Canada Goose Privacy Policy

Effective Date: January 1, 2020

Introduction

The following is the privacy policy (the “Privacy Policy”) of Canada Goose Inc. and Canada US, Inc. (together “Canada Goose”, “we”, “us” or ”our”) . Canada Goose recognizes the importance of your right to privacy, and we are committed to safeguarding Personal Information (as defined below) that Canada Goose collects, uses, and discloses from users of this site (the “Site”) as well as our apps, other websites or offline services, in each case that link to or expressly reference this Privacy Policy (collectively, the “Sites/Services”).

This Privacy Policy sets out the way we use your Personal Information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled. We advise you to read this Privacy Policy in its entirety, including the jurisdiction-specific provisions in the appendix to this Privacy Policy, which will apply to users in certain jurisdictions.


CATEGORIES OF PERSONAL INFORMATION WE COLLECT AND USE

We collect certain types of Personal Information from or about you throughout our interaction with you and from other sources.

“Personal Information” is any information:

  • that identifies or can be used to identify you or your household;
  • that relates to, describes, is capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your or household;
  • that can be used to authenticate you or provide access to an account;

We collect and use this Personal Information for the purposes and activities we have listed in the table below.

For at least the past 12 months, we have collected the following categories of Personal Information from the following sources:

Through the Sites/Services:

What we collect

We collect from you (which, for the purposes of this section, refers to you and your household) through the Sites/Services Personal Information that identifies you as an individual or relates to identifying information about you, including:

  • Your contact details including: your name, address, phone number, email address;
  • Your username, password and account preferences;
  • Your payment information;
  • Other information about you such as your date of birth, gender and language preference;
  • The product(s) you have purchased;
  • Information you provide to us when you participate in contests, sweepstakes and other promotions or use other features of our website that may be offered from time to time.
  • Information you provide to us when you participate in or respond to consumer surveys or requests for opinions, concerns, and preferences regarding our products or service.

How we use it

We use this information for certain activities, including:

  • Fulfill orders, process payments and returns, and ship products purchased by you;
  • Onboard you as an account holder;
  • Reporting and account management, maintenance and servicing;
  • Providing customer service;
  • Improving our Sites/Services;
  • Performing research and business analytics, and identifying usage trends;
  • Engaging in fraud monitoring and prevention;
  • Compliance with applicable laws and regulations;
  • Protecting our business and our customers against illegal activity;
  • Performing audits;
  • Verifying requests made pursuant to this Privacy Policy;
  • Tailoring marketing communications from our affiliates as well as from selected third parties;
  • Managing our business effectively; and
  • Developing new products and services.

Through your browser or device

What we collect

Certain information is collected from you by Internet browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version.

We may also collect from you various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device fingerprint or identifier so that we can recognize your device, along with the time of your visit and the page(s) visited.

How we use it

We use this information for certain activities, including:

  • Reviewing and processing applications for our Services;
  • Intake of new customers; account maintenance and servicing;
  • Providing customer service;
  • Improving our Sites/Services; performing research and business analytics, and identifying usage trends;
  • Engaging in fraud monitoring and prevention; compliance with applicable laws and regulations;
  • Protecting our business and our customers against illegal activity;
  • Performing audits; verifying requests made pursuant to this Privacy Policy;
  • Identifying Canada Goose products that may be of interest to you and marketing these to you if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;
  • Managing our business effectively;
  • Notifying you of product recalls or safety issues; and
  • Developing new products and services.

Using unique identifiers such as cookies, pixel tags, device profiling, and similar technologies

What we collect

We may use unique identifiers such as cookies, pixel tags, and similar technologies to collect from your browser, device information, and browsing information such as time spent on the Site, pages visited, language preferences, search engine terms, and other traffic data, including:

  • Details of products you have purchased from us;
  • When and where you made these purchases;
  • What you paid for them and how you paid;
  • Whether you've opened or clicked on links in electronic communications from us or visited pages on our website;
  • Your marketing preferences;
  • Marketing information (previous communication data; transaction history.

