Employment Candidate Privacy Policy

Published: November 29, 2023

Last updated: December 4, 2023

Introduction

Arden Holdings Inc. (“Ardene”, “we”, “us” or “our”) is an apparel, footwear, and accessories retailer operating in Canada. Because we value and respect your privacy, we have prepared this Privacy Policy to explain the way we collect, use, and disclose (“process”) personal information of our employment candidates.

Table of Contents

1. Why do we collect your personal information?
2. What kind of personal information do we collect?
3. How do we collect your personal information?
4. With whom do we share your personal information?
5. How do we protect your personal information?
6. How long do we keep your personal information?
7. What are your rights regarding your personal information?
8. How can you contact us regarding your personal information?

1.     Why do we collect your personal information?

We only collect and use your personal information where applicable law permits or requires it in connection with carrying out our application and recruitment process. We may use your personal information for the following legitimate business purposes:

• Identifying and evaluating job applicants, including assessing skills, qualifications, and interests;
• Verifying your information and carrying out employment, background, and reference checks (where applicable and subject to your consent if required by applicable law);
• Communicating with you about the recruitment process and your application;
• Keeping records related to our hiring processes;
• Creating and submitting reports as required by applicable laws or regulations;
• To comply with our legal, regulatory, or corporate governance requirements;
• Analyzing and improving our application and recruitment process; and
• To share Ardene related information (email campaign).

In addition to using your personal information for the position for which you have applied, we may retain and use your personal information to inform you about and/or consider you for other positions for which you may be qualified. If you do not want to be considered for other positions or would like us to delete your personal information, you may contact us as described below under Section 8.

We will only use your personal information for the purposes it was collected. If we need to use your personal information for an unrelated purpose, we will notify you and, if required by law, seek your consent.

You may withdraw your consent to the processing of your personal information for any of the above purposes by contacting our Data Privacy Officer whose contact information is listed in Section 8. Please note, however, that withdrawing your consent to the processing of your personal information may impede our ability to process your employment application.

2.    What kind of personal information do we collect?

In this Privacy Policy, personal information means any information about an identifiable individual collected in connection with, and necessary for, the recruitment process. We may collect personal information directly from you, as a job applicant, or may receive personal information from third parties, for example, in connection with a background, employment, or reference check, subject to your consent if required by law. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. We may process the following categories of personal information in connection with our recruiting activities:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses;
• Work history and other relevant experience including information contained in a resume, CV, cover letter, and/or job application;
• Education information including degrees awarded, transcripts, and other information provided in support of the job application;
• Compensation expectations, where permitted by applicable law;
• Information collected during phone, online, and/or in-person screenings and interviews.
• Details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits;
• Reference information and information received from background checks, where applicable, including information provided by third parties (including recruitment agencies); and
• Information related to previous applications to us or previous employment history with us.

3.    How do we collect your personal information?

We limit our collection of personal information to what you have shared through Gr8 People, our applicant tracking system, via emails, phone or in-person interviews.

4.    With whom do we share your personal information?

We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law. We will conduct  assessments to identify and mitigate against any risk to the protection of your personal information prior to sharing or transferring it.

Service providers

Your personal information may be processed by certain third-party service providers who assist us with administering your recruitment relationship with us, including third-party service providers who provide services to us or on our behalf. Third-party service providers include, but are not limited to, payroll processors and benefits administration providers. These third-party service providers may be located outside of Canada.  Our service providers are only provided with the information they need to perform their designated functions. They are not authorized to process your personal information for any purposes other than those stipulated for the performance of the services for which they are engaged with us.

We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:

• To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary to meet the specific legal obligation;
• During emergency situations or where necessary to protect public safety;
• Where the personal information is publicly available;
• If a change in ownership occurs; and
• For additional purposes (with your consent, and where such consent is required by law).

We require all our third-party service providers, by written contract, to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to us as an employer.

Transferring your personal information outside of Canada

As necessary for the purposes set out in this Privacy Policy (and where required by law), we may transfer the personal information we collect about you to the United States and other jurisdictions.

The measures that we use to protect personal information are subject to the legal requirements of the jurisdictions to which we transfer personal information, including lawful requirements to disclose information to law enforcement and government agencies in those countries. If you wish to access written information about our policies and practices regarding service providers outside of Canada, or if you have any questions about the collection, use, disclosure, or storage of personal information by service providers outside of Canada, please contact our Data Privacy Officer.  Their contact information is listed below under Section 8.

Transferring your personal information outside of Quebec (applicable to Quebec candidates only)

Your personal information may be transferred to service providers outside of Quebec. As mentioned above, we will conduct assessments to identify and mitigate against any risk to the protection of your personal information prior to its transfer outside of the province.

5.    How do we protect your personal information?

We have implemented reasonable physical, technical, and organizational measures to protect the personal information in our custody and control, and to prevent its theft, loss and unauthorized access, use, modification, and disclosure. We restrict access to personal information on a need-to-know basis to employees (who have a legitimate business need for such access) and authorized third-party service providers.

6.    How long do we keep your personal information?

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information as long as necessary to accomplish the purposes for which it was originally collected. Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

If you are offered and accept employment with us, the personal information we collect during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our employee personal information policies. If you do not become an employee, or, once you are no longer an employee of Ardene, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

7.    What are your rights regarding your personal information?

Subject to applicable law or regulation, you have many rights regarding your personal information, namely:

• The right to access your personal information and obtain a copy;
• The right to correct inaccurate personal information;
• The right to withdraw your consent to the processing of your personal information under certain circumstances; and
• The right to request the deletion of your personal information that is obsolete or not justified by the purposes of collection.

You may exercise these rights regarding the personal information in our custody and control by contacting our Data Privacy Officer. Their contact information is listed below under Section 8.

Please note we may request personal information for the purpose of verifying the identity of the individual seeking to exercise their rights.

8.    How can you contact us regarding your personal information?

Our Data Privacy Officer is responsible for and oversees the data privacy practices of Ardene.

If you have any questions or comments about this Privacy Policy, how we or our third-party service providers process your personal information, or how to exercise any of your rights regarding your personal information, please contact our Data Privacy Officer at:

Email:

privacy@ardene.com

Mailing address:

Arden Holdings Inc. (dba Ardene)

C/O Data Privacy Officer

2575 Boul. Pitfield

Montreal, Quebec, H4S 1W8

Canada

Updates to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes to our privacy practices. We encourage you to periodically review this Privacy Policy to ensure you are familiar with those changes. We will indicate at the top of this Privacy Policy when it was most recently updated.