Rack Room Shoes Applicant, Employee, Contractor, and Former Personnel Privacy Notice

Effective Date: 9/3/2026

This Applicant, Employee, Contractor, and Former Personnel Privacy Notice (this “Notice”) explains how Rack Room Shoes, Inc. and its affiliated companies (collectively, “Rack Room Shoes,” “Rack Room,” “we,” “us,” or “our”) collect, use, disclose, retain, and otherwise process Personal Information relating to individuals who interact with us in a personnel-related context. This Notice applies to applicants for employment, current employees, former employees, independent contractors, consultants, temporary or staffing agency workers, and individuals applying for internal positions (collectively, “Personnel”). It also covers Personal Information that we collected from or about you when you applied for employment with Rack Room, Personal Information collected when you apply or have applied for other positions internally during your employment with us, and Personal Information collected through your engagement, and carrying out of your services, as a contractor, consultant, and temporary/staffing agency worker. Depending on your relationship with Rack Room Shoes, the Rack Room Shoes entity that manages or managed your employment or engagement acts as the primary controller of your Personal Information.

This Notice applies regardless of whether you interact with us online, in person, or through other means, and supplements any additional local notices provided at or before the time of collection, including the California Notice at Collection contained this Notice. If there is a conflict between this Notice and a legally required local notice, the local notice will control.

Personal Information We Collect
Depending on the nature of your relationship with Rack Room Shoes, we may collect the following types of Personal Information about you. “Personal Information” means any information related to an identified or identifiable natural person, subject to applicable data privacy and protection laws. Personal Information includes the term “personal data” as used in applicable data protection laws. The specific Personal Information we collect may vary based on your role and interaction with us and may not include all of the examples listed below.

• Identifiers and Contact Information: name, alias, preferred name, maiden name(s), postal address, email address, telephone number, online identifiers, usernames, passwords, personnel or contractor identifiers, and government-issued identifiers (such as Social Security number, tax ID, passport, visa, or driver’s license), where permitted or required by law.
• Characteristics of Protected Classifications: date of birth (and age), gender, race, ethnicity, veteran or disability status, or other protected characteristics, where collection is permitted or required by applicable law.
• Professional, Employment, and Engagement Information: application materials, resumes or CVs, interview notes, employment or engagement history, job title, department, work location, compensation, performance evaluations, disciplinary records, separation details, contractor engagement information, and work authorization status.
• Education and Qualifications: education history, degrees, certifications, licenses, skills, training records, and professional affiliations.
• Compensation, Benefits, and Financial Information: payroll information, benefits elections, retirement or savings plan information, pension or post-employment benefit information (if applicable), expense reimbursement details, and tax-related records.
• Timekeeping and Attendance Information: work schedules, attendance records, time and leave records, and requests for time away from work.
• Internet or Other Electronic Network Activity Information: system access logs, IP address, device identifiers, login credentials, application and website usage, active and idle time, and other activity on Rack Room Shoes systems, applications, portals, and networks, and interactions with workforce-facing digital tools.
• Geolocation Data: approximate geographic location derived from IP address, facility access logs, or workplace systems, where permitted by law.
• Audio, Electronic, Visual, or Similar Information: CCTV footage, photographs, video recordings, badge access records, call recordings, and recordings, transcripts, and chat from meetings, calls, and training sessions conducted on company collaboration platforms, and other security or monitoring records.
• Communications and Interaction Data: emails, messages, customer or personnel support requests, chat communications, survey responses, and other communications with us.
• Health and Safety Information: occupational health and safety records, accommodation documentation, medical leave-related documentation, and drug screening or background check information, where permitted by law.
• Categories Listed in the California Customer Records Statute: contact information, payroll and tax information, benefits enrollment information, emergency contact details, and other information described in Cal. Civ. Code § 1798.80(e), where applicable in a personnel context.
• Sensitive Personal Information: such as Social Security number, government identifiers, account login credentials, precise geolocation, health information, biometric data, or union membership, where collected as permitted by law. We do not use Sensitive Personal Information for the purpose of inferring characteristics about you, except as permitted by applicable law.
• Inferences: inferences drawn from other Personal Information to support personnel administration, security, compliance, and operational purposes.