We may also collect from you various attributes associated with your device (such as IP address, installed fonts, language and browser settings, and time zone) in order to create a device fingerprint or identifier so that we can recognize your device.

How we use it

We use this information for certain activities, including:

  • Operating, maintaining, and protecting our Sites/Services;
  • Reviewing and processing applications for our Services;
  • Intake of new customers; account maintenance and servicing;
  • Improving our products and services;
  • Improving your experience on our Sites;
  • Performing research and business analytics; understanding your interests and preferences;
  • Identifying Canada Goose products that may be of interest to you and marketing these to you if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law;
  • Engaging in fraud monitoring and prevention;
  • Protecting our business and our customers against illegal activity;
  • Notifying you of product recalls or safety issues; and
  • Compliance with applicable laws and regulations.

Through your communications with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including Services offered at retail locations:

What we collect

We may collect:

  • Information that you give us when you use our virtual queue tool, including your phone number and e-mail, so that we can hold your place in line and notify you when it’s your turn to go into the store.
  • Information that you give us if you submit an employment application via our website including your resume information, employment history and educational qualifications;
  • Information you provide to us when you make an enquiry, complaint, claim under our warranty program or otherwise communicate with us, whether through our website, via email or over the phone;
  • Information you give us when you sign up for Basecamp; and
  • Your marketing preferences and marketing information.

How we use it

We use this information for certain activities, including:

  • Providing you with updates regarding your place in our virtual queue;
  • Reviewing and considering the information that you submitted in connection with your possible employment by Canada Goose and otherwise in connection with the hiring process and to respond to your application for current or future career opportunities;
  • Responding to enquiries;
  • Providing you with information about warranty claims;
  • Monitoring customer communications for quality and training purposes;
  • Improving our services;
  • Dealing with any complaints;
  • Identifying Canada Goose products that may be of interest to you and marketing these to you if you have indicated that you wish to receive such marketing or if we are otherwise entitled to do so by law; and
  • Monitoring information transmitted or received through our website or via email to prevent violations of our website terms of use or inappropriate content.

Drawing Inferences from Personal Information

What we develop

We may create user profiles based upon inferences from the Personal Information about you that we have collected (please see the “Online Advertising” section below for more information on our online advertising practices). In some instances, we may combine Other Information with Personal Information where permissible by law and applicable industry guidelines. In addition to Personal Information you provide directly to us, we may collect Other Information about you, including acquiring and using services provided by other parties who collect and analyze customer data.

How we use it

We use this information for certain activities, including:

  • Using these inferences for our internal business and operational purposes, such as to:
    • provide customer service and support;
    • improve our products and Sites/Services;
    • performing research and business analytics; and
    • better tailoring marketing communications from our affiliates as well as from selected third parties.

Through third-party sources:

What we collect

We may collect information about you from other sources, including:

  • Information that we collect where you participate in a third-party application or feature (e.g. Facebook or another social platform or website) through which you allow us to collect (and/or the third party to share) personal information about you or where you are on another website and opt-in to receive information from us.
  • Information that we collect when you visit our stores, including through in-store monitoring and surveillance.

How we use it

We use this information for certain activities, including:

  • Maintaining market awareness;
  • Build and maintain social media branding, and our branding in general;
  • Providing you with information about products which may interest you, if you have indicated that you wish to receive such information.
  • Storing information for security purposes and for preventing and investigating crime.
  • Reviewing and processing applications for our Services;
  • Intake of new customers; account maintenance and servicing; providing customer service;
  • Improving our Sites/Services; performing research and business analytics, and identifying usage trends;
  • Engaging in fraud monitoring and prevention; compliance with applicable laws and regulations;
  • Protecting our business and our customers against illegal activity;
  • Performing audits;
  • Verifying requests made pursuant to this Notice; tailoring marketing communications from our affiliates as well as from selected third parties;
  • Managing our business effectively; and
  • Developing new products and services.


