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* Staples’ U.S. Privacy Notice

STAPLES’ U.S. PRIVACY NOTICE

PRIVACY NOTICE

Effective Date: July 1, 2023

Version 5.0

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.

Please note that if you are a current or former employee or job candidate, your
Personal Information collected in that context is subject to our Workforce
Privacy Notice rather than this Privacy Notice. This Privacy Notice applies to
your interaction with our companies as a prospective, current or former
customer, visitor, or business partner.

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 or educator affiliations (based on program participation)
* Photos, images, writings, and other files you provide to us (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, a sweepstakes/contest, 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 device/browser
attributes, shopping/search activity, shopping cart abandonment, and other
interactions with our online services. We, and our technology partners, 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, for fraud detection, 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 and to measure advertising effectiveness. (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 and our business clients when
you take part in certain programs or purchase from certain sites operated by
us.
* 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 participate in commercial trade credit
programs; 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. Under applicable law in certain
jurisdictions, the disclosure of your personal information to third parties in
connection with targeted advertising or advertising analytics may be considered
a “sale” of personal information or the processing/sharing of personal
information.

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 (SMS) OR NOTIFICATION MARKETING

We may send you promotional text messages (SMS) when you opt-in to receiving
them. We may also send you push notifications to your device when you have our
mobile app installed.

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, including when you use our websites,
mobile apps, in-store devices/equipment, services, etc.

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 internet transmission, 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. COLORADO RESIDENTS

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

Colorado residents have the following rights under the Colorado Privacy Act
(CPA):

* 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.h. 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
information for purposes of (i) targeted advertising, (ii) the sale of
personal information, 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 CPA.

To exercise the rights applicable to you, see instructions below in section 7.i.
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:

Colorado 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 instances where we de-identify your Personal Information to prevent it from
being linked to you as an individual, we will maintain and use it in a
de-identified format and will not attempt to re-identify the Personal
Information.

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

C. CONNECTICUT RESIDENTS

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

Connecticut residents have the following rights under the Connecticut Data
Privacy Act (CTDPA):

* 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.h. 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
information for purposes of (i) targeted advertising, (ii) the sale of
personal information, or (iii) profiling in furtherance of solely automated
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 as permitted by the CTDPA.

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

Targeted Advertising:

We may participate in targeted advertising and/or the sale of data. You have
the Right to Opt-Out of this processing as described above.

Appeal Process:

Connecticut 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:

Sensitive Data:

In instances where we process your sensitive data, we will provide you notice
and an opportunity to consent to the processing of that 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 CTDPA.

D. 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.

E. UTAH RESIDENTS (EFFECTIVE 12/31/23)

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

Utah residents have the following rights under the Utah Consumer Privacy Act
(UCPA):

* 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.h. below
describes the personal information we collect about you, you have the right
to make a request to know, get access to, and obtain a copy of information
you provided to us 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, 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 Opt-Out. You may opt out of the processing of your personal
information for purposes of (i) targeted advertising or (ii) the sale of
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, or opt out is not
discriminatory, nor is charging a fee for excessive or repetitive consumer
requests as permitted by the UCPA.

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

Sensitive Data:

In instances where we process your “sensitive data” as defined under the UCPA,
we will provide you notice and an opportunity to opt out of the processing of
that 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 UCPA.

F. 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.h.
and 7.i. below.

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

To exercise the rights applicable to you, see instructions below in section 7.i.
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:

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.

G. 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.h. and
7.i. 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.h. 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.i.
How to Exercise Your State-Specific Privacy Rights.

Authorized Agent:

You may designate an authorized agent to exercise your rights under the
CCPA/CPRA on your behalf. You must provide the authorized agent written
permission to exercise your rights under the CCPA/CPRA on your behalf and we may
deny a request from an agent on your behalf if we cannot verify that they have
been authorized by you to act on your behalf. Even if you use an authorized
agent to exercise your rights under the CCPA/CPRA on your behalf, pursuant to
the CCPA/CPRA we may still require that you verify your own identity directly to
us. This provision does not apply if you have provided a power of attorney under
the California Probate Code.