How We Collect Personal Information
In accordance with applicable law, we may collect Personal Information from the following sources. The specific sources from which we collect information depend on your relationship with us and how you interact with Rack Room Shoes:

• Directly from you: when you apply for a position; accept or manage employment or engagement; complete onboarding or benefits forms; participate in training; communicate with us; use workforce systems; or otherwise interact with us online, in person, or through our facilities.
• Created by us: information generated in the course of managing the personnel relationship, such as account credentials, employment or engagement history, performance information, preferences, and inferences drawn from your interactions with our systems.
• Service providers and parties acting on our behalf: recruiters, background screening providers, payroll and benefits administrators, staffing agencies, IT providers, security vendors, consultants, and other service providers that perform services for us.
• Affiliates and related companies: where permitted by law, for administrative, operational, and business purposes.
• Public sources: publicly available sources such as professional networking sites, public records, or information you choose to make publicly available, where permitted by law.
• Government authorities and other third parties: including courts, regulators, or law enforcement agencies, where required or permitted by law.
• Automatically through your interactions with us: through the use of cookies, tracking technologies, access control systems, security monitoring, and other technologies when you use our websites, systems, equipment, applications, portals, networks, or facilities.

Where permitted by applicable law, we may combine Personal Information collected from one source with information obtained from other sources.

 
How We Use Personal Information
In accordance with applicable law, we may use Personal Information for the following purposes:

• Recruiting: recruiting, screening, interviewing, hiring, and onboarding applicants, employees, contractors, and other personnel.
• Personnel and Relationship Administration: managing employment or contractual relationships, workforce planning, scheduling, training, performance management, and internal reporting.
• Compensation, Benefits, and Post-Engagement Administration: administering payroll, benefits, retirement or savings plans (if applicable), insurance, expense reimbursement, tax reporting, and post-employment or post-engagement obligations for former employees, contractors, consultants, and temporary/staffing agency workers.
• Technology and Operations: providing, maintaining, and securing workforce systems, portals, applications, networks, and facilities.
• Communications: communicating with you regarding your application, employment or engagement, benefits, training, support requests, and other personnel-related matters.
• Analytics and Business Operations: conducting analytics, audits, reporting, improving operations, and supporting internal business functions.
• Security, Fraud Prevention, and Integrity: protecting our personnel, facilities, systems, and business; detecting, preventing, and investigating security incidents, fraud, or policy violations.
• Legal, Compliance, and Protection of Rights: complying with applicable laws and regulations; responding to lawful requests; enforcing policies; and establishing, exercising, or defending legal claims.
• Corporate Transactions: evaluating or carrying out mergers, acquisitions, reorganizations, or other corporate transactions.
• Consent: for other purposes disclosed to you at the time of collection or with your consent.

Where permitted by applicable law, we may deidentify or aggregate Personal Information so that it can no longer reasonably be used to identify you and use such information for lawful business purposes. We maintain deidentified information in accordance with applicable law and do not attempt to reidentify it. Where permitted by law, we may also process Personal Information for additional purposes that are compatible with those described above.

 
Disclosure of Personal Information
We may disclose Personal Information for the purposes described above and as necessary to operate our business to the following categories of recipients:

• Affiliates and Related Companies: for administrative, operational, and business purposes, where permitted by law.
• Service Providers and Vendors: agents, contractors, consultants, and service providers that perform services on our behalf, such as recruiting, background screening, staffing, payroll, benefits administration, workers compensation, IT support, security, analytics, and professional services.
• Professional Advisers: insurers, auditors, accountants, attorneys, and other professional advisers.
• Government Authorities and Law Enforcement: where required or permitted by law to comply with legal obligations or protect rights and safety.
• Business Transaction Parties: in connection with mergers, acquisitions, reorganizations, financing, bankruptcy, or sale or transfer of business assets.
• With Your Consent or at Your Direction: where you request or authorize disclosure.