In addition to the above, your Personal Information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim. We will not delete Personal Information if relevant to an investigation or dispute. It will continue to be stored until those issues are fully resolved.

We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our products to you based on fraud detection and creditworthiness checks. This will be informed by verification of your Personal Information (including by third parties). Depending on the outcome of these checks, a decision will be reached automatically as to whether we are able to provide products to you.

Where we need to collect your Personal Information under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide our products to you).


RETENTION OF PERSONAL INFORMATION

We will keep your Personal Information for as long as it is reasonably necessary considering the purposes for which your Personal Information has been collected. It will depend on factors such as whether you have any outstanding purchases or an account with us or have interacted with recent offers. For further information on how long we will keep your Personal Information, please contact our privacy officer at Privacyofficer@CanadaGoose.com.


DISCLOSURE OF YOUR PERSONAL INFORMATION

During at least the past 12 months, we have disclosed your Personal Information for the following business purposes or as otherwise described in this Privacy Policy:

  • We may share your Personal Information with other members of our group of companies so that we can provide the best service across our group. They are bound to keep and use your Personal Information in accordance with this Privacy Policy;
  • We may also share your Personal Information with certain contractors, service providers or advisors that help with our business operations (for example, order fulfilment, cloud services, fraud prevention, customer services, payment processing and marketing) and they may process your Personal Information for us. They are always required to meet our standards on processing and security of Personal Information. The information we provide them with, including your Personal Information, will only be provided in connection with the performance of their function;
  • If we're discussing selling or transferring part or all of our business the information may be transferred to prospective purchasers under suitable terms as to confidentiality – or if sold, to buyers who can continue to provide products to you;
  • We may also share your Personal Information where you have given us consent to do so or when we are otherwise required or permitted by law, for example by the Police or in defense of a legal claim.

If you choose to provide us with Personal Information, we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from other regions with laws governing data collection and use that may differ from your region’s law, please note that you are transferring your Personal Information to your region which does not have the same data protection laws as other countries. Further details on the safeguards adopted by us may be obtained by contacting us as set out at the end of this Privacy Policy; please also review the jurisdiction-specific appendix at the end of this Privacy Policy.


COOKIES, WEB BEACONS, TAGS AND OTHER SIMILAR TECHNOLOGIES

Our website (www.canadagoose.com) uses automatic data collection technology and services such as “cookies”, “web beacons”, “tags” and other similar technologies. A cookie is a small data file that is placed on the hard drive of your computer so that your computer will “remember” information when you visit a website. Web beacons and tags are small strings of code that are used in conjunction with a cookie and that allow us to record activity on our website. A web beacon allows us to capture certain additional types of information about a visitor's actions on a website, such as a visitor's cookie number, the time, date, duration and number of page views, a description of the page where the web beacon is placed, and details about any items that were purchased.

When you use our website, these technologies may record and collect Personal Information, such as information that identifies your computer, tracks your use of our website and collects certain information about you and your surfing habits. This information may include information that identifies your device, IP address, browser type and language preferences, and information about referring and exit pages and URLs, keywords, date and time, what sections of a website you visit, and other similar information concerning your use. This information is used for the purposes mentioned above and to help us serve you better by improving our website design, as well as our products, services, and promotions. We also use the technologies mentioned above to improve functionality of our website and user experience.

FUNCTIONAL COOKIES

Type of Cookie

Data Collected

Purpose of Cookie

Duration of Storage

Functional Cookie dwsecuretoken_xxxxx Request id to avoid any high jacking of a secure session Session
Functional Cookie dwanonymous_ xxxxx Stores the anonymous user id to retrieve the basket if a customer comes back later 6 months
Functional Cookie dwsid Stores customer session ID. Session
Functional Cookie dwcustomer_xxxxx Stores the id of a customer registered once and requested “to be remembered” 6 months
Demandware Données_pays Stores customer geolocation to provide geo-redict capability Permanent
Bazaarvoice BVImplMain Site Bazaarvoice Trackers to enable anonymous analytics & measurement reporting. Track successful order completion and send customers an invitation to submit an online review Permanent