Opt-Out Signal:

An opt-out preference signal may be sent by certain platforms, technologies, or
mechanisms on your behalf to communicate your choice to opt out of the
sale/sharing of your personal information. Opt-out preference signals will opt
you out of the selling/sharing of personal information at the browser level.

Metrics:

The following section describes consumer rights submission metrics for requests
we received from January 1, 2022 through December 31, 2022 for Company business
units (not limited to California residents):

Disclosure Requests

Number of Requests Received

Number of Requests Denied

Number of Days to Resolve Requests (Mean)

Deletion Requests

Number of Requests Received

116

Number of Requests Denied

Number of Days to Resolve Requests (Mean)

Do Not Sell My Personal Information Requests

Number of Requests Received

3533

Number of Requests Denied

Number of Days to Resolve Requests (Mean)

Minors:

We do not knowingly share or sell the Personal Information of children under 16
years of age.

Notice of Financial Incentive:

We may provide price discounts, coupons, services, and other perks to our
customers and for members of our loyalty programs. Through these offerings, you
may provide us with Personal Information depending on how you choose to interact
with us when and after you opt-in to our programs. There is no obligation to
opt-in, and you may opt-out at any time. The details of the programs are
contained in the program offerings. We offer these programs, among other things,
to enhance our relationship with you so you can enjoy more of our
products/services at a lower price. While we invest in our marketing and brands,
consumer data is more valuable to our business when it is combined with a
sufficient amount of other consumer data and after it is enhanced by our efforts
described in this Privacy Notice. The value to our business of any individual
consumer’s data is dependent on several factors, including, for example, whether
and to what extent you take advantage or opt out of any offerings and whether we
are able to enhance the data through our efforts described in this Privacy
Notice. While we do not calculate the value of consumer data in our accounting
statements, we provide this good faith summary for California residents. To the
extent we create overall business value from our programs that could be directly
or reasonably related to the value of consumer data, the method for calculating
the value would include: a) costs related to maintaining the program including
but not limited to IT infrastructure, delivery of offers, and marketing
activities to enhance consumer data; b) whether the sales generated by the
program exceeds the cost to us of offering the program including value of
discounts to consumer; and c) value of the insights we are able to create based
upon aggregate data.

Data Retention:

We retain all categories of your personal information for as long as is
necessary, even if you are no longer an active customer, to provide the goods
and services and to fulfill the transactions you have requested of us, and to
support other necessary purposes such as:

* providing related business processes (such as returns or exchanges),
* resolving disputes and enforcing our agreements,
* fulfilling our legitimate interests (such as improving our products and
services),
* responding to any questions, complaints or claims made by you or on your
behalf,
* preventing fraud, and
* complying with our legal obligations.

In determining how long to retain information, we may consider various criteria
such as the amount, nature and sensitivity of the information, and the potential
risk of harm from unauthorized use or disclosure of the information.

The purposes and criteria for which we process the data may dictate different
retention periods for the same types of information. For example, we retain
your email address as an authentication credential (where applicable) as long as
you have an account with us and an additional period of time after that for our
legitimate interests and for our fraud and legal compliance purposes. We may
also retain cached or archived copies of your information.

De-identified Data:

Non-Discrimination:

We will not discriminate against you for exercising any of your CCPA/CPRA Rights
and we will not deny you goods or services, charge you a different price, or
provide you with a lesser quality of goods or services if you exercise any of
your CCPA/CPRA Rights.

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

If you are a data controller with a consumer rights request for us, please
contact us at ConsumerRightsRequest@Staples.com.