We require service providers to process Personal Information only on our behalf and in accordance with contractual safeguards.

Workplace Monitoring and Tracking Technologies
To operate, secure, and manage our workplace, we monitor and log activity on Rack Room Shoes systems, devices, networks, and facilities, and we use certain tracking technologies on our workforce-facing and careers websites and applications. You should not expect that your use of company systems, accounts, or devices is private, except where applicable law provides otherwise. We conduct monitoring for legitimate business purposes, including security, system integrity, compliance, quality, safety, productivity, and the protection of our personnel, customers, and information.

Systems, Communications, and Activity Monitoring
Where and as permitted by applicable law and consistent with any separate workplace monitoring notices or policies, we may monitor, access, record, and retain:

• Systems and network activity: use of company devices, applications, networks, internet access, and accounts, including access logs, security events, and stored files and communications on company systems;
• Communications: business communications sent or received using company email, messaging, collaboration, and telephone systems; personal communications sent or received using company email, messaging, collaboration, networks, internet, and telephone systems;
• Productivity and activity information: where deployed, software that records application and website usage, active and idle time, and related activity metrics for security, compliance, and workforce-management purposes;
• Meetings and recordings: audio, video, transcripts, and chat from meetings (such as through MS Teams, calls, and training sessions conducted on company collaboration platforms (such as video conferencing tools). Where recording or transcription is enabled, participants are notified at the time through an in-meeting indicator or similar notice, and recording is conducted consistent with applicable consent requirements;
• Facilities and physical security: CCTV in non-private areas, badge and access-control logs, alarm code entries, and visitor records; and
• Location data: approximate location derived from IP address, facility access, or company devices and systems, where permitted by law.

Cookies and Analytics on Workforce and Careers Sites
Our workforce-facing and careers websites, portals, and applications use cookies and similar technologies for purposes such as authentication, security, system integrity, remembering preferences, and analyzing and improving how these sites are used. Some of these technologies are necessary for the sites to function and cannot be disabled; where nonessential analytics technologies are used, you may be able to manage them through available controls. We do not use workforce-facing properties for cross-context behavioral advertising. Where required by law, we recognize and process valid browser- or device-based opt-out preference signals, such as the Global Privacy Control.

Third-Party Services
Our systems and applications may link to or integrate with third-party platforms or services (“Third-Party Services”). We do not control and are not responsible for the privacy practices of those third parties. Personal Information you provide directly to a Third-Party Service is governed by that party’s own privacy notice and terms.

Use of Automated Decision-Making Technology
We may use artificial intelligence, automated decision-making technology, machine learning models, algorithms, and other automated means to support recruiting, workforce management, security, compliance, fraud prevention, and business operations. Automated tools may be used, for example, to:

• Support applicant/candidate matching, screening, or ranking;
• Detect security incidents, fraud, or anomalous activity;
• Manage system access and identity verification; or
• Support workforce analytics and planning.

Where required by applicable law, we will notify you before making decisions based solely on automated processing that produce legal or similarly significant effects and will provide additional information regarding such processing, including meaningful information about the logic involved and the significance of the processing.

Data Transfers
Personal Information may be stored, accessed, or processed in the United States or other jurisdictions where Rack Room Shoes, its affiliates, or service providers operate. We take steps designed to ensure that Personal Information is processed in accordance with this Notice and applicable law wherever it is located, including implementing appropriate contractual, technical, and organizational safeguards.

Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration, or destruction. While no system can be guaranteed to be 100% secure, we continuously evaluate and improve our security practices.