ANALYTICS COOKIES

Type of Cookie

Data Collected

Purpose of Cookie

Duration of Storage

Google Analytics _ga This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguishe unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners. Permanent
Demandware dwpersonalization_xxxxx Participation in an AB test lasting longer than a session 31 days
Fullstory fs_uid Track user behaviour/clicks on the website platform to better optimize user experience and inform site design Session
Freshmarket _session_id Track user behaviour/clicks across site forms to better optimize user experience and form design Session
CanadaGooseXX-pagevisits Total page view counts This cookie tracks the total page view of a customer per session to help us understand our customer better and improve site experience. Session
CanadaGooseXX-pdpvisits Total product detail page view counts This cookie tracks the total views a customer visits per session to help us understand our customer better and improve site experience. Session

TRACKING COOKIES

Type of Cookie

Data Collected

Purpose of Cookie

Duration of Storage

Bazaarvoice BVImplMain Site Stores customer ID to facilitate reviewing and posting Bazaar Voice product reviews. Permanent
Brandify W2GISM Store customer country and location preference for the store localtor on the website Session
Size analysis fita.sid.canadagoose Stores the customer preference of the fit data entered from previous activities so that the site can provide quick fit / size recommendations. Session

YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION

You have certain rights with regard to your Personal Information.

  • A. Your California Privacy Rights

If you are a California resident, you have the right to request and receive certain information about disclosure of your Personal Information to third parties for their direct marketing purposes.

For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act. Please see “Supplemental provisions for California residents” in the Appendix to this Notice.

  • B. Cookies and Interest-Based Advertising.

As noted, this Privacy Policy applies to all Personal Information collected and processed by us using cookies, web beacons and tags on our website.

When accessing our website, you are requested to consent to the use of cookies and similar techniques in accordance with our Privacy Policy. Should you change your mind at a later stage, you can easily change your “cookie settings” by changing the settings of your web browser (e.g. Internet Explorer, Google Chrome, Safari, etc.). For more information hereon, please refer to the ‘help’ section of your web browser and see below. If you do not consent to the use of cookies and similar techniques when accessing our website and/or when you turn off the use of cookies and similar techniques via your web browser settings later, you may still visit our website, but you may not be able to use some areas of the website and the website may not provide optimal functionality.

If you wish to block certain cookies, you can do so in the browser you are using by following the applicable link below:

Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Chrome: https://support.google.com/accounts/answer/61416?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Safari: https://support.apple.com/kb/PH5042

Our website uses the web analytics service Google Analytics that is provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses “cookies”. The information generated by the cookie on your use of the platform will be transmitted to and stored by Google on servers in the United States. You may refuse accepting cookies by selecting the relevant settings of your browser. However, please note that if you do so you may not be able to use the full functionality of the platform.

To opt out of being tracked by Google Analytics across all websites, you can visit http://tools.google.com/dlpage/gaoptout.

Personal Information obtained through cookies, web beacons and tags may be shared with or obtained by third party service providers on our behalf in accordance with applicable laws (cf. the section immediately below). In that case, the processing of this Personal Information may also be subject to the privacy policies of these third-parties. We therefore highly recommend that you take due account of these privacy policies when using our website.

  • C. Unsolicited Communications

Canada Goose complies with applicable laws regarding unsolicited marketing messages (e.g. ‘spam’) and will not send you such messages in contravention of such laws. Our online store allows you to sign up and expressly consent to receiving electronic communications. We will ensure that each email includes an opt-out feature and instructions on how to un-subscribe if you no longer wish to receive future e-mails from us. You may also contact us at askus@canadagoose.com to stop receiving them or can unsubscribe using the link included in the e-mail or by telephoning us at 1 (888) 276-6297. If you have not expressly opted-in to receiving electronic marketing communications, we will only communicate with you if we are otherwise entitled to do so by applicable law.

