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Privacy Candidates

CANDIDATE PRIVACY STATEMENT

 

We amend this Candidate Privacy Statement from time to time to keep the information provided up to date. In the latest update to this Privacy Statement, we made the following key changes:

·       We made clear which Foot Locker entity is the controller for certain processing activities;

·       We clarified what data we process, for which purposes, and on which legal bases;

·       We added details of the safeguards we rely on for international data transfers; and

·       We added the new email address of our data protection officer (DPO).

 

When applying for a job position at Foot Locker or any of its affiliates or brands, including Kids Foot Locker, located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (the “UK”) (“Foot Locker”), we will be processing certain personal data of you. With this Candidate Privacy Statement (“Statement”) we inform you on how we process your personal data.

 

This Statement applies to all users and candidates who apply for a job in Europe, Switzerland or the United Kingdom who visit and/or apply for a job through our Career Site, or otherwise apply for a job position

 

This Statement has the following chapters:

 

1.          Who are we?

2.          What personal data do we collect from you?

3.          Why do we use your personal data and what is the applicable legal basis?

4.          How long do we retain your personal data?

5.          What automated decisions do we make about you?

6.          To whom do we disclose your personal data?

7.          Do we transfer your personal data outside of the EEA, Switzerland, and the UK?

8.          Third-party links

9.          What are your rights?

10.       Questions and concerns

 

1.     Who are we?

 

The terms “we”, “our” and “us are used to refer to Foot Locker entities in Europe. The data controller of your personal data depends on how you interact with us.

 

Foot Locker Europe B.V. (incorporated under Dutch law and is registered at the Dutch Chamber of Commerce under the registration number 23067735) is the data controller of all processing activities listed in this Statement, except for the in-store/office processing activities related to your job application (e.g., interviews with local HR team or manager).

 

The entity of the store/office where you applied for the job is the controller for the in-store/office processing activities related to such job application. Please see Annex I to this Statement, including our list of entities to find your relevant Foot Locker entity that may become your employer.

 

Foot Locker Corporate Services, Inc. (incorporated under the law of New York and registered at the U.S. chamber of commerce under the registration number 861249) and third-party service providers (as listed in Annex II) are joint data controllers for personal data processed by third party cookies (as explained in chapter 3 of the Cookie Statement).

 

2.     What personal data do we collect from you?

 

2.1  Personal data you may share with us directly:

 

a)     Identification and contact information data, such as full name, address, email, and phone number;

b)     Education information: level of education, schools attended, diplomas, certifications;

c)     Professional experience and skills: background check information, your resumé (possibly including photograph), your LinkedIn profile or profile on a similar social network, your employment history, previous employers and positions, responsibilities and duties, professional and language skills, other relevant skills, years of working experience, interested work areas and locations, references.

d)     Other information: confirmation of minimum age requirement, details or preferences about the contract (e.g., availability, full/part time, preferred location, current and preferred compensation, notice period);

e)     Exclusively for store positions, professional assessment: we request the completion of a questionnaire for screening the most suitable candidates for the positions available, e.g., your problem solving, leadership or teamwork abilities. After you have taken the questionnaire, an assessment will be made, and a fit score will be generated which will help us assess your suitability for the position you applied;

f)      Interview notes: during the interview, we may collect certain notes about you;

g)     Additional personal data collected upon an employment offer: once we reach a verbal agreement with you, we will request you to provide additional personal data, via completion of the additional personal data form, provided by our Career Site or via other means, which contains your social security number or ID number, a copy of your national ID or passport, work permit details if relevant, nationality, gender, birthdate and place, bank details, emergency contact details, marital status and tax information; and

h)     If you are already our employee and you are applying for another job position within Foot Locker: we may match your candidate profile with your employee profile, via your employee ID or your email address. We may also obtain your employment history (e.g., previous employers and positions, responsibilities, reasons for leaving), your relocation preference, and your professional skills for the applied position.