H. STATE-SPECIFIC DISCLOSURES ABOUT HANDLING CATEGORIES OF PERSONAL INFORMATION

For California, Colorado, Connecticut, Utah (as of 12/31/23), and Virginia,
residents, the following section describes:

1. Categories of Personal Information We Collect and Process
2. Examples of Specific Personal Information that may be Collected
3. Categories of Sources from which Personal Information is Collected
4. Purpose of Collecting/Processing the Personal Information
5. Categories of Other Parties to whom Personal Information may be Disclosed
6. Categories of Third Parties to whom Personal Information is Sold/Shared* and
the Purpose of Sale/Sharing*

*Share/Shared/Sharing as defined by California, Colorado, Connecticut, Utah (as
of 12/31/23), and Virginia law.

While this information is provided throughout this Privacy Policy, we provide
the supplemental information below pursuant to requirements under these laws.

Not all categories or examples of specific Personal Information may be collected
about you depending on how you interact with us.

Categories of Personal Information We Collect/Process

Examples of Specific Personal Information that may be Collected

Categories of Sources from which Personal Information is Collected

Purpose of Collecting/ Processing Personal Information

Categories of Other Parties to whom Personal Information may be Disclosed

Categories of Third Parties to whom Personal Information is Sold/Shared and the
Purpose of Sale/Sharing

Identifiers

Names, Account/Loyalty Program IDs, Emails, Addresses, Phone Numbers, IP
Addresses, Other Device Identifiers, Tax Exempt Numbers, Driver’s License

From You, Your Devices (when you visit our sites or use our apps), Service
Providers (e.g., data brokers, fraud prevention companies), Business Partners,
Social Networks

To identify you in support of business activities such as fulfilling a
transaction, communicating with you (order notification, etc.), personalizing
your experience, fraud prevention, administering programs

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, payment processing companies, fraud prevention
companies, delivery companies, CA recycling partners, and product manufacturers

Advertising Networks for the purpose of Marketing and improving their products
and services

Commercial Information

Products or Services Purchased, Price or Service Quotations, Credit Card or
other Financial Information, Chat Sessions, Feedback/Survey Responses,
Copy/Print Materials, Website Account Credentials, Communications Entrusted to
Us

From You (when you transact with us or participate in any of our programs)

To support a business transaction, communicating with you (surveys about your
purchase, customer service, order notification, etc.), improve our products and
services, to provide services you request of us

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, fraud prevention companies, payment processing
companies, delivery companies, and product manufacturers

Advertising Networks for the purpose of Marketing and improving their products
and services

(We do not sell credit card or other financial information.)

Biometrics

N/A

None

Characteristics of Protected Classifications

Demographic information such as age ranges, marital status, etc.

From You and Service Providers (e.g., data brokers, survey vendors, fraud
prevention companies)

To protect against fraud, enable you to apply for a company credit card,
demographically understand our customers to improve our products and services

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and marketing/sales analytics companies

None

Internet or Other Electronic Network Activity

Browsing activity, searches, and other interactions on our websites or mobile
apps (such as text entered, pages visited, links clicked, keystrokes/ cadence,
and mouse movements), your interactions with our ads

From You, Your Devices (when you access our websites or mobile apps) and fraud
prevention companies

To send marketing to you, improve our products and services, fraud prevention,
etc.

Advertising Networks and Service Providers/Business Partners/Business Clients
such as cloud service providers, fraud prevention companies, and eCommerce
analytics companies

Advertising Networks for the purpose of Marketing and improving their products
and services

Geolocation Data

Location based on IP address or mobile device location information

From You, Your Devices (when you access our websites or mobile apps), Service
Providers (e.g., data analytics providers, fraud prevention companies)

To personalize your experience, display store locations near you, fulfill your
orders, analyze web/app traffic, fraud prevention

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and eCommerce functionality vendors

None

Recordings/ Electronic Communications (e.g., audio, visual, chat, etc.)

