Privacy Policy

Last Revised: 19 May 2018

Our Commitment to Privacy

Gap Inc. and our affiliates and subsidiaries in the European Union, including GPS (Great Britain) Limited, Gap Europe Limited, Gap (UK Holdings) Limited, Gap (France) SAS, Gap Stores (Ireland) Limited, and Gap (Italy) SRL (collectively, "Gap Inc."), and our brands, including Gap, Banana Republic, Old Navy, Gap Factory, Banana Republic Factory, and Athleta (collectively, our "Brands") value our customers and respect your privacy.

This policy describes the personal information Gap Inc. and our Brands collect about you, why we collect it, how we use it, and when we share it with third parties. This policy covers our European stores and online experiences including our websites and mobile apps. Our policy also describes the choices you can make about how we use your personal information. If our information practices change, we will post an updated policy on our website. You can tell if the policy has changed by checking the revision date that appears above.

If you have any questions about our Privacy Policy, please contact us as described in the section entitled, "How do I contact you?" below.

What kind of information does Gap Inc. collect?

We collect personal information from you, which is information that identifies you as an individual or relates to an identifiable individual.

  • This may include your name, email address, postal address, phone number, credit card, bank card, cheque and other payment details, gender, birthday, photographic & video images, anticipated due date for expectant mothers and personal interests preferences when you visit one of our websites or stores, install or use our mobile apps, place an order online or by phone, make an in-store purchase, save your information with us online, contact us with a question or concern, or participate in a contest, promotion, or survey. We maintain a record of your product interests and the purchases, returns and refunds you make online, through a mobile app, by phone and in our stores.

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

We may combine personal information with information about your online and in-store transactions and other interactions with us, including your purchases. We may also combine your personal information with information we receive from other sources.

  • Such other sources include, for example, joint marketing partners, public databases, publicly available pages on social media platforms and other third parties.
  • If you choose to engage in social sharing, such as by connecting your social media account to your customer account or by logging into your customer account from your social media account, the social media site may share information with us about your use of their services, including profile information, information about your contacts and content you have viewed or liked. Please refer to the social media site’s privacy settings to control how your information is shared.

If you submit 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.

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Where is personal information stored?

Personal information about you may be processed or stored on servers hosted in various countries, whether within or outside of the European Economic Area ("EEA"). Accordingly, this means that your personal information may be transferred outside of the EEA to various countries, including 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 will 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.

  • Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal information.

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How does Gap Inc. use my information?

We may use your personal information for legitimate business purposes, including the following:

  • Providing our products and services and fulfilling your requests.
    • To process and fulfil your order, including to send you emails to confirm your order status and shipment and to administer your customer account.
    • To respond to your inquiries and fulfil your requests.
    • To allow you to use our in-store and online technologies.
    • To make your shopping experience easier, more enjoyable and more efficient.
    • To allow you to enrol and participate in a loyalty or customer relationship program.
    • To allow you to apply for an offer of credit from a payment card provider.
    • To send administrative information to you, such as changes to our terms, conditions, and policies.
    • To provide you with customer service and for complaints handling purposes.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

  • Providing marketing materials and facilitating social sharing.
    • To send you marketing communications about our products, services, contests, and promotions that we believe may be of interest to you, by email, postal mail, telephone, text message, or other means including social media.
    • To facilitate social sharing that you choose to use.

We will engage in these activities with your consent or where we have a legitimate interest.

  • Analysis of personal information for business reporting and providing personalised services.
    • To help us learn more about your shopping preferences.
    • To provide consistent, personalised services across all channels and all of our Brands, including to personalise our advertising, marketing communications, shopping experiences and promotional offers.

We will provide personalised services either with your consent or because we have a legitimate interest.

  • Allowing you to participate in promotions and events.
    • To organize local community events, promotions and in-store experiences.
    • To administer and fulfill our contests and other promotions.

We will engage in these activities to manage our contractual relationship with you or because we have a legitimate interest.