 

2.2  Special categories of personal data:

 

Foot Locker knows that by embracing diverse people, ideas, and perspective, we will grow our workplace culture, encouraging team members to feel unique valued and engaged, enabling them to reach or achieve their full potential. If you require support or accommodation to complete the job application process, we may collect special categories of personal data such as your disability to provide the required support to you.

 

With the exception above, Foot Locker does not collect any special categories of personal data during the application process unless this is required by law to fulfill a legal obligation: you may have to provide a specific certificate for us to assess the truthfulness of the document and the percentage of disability. This document is securely stored with limited access.

 

2.3  Personal data we collect from you indirectly:

 

Information collected through the use of cookies, web beacons, pixel tags, log files or other similar technologies when you use our Career Site such as: online behavior and interaction patterns, your online activity, browsing history and search history, preferences, and location. For more information on how we use cookies, please read our Cookie Statement.

 

3.     Why do we use your personal data and what is the applicable legal basis?

 

Please find below an overview of each of the purposes for which we process your personal data and the legal basis relied upon.

 

Purpose

Legal basis

Process your job application

To manage the recruitment process.

Consent.

To find the best candidate, and to increase diversity, inclusion, and belonging by reducing bias or prejudice.

Necessary for the purposes of our legitimate interest, namely to find the best person for a specific job in the context of the application procedure and make sure that bias or discrimination among candidates is excluded.

To contact you for possible job positions and send you job alert emails.

Consent.

To provide you personalized site and job recommendations based on your interests and profile.

Consent.

To organize and carry out interviews with you.

Consent.

To prepare and finalize your employment contract.

Necessary for the performance of our contract with you.

Candidate account

To create, maintain and manage your account and your job application.

Necessary for the purposes of our legitimate interest, namely to create, maintain and manage your candidate account and job application.

Cookies

To operate our business and analyze, develop, and improve our Services.

Consent.

Improvement of our services and enhancing user experience

To operate our business and analyze, develop, and improve our Career Site and services.

Necessary for the purposes of our legitimate interest, namely to operate our business in an efficient and appropriate manner and to enhance the effectiveness, user experience, functioning, and security of our systems, networks, and services.

Compliance

To comply with applicable laws and regulations.

Necessary to comply with an applicable legal obligation.

Other

Potential and/or actual litigation or investigations concerning Foot Locker.

Necessary for the purposes of our legitimate interest, namely, to establish, exercise, or defend us against legal claims.

 

4.     What automated decisions do we make about you?

 

We do not make any decisions on you during the job application procedure that involves automated decision making. All decisions involve human intervention from the relevant departments within Foot Locker, among which our Human Resource department.

 

5.     How long do we retain your personal data?

 

We do not process your personal data any longer than necessary for the purposes as described in this Statement. For information about the lifespan of cookies, please refer to the Cookie Settings.

 

In case you are hired by Foot Locker, all your personal data, gathered through the recruitment process, will be uploaded to our HR related system. We will maintain your candidate profile on the Career Site during your employment with us. We will inform you on how your personal data is processed through the Employee Privacy Statement. In case you have provided additional personal data following an employment offer (see above 2.1(g)), such data will be deleted from the Career Site within 15 days after completion of hire.

 

In case you are not hired, Foot Locker will retain your personal data for one year (six months in Germany) starting from the last update of your profile. During this one-year period, you can reapply for another position at Foot Locker using the same profile.

 

If necessary to meet legal or regulatory requirements, or where we are subject to a statutory retention period, we will retain your personal data for the period necessary to meet those requirements or the period specified by the law respectively.

 

Notwithstanding the above, we may retain your personal data for the length of any applicable limitation period for issues, claims or concerns you may have about the services you have received, and to allow us to establish, exercise, or defend legal proceedings.

 

For information that you have provided to third parties directly as part of the application process, please visit their websites or contact such third parties for more information on their data retention and privacy practices.

