Foot Locker Privacy Statement: ( Foot Locker ) is committed to upholding fundamental principles of privacy and security in our relationship with our in-store customers and visitors to our web site. Our objective is to build an enduring relationship between Foot Locker and you based on a foundation of integrity and trust. This Privacy Policy describes the commitments of Foot Locker and your rights regarding personal information. It complies with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and similar provincial legislation, and is based on the Canadian Standards Association s Model Code for the Protection of Personal Information. Our commitment to you is based on the following principles: 1. Accountability Who is Responsible for Your Information Foot Locker is responsible for all personal information under its control, including any personal information transferred to any parties for processing, storage or other purposes. 2. Identifying Purposes Why We Collect Your Information Foot Locker may collect, use and disclose personal information, but will identify the purpose for which personal information is being collected at the time of collection or prior to a new use. Unless permitted or required by law, we will not use or disclose your personal information without your knowledge and consent. Foot Locker collects personal information (such as your name, address and telephone number) for the following purposes: To process credit card transactions; To process exchanges or product returns; To conduct refund call backs to determine if refund service was to standard; To service product holds and layaways where available; To communicate information and offers to customers and web site users; To enable customers and web site users to participate in promotions or contests; To process job applications; and To respond to questions, requests for information or complaints. If you have registered to receive communications from us and/or from one of our particular store locations and later change your mind, you may opt out of receiving direct marketing or promotional communications in electronic or printed form by writing to: - 1 -
c/o Customer Service Department 230 Barmac Drive, 2 nd floor Or you may send an email to flcanadacustomerservice@footlocker.com. Or you may call us at 1.866.919.9010. 3. Knowledge and Consent When We Would Need Your Permission Every reasonable effort will be made by Foot Locker to ensure that you understand the purpose for which personal information is collected. Your consent will be obtained, as required, for the collection, use or disclosure of personal information. Foot Locker provides information about the purpose of the personal information collection, use and disclosure through this Privacy Policy, our store teams and our web site. Consent is obtained verbally at the store level, in writing on our store receipt forms, through written registration or ballot forms, electronically through our website, and/or during telephone conversations with customers. When Foot Locker Canada asks its customers and web site users to supply optional personal information for contests, surveys, e-commerce applications, or for any other purpose, that information will remain private and will not be disclosed to any outside agency, advertiser or third party, unless the customer or user was made aware of this possibility and provided their consent prior to submitting their personal information. Foot Locker reserves the right to collect, use or disclose customer and web site user information without consent when permitted or required by law. 4. Limiting Collection How We Collect and Limit the Information Collected Foot Locker will collect personal information by fair and lawful means and will limit the amount and type of information collected to that required for the purposes identified above or at the time of collection or prior to a new use. Although the amount and type of personal information required depends largely on the purpose for which it is being collected, Foot Locker typically collects the following information: Customer First and Last Name Address Telephone number Signature Credit card number E-mail address In addition, Foot Locker may also collect the following information on an optional basis when web site users register to receive e-mail updates: - 2 -
Demographic information (i.e. sex and age) Preferences regarding brands, music, sports and hobbies 5. Limiting Use, Disclosure and Retention When Information is Used, Who Sees it and How Long We Keep it Foot Locker will only disclose personal information for the purposes for which it was collected, except with your consent, or as required or permitted by law. Subject to any applicable business, legal or regulatory requirements, we will not retain personal information longer than necessary to fulfill the identified purposes and will take commercially reasonable steps to ensure that such information is destroyed in a secure manner. Foot Locker may share personal information with third parties engaged to assist us in providing services to you or to carry out one or more of the purposes described above. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by Foot Locker and to comply with the general privacy principles described in this Privacy Policy. For the purposes set out in this Privacy Policy, we or one of our affiliates or an unaffiliated service provider may process and store your personal information outside of the province in which you reside and/or outside of Canada, and as such, courts in those other provinces or foreign jurisdictions of may, in certain circumstances, be entitled to access your personal information. Foot Locker also reserves the right to disclose and/or transfer personal information to a third party in the event of a proposed or actual purchase, sale (including liquidation, realization, foreclosure or repossession), lease, merger, amalgamation or any other type of acquisition, disposal, transfer, conveyance or financing of all or any portion of Foot Locker or of any of the business or assets or shares of Foot Locker or a division thereof in order for you to continue to receive the same products and services from the third party. 6. Accuracy Keeping Your Information Up to Date Foot Locker will strive to keep all personal information as accurate, current and complete as is necessary for the purpose(s) for which it is to be used. You can help us maintain the accuracy of your personal information by notifying us of any changes to this information. You may contact Foot Locker in any one of the following ways to request correction or update of your personal information: E-mail: Mail: flcanadacustomerservice@footlocker.com c/o Customer Service Department 230 Barmac Drive, 2 nd Floor - 3 -
