PRIVACY NOTICE

Effective Date: January 1, 2023

Version 4.0

This Privacy Notice describes our handling of Personal Information in connection with your activities in our locations or your use of our websites, mobile applications, or the services we provide.  By visiting our locations, websites, or mobile applications or using our services, you hereby consent to these terms.  

“Personal Information” refers to both online and offline information that identifies you or that can be reasonably linked to you as an individual. We encourage you to read this Privacy Notice which describes how we collect, use, disclose, share/sell, and protect your Personal Information, and the choices you have regarding your Personal Information. 

1. Personal Information Collected and How It is Collected

Types of Personal Information that we, or our service providers on our behalf, may collect:

• Name and contact information such as postal address, email address, and phone number
• Digital information, including your device IDs, browsing/search history, referring URL, browser, operating system, IP/MAC address, and your direct interactions on our websites or mobile apps such as text typed, pages visited, links clicked, keystrokes/cadence, and mouse movements
• Your transaction information, including purchases/returns/exchanges of products and services and your loyalty program activity information
• Payment card number and other payment information
• Your Account Number or Loyalty Program ID

In certain situations, we, or our service providers on our behalf, may also collect data such as:

• Driver's license number (for example, if you return a product)
• Signatures (for proof of delivery or shipment receipt tracking)
• Location information (such as when you manually provide your location and ask us to tell you about nearby stores or when you allow location sharing when using our mobile apps)
• Demographic and preference information (to help find products or services that may be of interest to you)
• Survey responses, chat sessions, and feedback (regarding products/services purchased, customer service interactions, and your customer experience)
• Advertising interactions (such as cookie IDs, device advertising IDs, which ad was served, and the URLs where the ads are served when you interact with our emails or online/mobile ads)
• Voice, Chat, Video, and CCTV Recordings (for example, calls and messaging with customer service, our sales team, or chat vendor for quality assurance, training, or analysis, or when visiting stores that use security cameras (video only))
• School affiliation (based on program participation)
• Photos or graphic images and files (if you receive product deliveries or request certain services from us)
• Employer name and business contact information (if your company has a business relationship with us)
• Your postal mail (if you participate in that program with us)
• Your business contact, relationship, or transactional information (if interacting with us in a business-to-business scenario)
• Inferences drawn from or created based on some of the information identified above

Personal Information is collected from the following:

• Information You Provide Us Directly.  We collect Personal Information from you directly, for example, in connection with a purchase (in-person or via our websites or mobile apps), a service, a promotion/event, a customer service request, a survey, or an application for a membership program. When using our mobile apps, we may also ask you to grant us access to the camera, photo library, or microphone on your mobile device to enable certain features such as scanning bar codes and speech-enabled search.
• Information Collected Through Automated Technologies.  We and our partners may use cookies, tags, web beacons and other technologies on our web properties and mobile applications to track and collect some Personal Information made available through your activity on our sites/apps, such as shopping/search activity and other interactions with our online services. We, and a technology partner, may collect your direct interactions on our websites or mobile apps such as text typed, pages visited, links clicked, keystrokes/cadence, and mouse movements to monitor how you interact with our website and for troubleshooting purposes. We also use cookies to enable core site functionality, to analyze website usage so that we can measure and improve services and performance, and to serve ads that are relevant to your interests.  Cookies “remember” your device/browser when you return to a website and make your experience more personalized and user-friendly and allow us to better understand how our websites are used to improve the experience.

If you use a mobile device, your device may disclose location information (when you enable location services) with our websites, mobile applications, services, or our service providers. For example, precise geo-location can be used to help you find our nearby locations.

• Information We Receive from Other Parties.  We may obtain information about you from other sources to enhance our existing information for purposes such as prospecting, marketing, fraud detection, and/or improving the information you have provided.

Our sites and mobile applications may allow you to sign-in to our digital property using a social media network login and we may also include other social media features, such as a “share this” button. In these cases, we may receive information from the social media network, including your profile information, picture, user ID associated with your social media account, and other information you permit the social media network to disclose with partners. The data we receive from these social media networks is dependent upon their policies and your privacy settings on that partner site. You should always review and, if necessary, adjust your privacy settings on these websites and services before utilizing these features.

Minors

Our websites and online mobile applications are not directed toward children under 13 years of age.  We do not knowingly collect online Personal Information of children under 13 years of age without parental/guardian consent.  