 

6.    To whom do we disclose your personal data?

 

To the extent applicable, we may disclose or share your personal data with the following parties:

 

Party

Purpose

Foot Locker Group

All Foot Locker entities that are part of our group organization, which is owned, directly or indirectly by Foot Locker, Inc., a company organized under the laws of the State of New York, USA.

To ensure general governance at group level, for internal and administrative management, for the fulfillment of our services, safety and security, project collaboration, support (including regarding IT), and related actions and requirements.

Third party vendors

Please see Annex II to this Privacy Statement, including our Third-Party Vendors List.

To obtain business, professional, and technical support and maintenance for our Sites and IT systems, storage, business-related processing. To obtain a professional assessment and a fit score of candidates to help us find the most suitable for the respective positions.

Supervisory authorities, investigative authorities, or other governmental bodies

To comply with a subpoena or other legal process or obligations, to protect our rights, protect your safety or the safety of others, investigate fraud, to respond to legitimate government requests, including from public and government authorities outside your country of residence, including for national security and/or law enforcement purposes.

 

Further, we may disclose or share your personal data if:

a)     We sell our company or part thereof (including separate assets), or if we merge with another company. In such event, we may share your personal data with the new owner or merging party respectively; or

b)     We are subject to insolvency proceedings, as part of the sale of our assets by a liquidator (or similar).

 

7.     Do we transfer your personal data outside of the European Economic Area (“EEA”)?

 

For certain processing activities, we store or otherwise transfer your personal data in and to locations outside the EEA, Switzerland, and the UK.

 

In case of transfers of personal data between the EEA, Switzerland, and the UK, we rely on the respective adequacy decisions issued by the European Commission and the competent authorities in Switzerland and the UK. The same applies to transfers from the EEA, Switzerland, and the UK to other adequate countries. For more information on adequacy decisions, please see here for the EEA, here for Switzerland and here for the UK.

 

In case of transfers of personal data to countries outside:

a)     the EEA for which the European Commission has not decided that an adequate level of personal data protection exists; 

b)     Switzerland for which the authorities in Switzerland have not decided that an adequate level of personal data protection exists; and

c)     the UK for which the authorities in the UK have not decided that an adequate level of personal data protection exists;

we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data by signing the Standard Contractual Clauses (Module 1 or 2 as appropriate) of the European Commission (article 46(2)(c) GDPR), for Switzerland as amended to include the Swiss law specifics. For more information on these Standard Contractual Clauses, please see here for the EEA and here for Switzerland.

 

For the UK, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data by signing the UK Addendum to the EU Standard Contractual Clauses (Module 1 or 2 as appropriate) or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on the UK Addendum and the UK International Data Transfer Agreement please see here.

 

In case of transfers of personal data from the EU and Switzerland to the United States (the US) within the Foot Locker group, we have certified compliance with the EU-US Data Privacy Framework (EU-US DPF) and the Swiss Extension to the EU-US DPF as set forth by the US Department of Commerce (DoC). We have certified to the DoC that we adhere to the EU-US DPF Principles (EU-US DPF Principles).

 

The Federal Trade Commission has jurisdiction over Foot Locker Inc.’s compliance with the EU-US DPF. In compliance with the EU-US DPF Principles, Foot Locker Inc. commits to resolve complaints about our collection or use of your personal data.

In the context of onward transfers, Foot Locker has responsibility for the processing of personal information it receives under the Data Privacy Framework and subsequently transfers to a third party acting as an agent on its behalf. Foot Locker shall remain liable under these principles if its agent processes such personal information in a manner inconsistent with the principles, unless Foot Locker proves that it is not responsible for the event giving rise to the damage.

 

We have further committed to refer unresolved non-human resources data related DPF complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive a timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit their website at https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS are provided at no cost to you.

 

If there is any conflict between the terms in this Privacy Statement and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern.

 

To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/. If you have an inquiries or complaints regarding our DPF policy, please contact us at: privacy@footlocker.com.

 

8.     Third-party links

 

Our Career Site contains links to third-party websites and applications. We are not responsible for the privacy practices or content of such third-party websites or applications that are not affiliated with or maintained by Foot Locker. We recommend that you review the privacy statement posted on the third-party websites and applications that you access through our Services.

