valid subpoena, order, or government request, or to protect the operations, privacy, safety, property or rights of Gap Inc. or others.

During a sale or business transaction
In the event of any potential or actual 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), your personal information may be shared with third parties such as the acquiring entity and its advisors.

8. How we Store and Secure Your Information

8.1 Where We Store Information.

Gap Inc. is a global company with a global footprint, but the majority of the Personal Information that we collect is stored in the United States.  Your personal information may be subject to the laws of the countries in which it is stored or used. By providing us with any personal information, you understand that your information may be transferred, processed, or stored outside of your country of residence, including the United States, which may have a different data protection regime from the country in which you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information. European customers can read more about this topic here:

EU Data Transfers
For transfers from the EEA to countries not considered adequate by the European Commission (the full list of countries deemed adequate by the EEA is available here), we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information. If you would like to obtain a copy of these measures, please contact us.

8.2. Information Retention.

We will retain your personal information for as long as needed to provide the service to you (for example, as long as you have an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our services or maintaining security, and in each case, as consistent with applicable law. We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.

8.3. Information Security.

We do our best to provide you with a safe and convenient shopping experience. We have put in place a wide variety of technical and organizational security measures to help protect you and the personal information we collect about you. Please note that we will never email you asking for account information like your user name, date of birth, credit card information, or other personal information. Finally, we will never email you with attachments that can be opened. If you received a suspicious email that appears to be from us please contact us.

8.4 Third Party Services.

We are not responsible for, and this policy does not address, the privacy practices of other third parties, such as Facebook, Apple, Google, Microsoft, or any other app developers, social media platforms, operating system providers, wireless or telecommunications service providers, or device manufacturers. The inclusion of a link on our services does not imply an endorsement of the linked sites or services by us or our affiliates.

8.5 Sensitive Information.

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through our services or otherwise to us.

8.6 Third Party Payment Service.

We make certain third-party payment service processors available to you such as PayPal or Apple Pay.  If you wish to use one of these services, your personal information will be collected by such third party and will be subject to the third party’s privacy policy. We have no control over, and are not responsible for this third party’s collection, use, and disclosure of your personal information.

8.7 Changes to this Policy.

We will post updates to our privacy policy on our websites. If we change the policy in a manner that materially impacts your privacy rights, we will provide additional notice to you.

 

Contact Information

Have questions or want more information? Click your region to contact customer service:

UK and EU Customer Contact
In the UK, Gap Europe Limited located at 5th Floor, 6 St Andrew Street, London EC4A 3AE, London UK and GPS (Great Britain) Limited located at Nations House, 103 Wigmore Street London W1U 1QS are the companies responsible for collection, use, and disclosure of your personal information under this Privacy Policy.

In the Republic of Ireland, Gap Stores (Ireland) Limited whose registered office is at Arthur Cox, Earlsfort Terrace Dublin 2 is the company responsible for collection, use, and disclosure of your personal information under this Privacy Policy.

In France, Gap France SAS located at 49/53 Avenue des Champs-Elyesses 75008 Paris France is the company responsible for collection, use, and disclosure of your personal information under this Privacy Policy.

In Italy, Gap Italy SRL with its registered office at Baker & McKenzie, Piazza Meda Filippo 3 Milan Italy 20121 is the company responsible for collection, use, and disclosure of your personal information under this Privacy Policy.

To make choices about receiving promotional communications, to update or change personal information, or to place an order, or for any other inquiries, you can contact any of our Brands by email, telephone, or postal mail:

Email:
custserv@gap.eu

Telephone:
Calling within the UK 0800 368 0674
Calling international: click here for phone numbers outside of the UK.

Post:
Gap EHQ
Freepost WD 3719
Castle Mound Way
Rugby, Warwickshire,
CV23 0BR
United Kingdom

UK & EU Data Protection Authorities
You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

Gap Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-800-GAPSTYLE (1-800-427-7895)
1-888-906-1104 (TDD hearing impaired)
custserv@gap.com

Banana Republic Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-888-BR STYLE (1-888-277-8953)
1-888-906-1345 (TDD hearing impaired)
custserv@bananarepublic.com

Old Navy Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-800-OLD-NAVY (1-800-653-6289)
1-800-449-4253 (TDD hearing impaired)
custserv@oldnavy.com

Athleta Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-877-3ATHLETA (1-877-328-4538)
1-888-906-1345 (TDD hearing impaired)
custserv@athleta.com

Gap Factory Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-844-GFS-ONLINE (1-844-437-6654)
1-844-437-6654 (TDD hearing impaired)
custserv@gapfactory.com

Banana Republic Factory Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-844-273-7746
1-888-906-1345 (TDD hearing impaired)
custserv@bananarepublicfactory.com

Hill City Customer Services
6007 Green Pointe Drive
Groveport, OH 43125

1-844-HILL-CITY (1-844-445-5248)
1-888-906-1104 (TDD hearing impaired)
custserv@hillcity.com

INTERMIX Customer Service
1440 Broadway, 5th Floor
New York, NY 10018
(855) 446-4943
customerservice@INTERMIXonline.com

Janie and Jack Customer Service
2299 Kids Way
Dixon, CA 95620
1-877-449-8800
privacy@janieandjack.com

Gap Canada Customer Service
13153 Coleraine Dr.
Bolton, ON L7E 3B6
Canada

1-800-GAPSTYLE (1-800-427-7895)
Please dial 711 for relay service
custserv@gapcanada.ca

Banana Republic Canada Customer Service
13153 Coleraine Dr.
Bolton, ON L7E 3B6
Canada

1-888-BR STYLE (1-888-277-8953)
Please dial 711 for relay service
custserv@bananarepublic.ca

Old Navy Canada Customer Service
13153 Coleraine Dr.
Bolton, ON L7E 3B6
Canada

1-800-OLD-NAVY (1-800-653-6289)
Please dial 711 for relay service
custserv@oldnavy.ca

Athleta Customer Service
5900 North Meadows Drive
Grove City, OH 43123
USA

1-877-3ATHLETA (1-877-328-4538)
Please dial 711 for relay service
custserv@athleta.com

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