Voice, Video, Chat, and CCTV Recordings

From You (calls with customer service or sales, or when you visit some of our
locations), Service Providers (e.g., chat service providers, call recording
software providers)

For quality assurance, training and analysis purposes, to improve our products
and services, fraud prevention

Service Providers/Business Partners such as cloud service providers and customer
service call recording companies

None

Professional or Employment-Related Information

Employer Name and Job Title

From You (e.g., when you inquire about our programs), Service Providers (e.g.,
data brokers), Business Partners

To send you marketing, personalize your experience, enroll you in certain
programs at your request

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and program administrators

None

Education Information

School Affiliations

From You (when you participate in certain programs such as Classroom Rewards)

To administer certain programs

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and program administrators

None

Inferences

Product and Service Preferences

From You (when you tell us what products and service are of interest), by
analyzing other data we have about you, Service Providers (e.g., advertising
networks, fraud prevention companies), Social Networks

To provide you personalized experiences and marketing, group you into segments
with other similar customers, improve our products and services

Advertising Networks and Service Providers/Business Partners such as cloud
service providers and marketing/ eCommerce analytics companies

None

Sensitive Personal Information*

Driver’s License Number, Passport Number, Contents of Mail, Precise

Geolocation

From you, postal mail that you requested we receive/process, your mobile device

To fulfill the services you requested of us

Returns Processing Vendor, Passport Processing Vendor, Mail Service Vendor,
Store Locator Service

None

The above categories are intended to encompass the Personal Information
described in subdivision (e) of Section 1798.80 of the California Civil Code.

*We do not collect, process, or share Sensitive Personal Information for the
purpose of inferring characteristics about you.

I. HOW TO EXERCISE YOUR STATE-SPECIFIC PRIVACY RIGHTS – FOR RESIDENTS OF
CALIFORNIA, COLORADO, CONNECTICUT, UTAH (AS OF 12/31/23), AND VIRGINIA:

Residents may submit a Right to Know/Access request by either:

1. Submitting an online request here: Data Disclosure Request
2. Submitting a phone request by calling 1-800-333-3330

Residents may submit a Data Correction or Data Deletion request by either:

1. Submitting an online request here: Data Correction/Deletion Request
2. Submitting a phone request by calling 1-800-333-3330

Residents may submit a request to Opt-Out of Targeted Advertising,
Selling/Sharing with Third Parties, or Profiling by either:

1. Submitting an online request here: Do Not Sell/Share My Personal Information
2. Clicking the “Do Not Sell/Share My Personal Information” button on our
website

We will take reasonable steps to verify your above request prior to fulfilling
it by requiring a response to a confirmation email sent to the email address on
the request. For purposes of verifying your identity, we will request that you
provide personal information we already have on file including your first and
last name, email address, and phone number. We may also request mailing address
and, if applicable, your account number, login ID for our websites, and
rewards/loyalty number to ensure that we have a verified match. We will respond
to your request and let you know if we need additional information.

J. INTERNATIONAL RESIDENTS

As residents of some international jurisdictions (such as the EU or UK), you
will have certain additional rights with respect to your Personal Information
under local laws (such as the General Data Protection Regulation) including:

1. The right to be informed.
2. The right of access.
3. The right to rectification.
4. The right to erasure.
5. The right to restrict processing.
6. The right to data portability.
7. The right to object.
8. The right to restrict automated decision making and profiling.

To exercise any of these rights, please see Section 8 below to contact us. We
will respond to your request within 30 days of receipt. We must verify your
identity in order to honor your request.