 

9.     What are your rights?

 

Below we set out your rights in more detail and give information on how you can exercise these. To exercise any of these rights, please use the following webpage www.footlocker-emea.com/en/privacy. We will respond to your exercise of right request within one month but have the right to extend this period to two months. If we extend the response period, we will let you know within one month from your request.

 

a)     Access: you are entitled to ask us if we are processing your personal data and, if we are, you can request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If your request is clearly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to comply in such circumstances.

b)     Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.

c)     Erasure: you are entitled to ask us to delete or remove personal data in certain circumstances. There are certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with legal claims.

d)     Restriction: you are entitled to ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy or the reason for processing it.

e)     Data portability: you may request the transfer of a copy of certain of your personal data to you or another party (if technically feasible). You have the right to ask that we provide your personal data in an easily readable format to another company.

f)      Objection: where we are processing your personal data based on our legitimate interest (or those of a third party), you may object to processing on this ground. However, we may be entitled to continue processing your personal data based on our legitimate interests.

g)     Right to withdraw consent at any time: where you may have provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Please note that the withdrawal of your consent does not affect the lawfulness of the processing based on your consent before its withdrawal.

h)     Lodge a complaint with a supervisory authority: If you have any complaint about the way we process your personal data, you may lodge a complaint with a supervisory authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of supervisory authorities per EU member state here.

 

We are required to verify your identity including, but not limited to, the verification of your email address. If you do not allow us to verify your identity where needed, we cannot proceed to process your request.

 

Please note that the above-mentioned rights, with the exception of the right to object to direct marketing, are not absolute. Under certain conditions and in line with applicable data protection legislation, we may refuse a request. If such a restriction (partially) applies to your request, we will inform you on the reason of our refusal to comply to your request.

 

10.   Questions and concerns

 

If you have any questions, concerns, or complaints with the way we have handled your personal data, or if you would like to receive more information on the processing of your personal data by Foot Locker, please contact us at: privacy@footlocker.com.

 

Foot Locker has a data protection officer (DPO) in place to monitor the correct and compliant processing of personal data. If your questions or concerns about the processing of personal data have not been adequately addressed via the above email address, you can contact the DPO at dpo@footlocker.com

 

Last Updated: April 2025

 

ANNEX I

 

COUNTRY

ENTITY

REGISTERED ADDRESS

COMM. REGISTER NO.

VAT NUMBERS

AUSTRIA

Foot Locker Austria GmbH

Schottenfeldgasse 85/11

1070 VIENNA

AUSTRIA

FN 165131 s

ATU43738602

BELGIUM

Foot Locker Belgium B.V.

Boulevard Louis Schmidt 87

1040 Etterbeek, BRUSSEL BELGIUM

RRP/RPM 0442.407.102

BE0442.407.102

CZECH REPUBLIC

Foot Locker Czech Republic s.r.o.

Pobřežní 394/12

186 00 PRAGUE 8

CZECH REPUBLIC

271 26 706

CZ27126706

DENMARK

Foot Locker Denmark 2009 B.V., filial af Foot Locker Denmark B.V. Holland

Nybrogade 12

1203 Copenhagen K

DENMARK

33268300

DK33268300

FRANCE

Foot Locker France SAS

124, rue de Verdun, 2ème étage 92800 PUTEAUX

FRANCE

382 401 867

FR96382401867

GERMANY

Foot Locker Germany GmbH & Co. KG

Tiroler Straße 13C

45659 RECKLINGHAUSEN

GERMANY

HRA 4942

DE814084510

HUNGARY

Foot Locker Hungary Kft

Váci utca 14

1052 BUDAPEST

HUNGARY

01-09-718211

HU13089719

IRELAND

Foot Locker Retail Ireland Ltd.