  • Accomplishing our business purposes.
    • To address problems with and improve our products, brands, services and technologies, as well as to develop new products and services.
    • To prevent, detect, mitigate and investigate fraud, health and safety incidents, security breaches and activities that are or potentially may be prohibited or illegal.
    • To enforce our Terms of Sale and Use.
    • As we believe to be required or appropriate to protect the rights, property, safety and security of Gap Inc. and our employees, customers and others.
    • As we believe to be required or appropriate under applicable law, to respond to requests from government authorities and to comply with the legal process.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.

You always have the choice not to receive marketing communications from us. For instructions on opting out, please see the "How do I make choices about receiving promotional communications?" section below.

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How does Gap Inc. share my information?

We share your personal information in the following ways:

  • To our affiliates for the purposes described in this Privacy Policy.
    • When you provide personal information to one of our Brands, we may share that information with our other Brands for the purposes described in this Privacy Policy. Our Brands are operated by our various affiliates and subsidiaries. You can consult the list and location of our Brands here.
  • You may elect to disclose personal information.
    • You may disclose personal information when you post content to our websites, in-store technologies or other public forums, such as our Brands’ social media pages, blogs, and online product reviews. Any information that you disclose through these services will become public.
    • Your personal information will be disclosed in connection with your social sharing activity, such as if you log into your customer account from your social media account. By connecting your customer account and your social media account, you authorise us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy.
  • To our service providers, to facilitate services they provide to us.
    • These can include providers of services such as customer information management, fulfilling promotions, sending communications to our customers, conducting surveys, website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, network security, customer service, auditing, and other services. We do not authorize any of these service providers to make any other use or disclosure of your information.
  • To third parties with which we partner.
    • We share your information when we team up with another company to offer or provide products, services, contests, or promotions to our customers.
  • In connection with a scrip or loyalty program.
    • If you choose to participate in any third-party scrip, loyalty, or similar program in which a Gap Inc. Brand is a participating vendor, and you authorize Gap Inc. or our credit card processor to provide information about your purchases to the company administering the program, we will share your personal information with that program. Scrip programs allow you to instruct us to divert a percentage of the amount you spend on Gap Inc. purchases to participating schools and other non-profit organizations. Loyalty programs allow you to earn “points” or “stamps” on purchases at Gap Inc. brands, which you may then use toward certain rewards offered by the loyalty programs in which you participate. The information you authorize us to disclose to the third-party scrip or loyalty program may include your credit card number and the date and amount of your purchase, and may also include your name, date of birth, gender, shopping preferences and other information you have asked us to provide. Please note that once we disclose this information, the scrip or loyalty company may use and share it with others in accordance with its own privacy policy. You should review these policies carefully, as we have no control over them.
  • Other uses and disclosures.

We also use and disclose your personal information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • This can include laws outside your country of residence.
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information we believe is important.
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons.
    • To enforce our terms and conditions.
    • To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any 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). Such third parties may include, for example, an acquiring entity and its advisors.

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What other information does Gap Inc. collect?

We collect information that does not reveal your specific identity or does not directly relate to an individual, such as browser and device information; information collected through cookies, pixel tags and other technologies, demographic information and other information provided by you; and aggregated information.

We may use and disclose such information for any lawful purpose. If required, we will treat such information as personal information in accordance with this policy. We will also treat such information as personal information to the extent it is combined with personal information. For example, when you use our technologies, we may keep a record of your product interests, the purchases you make and other content you generate (such as adding items to your shopping cart/trolley).

We may collect information in a variety of ways, including:

  • Through your browser or device.
    • Certain information is collected by most 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, Internet browser type and version, and browser click-through and usage data. We use this information to ensure that the services we offer function properly.
  • Through our mobile applications.
    • When you download and use one of our mobile applications, we may track and collect usage data, such as the date and time the app on your device accesses our servers and what information and files have been accessed, viewed and/or downloaded to the app based on your device number or other identifier.
  • Using cookies.
    • Cookies are pieces of information stored directly on the computer that you are using. Our websites, online advertisements, and emails use cookies, pixel tags, and other technologies to automatically collect information about your interactions, such as browser type, pages viewed, links clicked, and other actions you take in connection with our websites, online ads, and email. We use the information for a variety of purposes, including to facilitate navigation, to display information more effectively, to personalise your experience, to understand how our websites are used, to measure the success of our marketing campaigns, and for security purposes. If your browser is set to decline cookies, you may not be able to access your customer account or make a purchase on our websites. To learn how we use cookies for advertising, please see the section, "How is my information used for behavioural or targeted advertising and what choices do I have?" below.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. If you do not accept cookies, you may experience some inconvenience in your use of our sites. For example, you may not be able to access your account information or make a purchase on our websites.

  • Using pixel tags and other similar technologies.
    • We may use pixel tags to, among other things, track the actions of users of our sites and services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of our sites and services and response rates.
  • Using Adobe Flash technology.
    • We may use Adobe Flash technology, including Flash Local Shared Objects (“Flash LSOs”), and other similar technologies to collect and store information about your use of our websites and mobile applications. You can adjust your Flash player settings to block Flash LSO storage on your computer using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to limit acceptance of Flash LSOs may interfere with the functionality of some Flash applications, including those used in connection with our websites and mobile apps.
  • IP Address.
    • Your Internet Protocol (“IP”) address is a number that is automatically assigned to the computer that you are using by your Internet service provider. An IP address may be identified and logged automatically in our server log files whenever you access our websites, along with the time of the visit and the pages that were visited. Your IP address may also indicate your approximate physical location. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other technologies. We use IP addresses for purposes such as calculating usage levels and diagnosing server problems. We may also derive your approximate location from your IP address.
  • Physical Location.
    • We may collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with personalised location-based services and content. You may be permitted to allow or deny such uses, but if you do deny them, we may not be able to provide you with a personalised user experience.
  • In-Store Technologies.
    • We may provide in-store technologies to help personalise and improve your shopping experience. These technologies may require the collection of certain information about your mobile device, such as your MAC address or other device identification information and may also permit you to submit personal details for increased levels of personalization, such as your interests, shopping preferences, and sizing information.
  • Aggregated Information.
    • We may aggregate and/or anonymise 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.

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What if I connect to Gap Inc.’s in-store Wi-Fi services?

If you choose to connect to our in-store Wi-Fi services, Gap Inc. will receive information about you and your device, and may associate it with other information we have collected from and about you.

  • This may include your device’s MAC address, IP address, received signal strength indicator (RSSI) and technical details about your device such as its operating system and device type (including make and model) and technical capabilities. If you have given your device a name, we may receive it. We will also receive information about how you use our Wi-Fi network while you are connected, including the store location, 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. We collect this information each time you connect to the Wi-Fi services.

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.

As a convenience, in certain stores, we may provide you with an option to stay connected to our Wi-Fi networks.

  • If you choose this option, you will be automatically logged into the Wi-Fi network of any stores offering automatic connection to Wi-Fi services, and we may collect the information described above even if you do not actively use your Internet browser or your mobile applications during your time in our store. You can choose to disconnect from the Gap Wi-Fi network at any time through your device’s Wi-Fi settings. However, please note that disconnecting from one store’s Wi-Fi network will only disconnect you from that network during your current visit. You may be able to opt out of certain uses of your device information 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.

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What if I use different devices to visit Gap Inc. websites or mobile applications?

In order to provide you with a more efficient and convenient shopping experience, you may be able to access various content or sign into your account from many different devices. If you use different devices to access our sites or our mobile applications, such as your home computer, laptop and/or mobile device, we may be able to link each of your devices with your account.

  • For example, our sites may allow you to access your favourite items or shopping cart via an email link that is unique to your account. By clicking on the link, you will be automatically signed into your account in order for you to continue your shopping experience where you left off. If you choose to click the email link on a new device, we will be able to associate your current device with your account information. Information we have collected from your different devices may be combined with other information you have provided us, including information that is saved in your customer account, and we may use such information to help provide more tailored experiences and consistent services and experiences across all of your devices as explained in this Privacy Policy.