  • D. Third-Party Advertising Partners

We use third-party service providers to serve advertisements on our behalf across the internet. These advertising service providers may collect non-identifiable information about your visits to our website, and your interactions with our products and services. Such non-identifiable information does not include your name, address, email address or other Personal Information. Such providers may place and access their own cookies, tags, web beacons or similar technologies on your computer or device used to access the website to serve you ads or other content personalized to your interests. In addition to the information about your visits to our website, our service providers may also use the information about your visits to other websites to target advertisements for products and services available from Canada Goose.

As described above, you may reject the use of cookies when accessing our website and you may be able to set your browser to reject cookies later. In that case, you may still receive online advertising, but it may be less personalized.

  • E. “Do Not Track” Signals

Unless your browser settings are configured to make your online activities and publicly available information about your online activities (such as traffic data) invisible to usage analytics tools, we do not presently have the capability to omit you from usage analytics to the extent your browser only sends us a “do not track” signals or message and does not otherwise screen you from tracking without any action on our part.

Third parties, other than our vendors (such as our website analytics provider), do not have authorization from us to track which websites you visited prior and after visiting our website. That said, we cannot control third party tracking and there may be some third party tracking over time and across third-party websites that occurs without our knowledge or consent.

If you do not wish your online activities (on our website) to be tracked, we highly recommend to change your web browser settings. For more information hereon, please refer to the ‘help’ section of your web browser.

THIRD PARTY LINKS

Our website may contain links to other websites which are not under the control of Canada Goose. We are not responsible for the privacy practices or content of such other websites. We encourage our users to be aware when they leave our website and to read the privacy statements of each website to which we may link that may collect Personal Information.

SECURITY

We maintain reasonable technical, physical and administrative security safeguards to protect Personal Information against loss and any form of unlawful processing (such as theft and unauthorized access). Any Personal Information you provide to us is exchanged on a secure server. Furthermore, our website is secured by SSL-encryption to protect Personal Information from unauthorized access when transferring them over the Internet.

CHILDREN’S PRIVACY

We do not knowingly collect personally identifiable information from children under 16 without permission from a parent or guardian. If we learn that we have collected the Personal Information of such a child, we will take steps to delete the information as soon as possible.

CHANGES TO THIS PRIVACY POLICY

Canada Goose reserves the right, in its sole discretion, to change, modify, add or remove portions of this Privacy Policy at any time and from time to time. We will notify you of any material changes to our Privacy Policy as required by law. We will also post an updated copy on our website. Please check our site periodically for updates. Your continued use of our website means that you consent to the collection, use and disclosure of your Personal Information as set out in the updated Privacy Policy.

HOW TO CONTACT US

We welcome your feedback. If you have any questions about this policy please contact Canada Goose’s Chief Privacy Officer at: Privacyofficer@CanadaGoose.com. To submit a request pursuant to the California Consumer Privacy Act, please follow the procedures set forth in the section entitled “Supplemental provisions for California residents” Appendix to this Privacy Policy.

In addition, Canada Goose US, Inc. can be contacted at 1 (888) 276-6297 or by mail at Canada Goose US, Inc., PO Box 61070 Eglinton & Dufferin RO, Toronto, Ontario, M6E 5B2, Canada.

Canada Goose Inc. can be contacted at 1 (888) 668-0625 and by mail at Canada Goose Inc. PO Box 61070 Eglinton & Dufferin RO, Toronto, Ontario, M6E 5B2, Canada.