Retention of Personal Information
We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Notice, including administering personnel relationships, complying with legal and regulatory obligations, resolving disputes, and enforcing our agreements. Retention periods vary depending on the nature of the information, the purpose for which it was collected, and applicable law. Retention periods may therefore differ by category of Personal Information and the applicable legal or business requirements. Because a fixed period cannot be stated for every category, we determine retention periods using criteria that include: (i) the length and nature of your relationship with us; (ii) the purpose for which the Personal Information was collected and whether that purpose remains active; (iii) the existence of a legal, regulatory, tax, accounting, or recordkeeping obligation requiring retention (for example, payroll, benefits, and employment records subject to statutory minimums); (iv) whether retention is necessary to establish, exercise, or defend legal claims or to comply with a legal hold; and (v) the sensitivity of the Personal Information and associated risk. When Personal Information is no longer needed under these criteria, we delete, destroy, or deidentify it in accordance with applicable law. 

We may continue to retain and process Personal Information after the end of an individual’s employment or engagement, including for former employees, contractors, consultants, and temporary/staffing agency workers for purposes such as legal compliance, audits, investigations, dispute resolution, defense of legal claims, tax and financial reporting, and record retention required by law.

Changes to This Notice
We may update this Notice from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make material changes, we will update the “Effective Date” above and provide notice through appropriate channels, such as our internal workforce systems or other reasonable means. We encourage you to review this Notice periodically to stay informed about how we process your Personal Information.

 
Contact Us
If you have questions about this Notice or our processing of your Personal Information, or if you would like to exercise any privacy rights available to you, you may contact us using the information below:

 

Rack Room Shoes, Inc.

Attn: Human Resources Department

Address: 8310 Technology Drive

Email: HR@rackroom.com

Phone: (704) 547-9200

If you need this Notice in an alternative format or require a reasonable accommodation to access it, please contact us using the information above and we will work with you to provide a suitable alternative.

California Notice at Collection
This California Notice at Collection supplements this Notice and applies to California residents who are Personnel, as defined in this Notice. It is provided at or before the point of collection and describes the categories of Personal Information collected, the purposes for which the information is used, and other information required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

Unless otherwise stated, this California Notice reflects our current practices and our practices during the twelve (12) months preceding the effective date of this Notice.

Categories of Personal Information Collected & How We Use Personal Information
We collect the categories of Personal Information described in the Personal Information We Collect section of this Notice. The purposes for which we collect and use those categories of Personal Information are described in the How We Use Personal Information section of this Notice.

Sensitive Personal Information
We use Sensitive Personal Information (see the Personal Information We Collect section of this Notice for more information regarding this category of Personal Information) only as permitted by the CCPA, including to administer personnel relationships, comply with legal obligations, ensure workplace safety, and perform other purposes expressly allowed by Cal. Civ. Code § 1798.121(a). We do not use or disclose Sensitive Personal Information for purposes that would trigger a right to limit its use or disclosure under the CCPA.

Deidentification
We or our service providers may deidentify Personal Information and disclose such deidentified information as permitted by applicable law. Where we do so, we maintain the information in deidentified form and do not attempt to reidentify it.

 
How We Collect, Disclose, and Retain Personal Information
We collect, use, disclose, and retain Personal Information about California Personnel as described in the sections of this Notice earlier provided:

• How We Collect Personal Information
• Disclosure of Personal Information
• Retention of Personal Information

 
Sale or Sharing of Personal Information
Rack Room Shoes does not sell or share Personal Information of Personnel for cross-context behavioral advertising as those terms are defined under the CCPA.

 
California Privacy Rights
California Personnel have rights under the CCPA, subject to applicable exemptions, including the right to request access to, correction of, deletion of, or a copy of Personal Information. Rack Room Shoes will not discriminate against individuals for exercising these rights.

 

Requests to exercise California privacy rights may be submitted using the contact information provided in the Contact Us section of this Notice.