CLAIRE’S AND ICING JOB APPLICANT PRIVACY NOTICE

Last Updated: January 1, 2023

Claire’s Stores Inc. (“Claire’s,” “Icing,” “we,” “our,” “us”) provides this Job Applicant Privacy Notice (“Notice”) to explain our practices regarding the collection and use of Personal Information about job applicants (collectively, “Applicants”) within the context of you applying for a job at Claire’s or Icing. 

As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you.  

USE AND DISCLOSURE OF APPLICANT PERSONAL INFORMATION

For the most part, we collect the following categories of Personal Information directly from you. Some categories of Personal Information (such as electronic network activity information) are collected automatically through your use of electronic or telephonic systems, from service providers that help us to run our business, and from third parties. Note that the Personal Information we collect about you may vary depending on the nature of your interactions with us. Personal Information we collect includes:

• Identifiers including real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers
• Personal Records including your name, signature, physical characteristics or description, address, telephone number, education, employment, or employment history
• Characteristics of protected classifications under state or federal law, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, disability, marital status
• Internet or other electronic network activity information including browsing history, search history, and information regarding your interactions with our websites or applications 
• Audio, electronic, visual, or similar information including closed-circuit images (CCTV), photographs and video of you, and audio recordings (for example, video interviews) 
• Professional or employment-related information, including:
  1. Recruitment information (such as skills, qualifications, references, recommendations, and other information included in a resume, application form, or cover letter)
  2. Background information commonly used for security screenings 
  3. Criminal records information including results of background checks obtained through government agencies 
  4. Job applicant profile information (organization information, performance and talent information, employment background, functional experience, leadership experience, honors or awards, education, training, professional certifications, evaluations, developmental planning, career interests and development information, and other talent management and team-based assessments) 
  5. Citizenship, immigration, visa status, and work authorization information (including information from related documents, such as your passport, driver’s license, or other identification, proof of residence, and proof of authorization to work in the United States, and documents you provide with your US Citizenship and Immigration Services Form I-9)
  6. Vehicle information (such as year, make, model, color, and license plate)
  7. Languages spoken
• Inferences drawn from the other categories of Personal Information used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Purposes for Which We Collect Your Personal Information

We may use the Personal Information we collect to:

• Communicate with you;
• Assess your job application;
• Manage recruitment duties and operate our business;
• Manage corporate information technology (including monitoring use of corporate technologies);
• Make it easier for you to log into corporate systems;
• Comply with applicable laws and regulations (such as Equal Employment Opportunity reporting);
• Manage the security of our premises and systems; and
• Detect and prevent fraud or other unlawful or harmful activity.

Disclosures of Applicant Personal Information

We may disclose Applicant Personal Information to our service providers that help us run our business (or for legally permitted internal uses by the service provider), benefits providers, and government authorities as required or deemed necessary to comply with law, or for the following business purposes: 

• Ensuring the security and integrity of Personal Information;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use;
• Performing services on our behalf or assisting us in performing business actions (such as to assess your job application);
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us;
• Processing, maintaining, or collecting Personal Information on our behalf; and
• Detecting or protecting against malicious, deceptive, fraudulent or illegal activity (including to comply with applicable laws and regulations).

Business Transactions. In the event of a business transaction, we may disclose Applicant Personal Information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.

Legal Compliance and Safety. We may also disclose Applicant Personal Information for legal compliance, law enforcement, and public safety purposes. For example, to law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our rights, or agreements with third parties, or for crime-prevention purposes.

We may combine your personal information with data we obtain from our services, other individuals, or third parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, or aggregated data, as permitted by law. 

YOUR CHOICES

If you have a registered job applicant online account, you may be able to adjust update your Personal Information through your account settings or profile. This may not update any previous job applications completed and submitted previously. 

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We generally retain Personal Information for seven years after the length of your employment. Otherwise, we may retain Personal Information for as long as is necessary for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply: 

• Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information; 
• Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected; 
• The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or 
• We are otherwise required or permitted to keep your information by applicable laws or regulations. 

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below. 

CALIFORNIA-RESIDENT JOB APPLICANTS

This section provides supplemental information to California-resident Applicants.

In addition to the Personal Information described above, we may collect (directly from you or from service providers that help us run our business) Personal Information that is considered sensitive under California law, namely: Social security, driver’s license, state identification card, or passport number; Account log-in in combination with any required security or access code, password, or credentials allowing access to an account; and Personal Information that reveals an Applicant’s racial or ethnic origin, religious or philosophical beliefs, or union membership. We collect, use, and disclose Personal Information considered sensitive under California law for the same purposes as described above. 

We do not sell or share for cross-context behavioral advertising the Personal Information of California Applicants.

If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. To exercise any of these rights, please submit a request through our by emailing us at [email protected] or call us at 1-800-CLAIRES. Please note that, depending on your privacy request, you may be asked to provide 2-3 pieces of personal information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the email or toll-free number listed above.

Right to Know. You have the right to request the following details regarding the Personal Information we have collected about you: 

1. The categories of Personal Information we have collected about you, including 
   1. The categories of sources from which the Personal Information was collected
   2. Our business or commercial purposes for collecting or disclosing Personal Information
   3. The categories of recipients to which we disclose Personal Information
   4. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
2. The specific pieces of Personal Information we have collected about you

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. 

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under California law you also have the right not to receive discriminatory treatment by us, including retaliation against you as an Applicant.

HOW TO CONTACT US

You may contact us at 1-800-CLAIRES or email us at [email protected]. You may also write to us at:

Attention: Legal Counsel

2400 West Central Road

Hoffman Estates, IL 60192