Telephone: 1.866.919.9010 Fax: 1.717.972.3712 7. Safeguards How We Protect Your Information Foot Locker will take commercially reasonable steps to keep your personal information secure including: Physical measures such as company alarm systems and security codes Organizational measures such as limiting access to the information and staff training Technological measures such as employee personal security identification codes for entering customer information into registers and generally accepted online information security techniques, such as firewalls and encryption 8. Openness How We Make Information about our Practices Available to You Foot Locker will provide you with a copy of this Privacy Policy upon request. This Privacy Policy is also available on Foot Locker s web site located at www.footlocker.ca. 9. Individual Access How We Make Your Personal Information Available to You Upon written request, Foot Locker will provide you with reasonable access to your personal information currently on file. All written requests should be directed to: c/o Customer Service Department 230 Barmac Drive, 2 nd floor Or you may send an e-mail to flcanadacustomerservice@footlocker.com. Foot Locker will respond to requests in writing and: Confirm the type of personal information we have on record and where it is held; Provide you with access to your personal information at either no cost or minimal cost. However, you will be informed of any incurred courier or copying expenses that you may be responsible for in advance; and Allow you to make any necessary updates to your personal information. If Foot Locker is unable to provide access to the personal information, we will advise you of the reason(s) for denying the access request. 10. Use of Our Website Foot Locker does not collect personal information from you unless you provide it to us. This means that you can visit our web site without telling us who you are or revealing any personal information. However, if you are required to submit registration information - 4 -
as a prerequisite for accessing any content area of our web site or to use any of its interactive services, contests, or e-commerce applications, we will not disclose or sell that personal information to any outside agency, advertiser or other third party, unless you were made aware of this possibility prior to submitting your personal information. Although Foot Locker may use "cookies" to track user patterns, Foot Locker will not use cookies to learn the identity of its users, nor attempt to track users after they leave Foot Locker web site. Further, cookies will not be used by Foot Locker to gather specific personal information about individual users. The usage patterns tracked by individual cookies will remain confidential and Foot Locker will not participate in any external site tracking programs. Nor will we share any cookie-generated information about individual users or user patterns with outside agencies or advertisers. A Foot Locker advertiser may be given summaries of collective user patterns. For example, an advertiser might be told their ad was viewed by 6,000 users on a particular day and 100 clicked on the ad. But an advertiser will never be given information about individual users or their browsing habits. Foot Locker will compile site-wide demographic information that it will share with advertisers, but it will not compile profiles of individual users, including the gathering of names, addresses, e-mail addresses and other personal information, to be shared with an advertiser, unless the user has consented to the compilation of this material and submitted it freely in a registration form or survey. Foot Locker tracks user IP addresses for the purposes of systems administration, demographic profiling and traffic logging, but Foot Locker will not use IP addresses to try to identify individual users of the Foot Locker web site Our web site may contain links to other web sites. Please note that when you click on one of these links, you are entering another site. Foot Locker is not responsible for how such linked sites collect, use or disclose your personal information, so we encourage you to read the privacy statements of these linked sites as their privacy policies may differ from ours. 11. Resolving Your Concerns How to Get Your Questions Answered You may submit a question or complaint concerning our policies, procedures and compliance with respect to this Privacy Policy. You may submit your question or complaint in writing to: c/o Human Resources Department 230 Barmac Drive, 2 nd floor Attention: Director of Human Resources Foot Locker will maintain procedures for addressing and responding to questions or complaints about our handling of personal information in a fair and timely manner. - 5 -
If the complaint is deemed to be justified, Foot Locker will take appropriate measures to resolve the complaint. If the matter is not resolved to your satisfaction, we will provide you with information on other recourses available to you. 12. Exceptions, Qualifications and Amendments We Will Abide by the Law We may collect, use or disclose personal information when required or permitted by law or in the good-faith belief that such action is necessary in order to conform to the edict of the law or comply with court orders, valid search warrants and subpoenas. As with all Foot Locker policies and procedures, this Privacy Policy is subject to all applicable laws. Foot Locker reserves the right to amend this Privacy Policy from time to time without notice. The Privacy Policy made available at Foot Locker store locations or posted at any time or from time to time via our web site located at www.footlocker.ca shall be deemed to be the Privacy Policy that is in effect. - 6 -