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Why did I receive a marketing email after I made a purchase in a Gap Inc. store?

To provide you with a more seamless customer experience, we keep records of all your Gap Inc. transactions, both online and in-store. For example, if you use a credit or debit card or give the sales associate your email address when you make a purchase in our store, we may associate that information with your online customer account. As described above, we may use information about your purchases to email you about other products and services that we believe may be of interest to you.

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How do I access or change my information?

If you would like to request to review, correct, update or delete personal information that you have previously provided to us, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us by using the contact information provided in the section entitled, “How do I contact you?”, below. We will respond to your request consistent with applicable law.

  • In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (for example, when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

You may also access your personal information at a Gap Inc. website by signing into your account using your email address and password. You will then be able to edit your personal information in your account profile.

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How do I make choices about receiving promotional communications?

Gap Inc. and our Brands want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information, such as information about special offers and sales events, from one or more of our Brands, you can let us know by contacting our customer service as described in the section entitled, "How do I contact you?", below or you can click on the self-service unsubscribe links below or contained within our emails.

Gap Unsubscribe

Banana Republic Unsubscribe

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How does Gap Inc. protect child privacy?

Gap Inc. is concerned about the privacy and safety of children when they use the Internet. We will never knowingly request personal information online from anyone under the age of 16. Our websites are general audience sites and are not targeted to or intended for use by children.

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How is my information used for behavioural or targeted advertising and what choices do I have?

We use our own cookies to help determine which of our ads are shown to you on other websites. To opt out of this targeted online advertising by Gap Inc. that utilizes our cookies, please click here.

We also work with third-party companies that use tracking technologies (including cookies and pixel tags) on our websites in order to provide tailored advertisements on our behalf and on behalf of other advertisers across the Internet.

  • These companies may collect information about your activity on our sites and your interaction with our advertising and other communications and use this information to determine which ads you see on third-party websites and applications. These technologies and the information collected about you may also be used to track your activity across multiple devices. For more information about this practice and to understand your options, including how to opt-out of receiving these tailored advertisements, please visit the European Interactive Digital Advertising Alliance: http://www.edaa.eu/.

We may also use your information such as your email address to deliver customized advertising on social media networks through tools such as Facebook Custom Audiences. You can find out more about these marketing programs by reviewing the privacy policies of the social media sites you use.

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What if I apply for a Gap Inc. branded credit card on your site?

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.

What if I participate in local store programs?

We may provide special opportunities for customers in certain stores or locations to receive personalised shopping or other services, such as notification when your favourite products will be in your local store, product recommendations, unique offers for certain community members such as teachers or fitness instructors, and invitations to special local events.

  • In order to provide these personalised services, a sales associate may ask for information about your interests, activities, shopping preferences and other people for whom you are shopping. We may also keep records of your sizing preferences, product wish lists, local store transaction history, and contact information. In certain countries, we may use your information to contact you by phone or text message, in accordance with this policy. In certain instances you may also be able to authorize a sales associate to make purchases on your behalf using payment information you have previously provided during an online or in-store transaction.

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How do I know my personal information is secure?

We do our best to provide you with a safe and convenient shopping experience. We have in place physical, electronic, contractual, and managerial safeguards to help protect the security and privacy of your personal information.

If for any reason you cannot access the secure server, or if you’re not quite comfortable shopping online at any of our websites, please feel free to place your order with us by telephone at the number listed in the section entitled, "How do I contact you?" below.

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What about links to other websites?

For your convenience and information, our websites may contain links to other sites, which may have privacy policies that differ from our own. We are not responsible for the content or practices of any linked site. We recommend that you review the privacy policy of any site that you access through our sites.

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How long do you retain my information?

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

  • The criteria used to determine our retention periods include:
  • The length of time we have provide our services to you or have another business need (for example, for as long as you have an account with us);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

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How do I contact you?

In the UK, Gap Europe Limited 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, 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

For questions about our Privacy Policy please contact us at privacy@gap.com.

How do I lodge a complaint with a data protection authority?

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 at:

 http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

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