49 Lower O'Connell Street

D01 CK02 DUBLIN

IRELAND

391370

IE6411370E

ITALY

Foot Locker Italy Srl

Via Ceresio 7

20154 MILANO

ITALY

10322270157

IT10322270157

LUXEMBOURG

Foot Locker Belgium B.V. Succursale de Luxembourg

18, Rue de L'Alzette

4010 ESCH-SUR-ALZETTE

GD-LUXEMBOURG

B 39434

LU27976639

NORWAY

Foot Locker Norway B.V. Norwegian branch

Haakon VII's gate 10

0161 OSLO

NORWAY

918 076 581

 

POLAND

Foot Locker Poland Spólka z ograniczoną odpowiedzialnością

ul. Bielańska 12

00-085 WARSAW

POLAND

0000392259

PL5252513747

PORTUGAL

Foot Locker - Artigos Desportivos e de Tempos Livres, Lda

Avenida 5 de Outubro, n.º 124, 7.º 1050-061 LISBOA

PORTUGAL

12861

PT506319431

ROMANIA

Foot Locker Romania SRL

Strada Dionisie Lupu nr. 33, Mansardă, Biroul nr. 5

020021 BUCHAREST, Sectorul 2

ROMANIA

J40/17888/2017

RO38389127

SPAIN

Foot Locker Spain SLU

Balmes, 195, 8°, 1a

08006 BARCELONA

SPAIN

B-101890

ESB80030315

SWEDEN

Foot Locker Scandinavia B.V., The Netherlands, filial Sweden

Strandvägen 7A

11456 STOCKHOLM

SWEDEN

516404-1492

SE516404149201

SWITZERLAND

Foot Locker Switzerland LLC

Aeschenvorstadt 4

4051 BASEL

SWITZERLAND

CH-660-0761005-2 (federal no.)

CHE-112.305.091 MWST

THE NETHERLANDS

Foot Locker Netherlands B.V.

Stationsplein 32

3511 ED UTRECHT

THE NETHERLANDS

23063181

NL800536253B01

THE NETHERLANDS

Foot Locker Europe.com B.V.

Stationsplein 32

3511 ED UTRECHT

THE NETHERLANDS

30181126

NL810639233B01

THE NETHERLANDS

Foot Locker Europe B.V.

Stationsplein 32

3511 ED UTRECHT

THE NETHERLANDS

23067735

NL800774115B01

UNITED KINGDOM

Freedom Sportsline Ltd.

4 More London Riverside

SE1 2AU LONDON

UNITED KINGDOM

1779106

GB545256538

 

ANNEX II

 

SYSTEM/
APPLICATION

THIRD PARTY VENDOR/ APPLICATION OWNER

HOSTING AREA

ADEQUATE LEVEL OF PROTECTION

PROCESSOR/ CONTROLLER

iCIMS

(application portal and career site)

iCIMS, Inc.

Bell Works, 101 Crawfords, Corner Road, Suite 3-100, Holmdel, NJ 07733, United States

United States

Standard Contractual Clauses

Processor

OneTrust

(cookies and DSR)

OT Technology Spain, SL

Paseo de la Castellana, 77

Madrid, 28046, Spain

Europe

European Union

Processor

Infor

(professional assessment)

Infor, Inc.

641 Avenue of the Americas, New York, NY 10011, United States

United States

Standard Contractual Clauses

Processor and Controller

Job portal

(recruitment support system)

Grupa Pracuj sp. z o.o.

Prosta 68, 00-838, Warszawa, Poland

Europe

European Union

Processor

Microsoft Booking and Teams

(schedule and carry out interviews)

Microsoft Corporation

One Microsoft Way, Redmond WA, 98052, United States

United States

Standard Contractual Clauses

Processor

Meta (Facebook)

Facebook Netherlands B.V.

Parkhuis Amsterdam

2n floor Jollemanhof 15

Amsterdam 1019 GW, Netherlands 

Europe

European Union

Controller

LinkedIn

LinkedIn Corporation

1000 W. Maude Avenue
Sunnyvale, CA 94085, United States

United States

Adequacy Decision

Controller