Lawful Bases of Processing:

The laws in some jurisdictions require companies to tell you about the legal
ground they rely on to use or disclose your “personal information” as such term
is defined under applicable law. To the extent that such laws apply and where
we are acting as a data controller that determines the purposes and means of
processing your personal information, such as when we collect, use, and disclose
personal information as described in the sections above, our lawful bases for
processing personal information include:

* To conclude or perform a contract with you, for example to:
* process your purchases of or requests for products and services, including
delivering gift cards in accordance with your instructions.
* communicate with you about orders, purchases, returns, services, accounts,
programs, contests, and sweepstakes.
* For our legitimate business purposes, including to:
* respond to your customer service inquiries and requests for information;
* maintain, improve, and analyze our websites, mobile applications, ads, and
the products and services we offer;
* detect, prevent, or investigate security breaches or fraud; and
* facilitate the functionality of our websites and mobile applications.
* To comply with our legal obligations, for example to maintain appropriate
records for internal administrative purposes and as required by applicable
law, and provide important product safety information and notice of product
recalls; and
* On the basis of your consent, for example to send you via email and other
electronic means personalized promotions and special offers or informing you
about our brands, products, events, or other promotional purposes.

Data Retention:

We will retain your personal information for as long as your account is active,
as needed to provide you services and to fulfill the purposes for which the data
was collected, and as necessary to comply with our legal obligations and fulfill
our business needs.

Complaints:

Some international jurisdictions give you the right to lodge a complaint if you
have any concerns or questions. For example, EEA residents have the right to
lodge a complaint with an EEA supervisory authority
(https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm)
and UK residents may lodge a complaint with the Information Commissioner’s
Office (https://ico.org.uk/make-a-complaint/). We would, however, appreciate the
opportunity to first address your concerns and would welcome you directing an
inquiry first to us per section 8 below.

K. TRANSMISSION OF INFORMATION TO/FROM OTHER COUNTRIES

If you are accessing our services from outside of the U.S., please be aware that
information collected through the services may be transferred to, processed,
stored, and used in the U.S. Data protection laws in the U.S. may be different
from those of your country of residence. We have taken commercially reasonable
steps to ensure that your personal information is appropriately protected and is
processed only in accordance with this Policy.

We may also use service providers in other countries. When you submit personal
information to us, your personal information may be processed in a country where
privacy laws are less stringent than the laws in your country.

8. HOW TO CONTACT US

This Privacy Notice applies to Staples, Inc., and its affiliated companies.

Please direct any questions, complaints or concerns regarding this Privacy
Notice and our treatment of your Personal Information to any of the following:

Primary contact by email: privacy@staples.com

Alternate contact by phone: 1-800-333-3330

or by writing to: Staples, Inc.

Privacy and Compliance

500 Staples Drive

Framingham, MA 01702

Upon receiving a written request, we will contact you directly, investigate your
request, and work to address your concerns. We reserve the right to take
reasonable steps to verify your identity prior to granting access or processing
changes or corrections.

9. PRIVACY NOTICE UPDATES

This Privacy Statement may change from time to time, and we will post on our
websites any updated Privacy Notice. Recent changes to the Privacy Notice are
documented below. Each version of this Privacy Notice will be identified by its
effective date displayed at the top of this Privacy Notice.

What has changed:

V5.0

July 1, 2023

* Updated for CPA, CTDPA, and UCPA
* Updated general information and format

V4.0

January 1, 2023

* Updated for CCPA/CPRA and CDPA
* Updated consumer rights metrics

V3.1

June 1, 2022

* Added 2021 CCPA metrics
* Updated general information

V3.0

July 1, 2021

* Added 2020 CCPA metrics
* Updated general information

V2.0

January 01, 2020

* Added California Consumer Privacy Act of 2018 (CCPA) rights. Expanded
Canadian Residents section with information provided previously in a separate
document.
* Changed the title of this document from Privacy Policy to a Privacy Notice,
reflecting trend to use the word “Notice” when referring to public
notifications while using the term “Policy” for internal communications.
* Updated the Nevada resident opt-out instructions

V1.1

October 1, 2019

* Addition of language addressing the Nevada Data Privacy Law

V1.0

May 25, 2018

* Reorganization and Standardization of Privacy Policy and Introduction of the
Privacy Resource Center

V0.1

March 23, 2017

* Removed references to the US-EU and US-Swiss Safe Harbor programs which have
or will be discontinued.

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