2. How We Use Personal Information

Personal Information may be used for the following purposes:

• To Communicate with You and to Provide, Support, and Improve our Products, Services, and Programs.  We use Personal Information to process your orders, purchases, refunds/exchanges, and requests for products, services, or information.  We may also use your Personal Information to create and maintain your accounts, to enable order shipment tracking notifications, to provide customer service, to administer our credit card/gift card programs, to personalize your shopping experience, to identify your preferences, to draw inferences, to provide you services across multiple devices, to improve the functioning and performance of our digital properties, to enable certain mobile app functionality (such as using your location to help you find our nearby locations), and to expand our product/service offerings.  We also use your personal information to administer our rewards/loyalty programs.
• Marketing and Advertising.  We use Personal Information to communicate and/or administer our sales/prospecting programs, promotions, contests, sweepstakes, and surveys, and to make you aware of our products and services. We may use your Personal Information to better predict your product/service preferences or interests. We may also use your activity on websites/applications to serve you personalized advertising in order to show you content that is more likely to be of interest to you. (See section 4 below for additional information regarding our Marketing activities.)
• Other Uses.  We use Personal Information for other reasons, including conducting sales research and analysis; preventing or mitigating fraud, illegal activity, and credit risk; support our core business functions; and relating to or complying with legal matters, investigations, and applicable laws and regulations.

3. When We Disclose Personal Information

We may disclose your Personal Information within our family of companies for purposes such as preference management, marketing, customer service functions, and improved user experiences.

We may also disclose your Personal Information outside our family of companies (for example, with partners such as service providers, data processors, contractors, etc.) for various purposes such as:

• Providing the Products or Services you Requested: To process transactions or provide products or services on our behalf. Examples include fulfilling orders for products or services, delivering packages, sending communications, analyzing data, processing payments, transmitting content, managing credit/collections, and providing customer service. We may also disclose your Personal Information with our business partners when you take part in certain programs.
• Sales and Marketing Purposes: To assess, develop, and administer programs, and notify you of promotions and offers for products or services that may be of interest to you.  
• Corporate Transactions: In connection with a merger, acquisition or sale involving all or a portion of our company. 
• Other Reasons: Such as to enhance data and digital properties; to improve our websites/mobile apps and internal business processes; to enhance product review content on other platforms; to enforce the terms of use applicable to our services; to detect, prevent, or mitigate fraud and credit risk, security, or technical issues; to satisfy applicable law, regulations, legal processes, or valid governmental requests; and to protect against imminent harm to the rights, property or safety of our company, our customers or the public as required or permitted by law.
• With Your Consent: In circumstances other than those described above.

4. How We Use Personal Information for Marketing

a. Digital Marketing

We participate in digital advertising to present you with online ads for our products and services that we believe may be of interest to you. We may partner with advertising companies to provide you with relevant content and offers that may be useful to you, we may partner with third-party companies to display content, offers or advertising that is tailored to your interests based on how you browse and shop both on and off our sites. In addition, others (advertisers and ad networks, ad serving companies, or other service providers) may infer user interests based on interactions with, or clicks on, personalized ads or content.  As a result, you may see ads on our websites or other websites based on your purchases, search history, or web/mobile browsing activities (for instance, an ad from us may be displayed to you on another website if you recently browsed for office supplies). These interest-based ads (also sometimes called “personalized or targeted ads”) are displayed to you based on information collected from your online interactions across multiple websites that you visit, or across multiple devices you may use.

b. Email Marketing

We may use your email address to deliver marketing information, product recommendations, and non-transactional communications about us via email.

c. Direct Mail Marketing

We may use your mailing address to deliver notices of new services/partnerships, offers/coupons, printed catalogs, etc. about us or our products or services via direct mail.

d. Text-Based Marketing (SMS)

We may send you promotional text messages (SMS) when you opt-in to receiving them.

5. Your Choices Regarding Your Personal Information

a.  To Stop Certain Collection and Use of Your Personal Information:

Emails, Texts, Mail, and Notifications

• You can stop promotional emails from us by using the “unsubscribe” link in the footer on our promotional emails or contacting us if you have questions.
• You can stop text messages by replying “STOP” to our text messages.
• You can request to stop postal mail by contacting us as noted in section 8 below.
• You can stop in-app push notifications from our mobile apps by adjusting your Notification Settings.

Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your online account, Rewards account, membership program, or purchases. If you have any questions regarding transactional communications, please see Section 8 below to contact us.

If you are receiving any other communications, have any questions, or continue to receive communications after opting out, please e-mail us at Info@Staples.com.  Please include any relevant information such as a forwarding of the email received, specification of the order number in question, screenshot of the online message, scan of the mailed marketing artifact, etc.  Please note that you may continue to receive communications while we process your request.

If you have any questions regarding the above, please contact us at Privacy@Staples.com.

Interest Based Advertising

Industry groups such as the Digital Advertising Alliance and the Network Advertising Initiative have developed services to help you manage your Interest Based Advertising preferences. Please note that if you opt-out of Interest-Based Advertising, you may still see ads from us, but they will not be as relevant to you.

If your browsers are configured to reject cookies when you visit these pages, or if you subsequently erase your cookies, use a different device, or change web browsers, your opt-out may become ineffective and may need to be repeated.