APPENDIX – JURISDICTION SPECIFIC PROVISIONS

Supplemental provisions for California residents

A. Shine The Light Inquiries. California residents have the right to ask us one time each year if we have shared Personal Information with third parties for their direct marketing purposes. To make a request, please send us an email at legal@canadagoose.com, call us at the phone numbers listed in the How to Contact Us section above or submit your request here https://www.canadagoose.com/on/demandware.store/Sites-CanadaGooseUS-Site/en_US/CustomerService-ContactUs?user=true. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry

B. CCPA Requests. California residents also have certain rights with respect to Personal Information under the California Consumer Privacy Act (“CCPA”). For purposes of this subsection, the terms “consumer,” “categories of personal information,” “business purpose,” “third party,” and “sell.” have the meanings ascribed to them respectively in the CCPA. Terms defined under the CCPA may differ in meaning from the common usage of the same terms used elsewhere in this Privacy Policy.

  1. You have the right to request, up to two times every 12 months, that Canada Goose disclose to you the following: (i) the categories of Personal Information that Canada Goose has collected about you; (ii) the categories of sources from which Canada Goose has collected Personal Information about you; (iii) the business or commercial purpose for collecting or selling your Personal Information; (iv) the categories of Personal Information that Canada Goose has sold about you in the last 12 months and the categories of Third Parties to whom the Personal Information was sold, by category or categories of Personal Information for each Third Party to whom the Personal Information was sold; (v) the categories of Personal Information that Canada Goose has disclosed about you for our business purposes in the last 12 months and the categories of Third Parties to whom the Personal Information was disclosed, by category or categories of Personal Information for each Third Party to whom the Personal Information was disclosed; and (vi) the specific pieces of Personal Information that Canada Goose has collected about you. You have the right to request a portable copy of your Personal Information.
  2. In response to verified requests pursuant to #1 or #2 above, we will disclose and deliver the required information to you free of charge within 45 days of receiving a verifiable consumer request. We may extend this time period to provide once by an additional 45 days when reasonably necessary. We will provide notice of the extension within the first 45-day period.

  3. You have the right to request that Canada Goose delete Personal Information collected from you, subject to certain exceptions allowed under applicable law.
  4. You have the right to opt out of the Sale of your Personal Information to Third Parties. Please note that, according to our understanding and interpretation of the CCPA, we do not sell any of your Personal Information. If you would like to opt-out of cookie-based tracking for advertising purposes, you will need to separately adjust your browser settings and set your preferences as described in YOUR CHOICES REGARDING YOUR PERSONAL INFORMATION – Cookies and Interest-Based Advertising above.
  5. Canada Goose will not discriminate against you because you elect to exercise these rights, including by:
    • Denying goods or services to you.
    • Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
    • Providing a different level or quality of goods or services to you.
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

None of the foregoing, however, prohibits Canada Goose from charging you a different price or rate, or from providing a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Canada Goose by your data.

C. Submission of Requests. You or your authorized representative may exercise these rights by submitting the request online here or by calling us at 1 (888) 276-6297. If you wish to submit a CCPA request to have your Personal Information deleted (see section I.A.3 in this Appendix), call us at 1 (888) 276-6297. In order to verify your request, we will require you (or your authorized representative) to provide your full name, your e-mail address, your mailing address and your phone number.

D. Authorized Agents. If you are an authorized agent seeking to submit a CCPA request on behalf of a consumer, you must make your request by emailing us at legal@canadagoose.com and put the words “CCPA Requests, Authorized Agents” in the subject field. You also need to attach to your email proof that you are registered with the Attorney General, as required by law, and proof you have written authority to act for the consumer. You must also provide the full name, e-mail address, mailing address and phone number of the consumer you are representing so we can verify their identity, or provide documentation that you have power of attorney for the consumer pursuant to Probate Code sections 4000-4465. We will not be able to honor requests without sufficient documentation that you are authorized to represent the consumer.

E. Verification. We will take reasonable steps to verify your identity (or the identify and authority of your authorized representative) prior to responding to your requests under CCPA. Upon receiving a request pursuant to #1 or #2 above, we will confirm receipt within 10 days and provide you with information about how we will verify and process the request.

F. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. For example, we may retain Personal Information as permitted by law, and to process transactions and facilitate customer requests. Employment-related Personal Information will not be included in fulfillment of your requests.