You may visit the following sites to become more familiar with these entities and their unsubscribe options:

• The Digital Advertising Alliance (DAA): https://digitaladvertisingalliance.org/
• The Network Advertising Initiative (NAI): https://optout.networkadvertising.org/?c=1
• The Interactive Advertising Bureau (IAB): https://www.iab.com/

Website Analytics

We use Google Analytics on our web sites to collect usage data, to analyze how users use the web sites and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

Mobile Apps

If you have granted our mobile apps access to your device’s camera, microphone, location, etc., you may revoke such access by configuring the permissions located in your device’s “Settings”.

Cookie Preferences

You may adjust your cookie preferences using your internet browser setting or, on some of our sites, by using the link in the footer of our website.  Please note that if you clear all cookies on your browser, or use a different browser or computer, you will need to complete the opt-out procedure again.

b. To Correct Your Personal Information

You can request that inaccuracies pertaining to your Personal Information be corrected.

You can update some information by logging into your account or you may contact us as described in section 8 below with changes.  To prevent unauthorized changes, we may ask for certain information to verify your identity before we process such requests.

We may not fulfill your request in some cases, for example, if it requires a disproportionate technical or practical cost or effort or if it conflicts with our legal obligations or business requirements.

6. How We Protect Your Personal Information

We employ technical, physical, administrative, and organizational safeguards to help protect your Personal Information.

Our websites may contain links to other websites, services, social media platforms, etc. operated and maintained by partners. We may also provide social media features that enable you to disclose information with social networks and to interact with us on various social media sites. Your use of these features may result in the collection or sharing of information about you, depending on the feature. These properties, which we do not control, operate independently, and have their own privacy and security practices and statements, which we encourage you to review to make sure you understand the information that may be collected, used, and disclosed by those sites and how it is protected.

Unfortunately, no e-commerce solution, website, mobile application, database, or system can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot guarantee or warrant the security of the information you transmit to or from us. You should also take steps to protect your personal information against unauthorized disclosure or misuse:

• We urge you to keep your passwords secure and confidential and not divulge them to anyone, use different and complex passwords for each account and consider using a commercially available Password Locker or Vault to generate and store your passwords.
• Remember to log off your account and close your app/browser window when you have finished your visit. This is to help ensure that others do not access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
• Other public online safety resources:
  • https://staysafeonline.org (National Cyber Security Alliance)
  • https://www.consumer.ftc.gov (FTC)
  • https://www.aarp.org (AARP)
  • https://www.bbb.org (Better Business Bureau)

If you think the Personal Information you provided to us has been improperly accessed or used, or if you suspect that unauthorized purchases have been made on our websites using your Personal Information, please see Section 8 below to contact us immediately.

7.  Customer Specific Disclosures

a. Contract or Business Customers

If you are a contract customer and would like to opt-out of receiving promotional postal mail and/or email from us, please notify your Account Managers.

If you are a business entity receiving unsolicited communications from us and do not have an Account Manager, please see Section 8 below to contact us.

b. Nevada Residents

Under Nevada SB 220, Nevada residents may submit an opt-out request regarding the sale of their Personally Identifiable Information (PII) collected through a website or online service.  You may submit your request to Opt-Out of the sale of Personal Information to third parties by submitting an online request at: Do Not Sell My Personal Information

c. Virginia Residents

This section applies specifically to residents of Virginia, in addition to all other non-state specific information contained in this Notice and sections 7.e. and 7.f. below.

Virginia residents have the following rights under the Virginia Consumer Data Protection Act (VCDPA):

• 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.e. 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 of the information.
• Right to Opt-Out. You may opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• 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 VCDPA.

To exercise the rights applicable to you, see instructions below in section 7.f. How to Exercise Your State-Specific Privacy Rights.

Targeted Advertising:

We may participate in targeted advertising.  You have the Right to Opt-Out of this advertising, as described above.

Appeal Process:

Virginia residents may submit an appeal for refusals to take action on your request by emailing Privacy@Staples.com with your name, email address, phone number and request id of the original request.

De-identified Data:

In any instances where we maintain data in a de-identified format, we will not attempt to re-identify the data.

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

d. California Residents

1. California Shine the Light Law

Under California Civil Code sections 1798.83–1798.84, California residents may request a notice disclosing the categories of personal information we have disclosed with third parties, for the third parties’ direct marketing purposes, during the preceding calendar year. If you are a California resident and would like to make such a request, please see Section 8 below to contact us. Please allow 30 days for a response.

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

This section applies to residents of California, in addition to all other non-state specific information contained in this Notice and sections 7.e. and 7.f. below.

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.e. 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 7.f. How to Exercise Your State-Specific Privacy Rights.

Authorized Agent:

You may designate an authorized agent to exercise your rights under th