Buckle Teammate, Applicant, Consultant and Contractor Privacy Policy

This Buckle Teammate, Applicant, Consultant and Contractor Privacy Policy (“Policy”) describes Buckle's practices for collecting, using, disclosing, sharing and retaining information about our teammates, applicants, consultants and contractors. When you apply for a job or accept employment or a contract with Buckle, you agree to the terms of the practices regarding the collection, use and disclosure of your information described in this Policy.

This Policy does not apply to information collected through our retail store and websites, mobile application, social media, direct marketing campaigns and other online communications. For more information regarding those privacy practices, please click here.

What We Collect: Categories and Specific Items

Buckle collects the following types of personal information:

• Identifying Information: Your name, mailing address, email address, phone number, and unique personal identifiers associated with you.
• Protected Classifications under California or Federal Law: Your gender, gender identity, date of birth, disability, or other protected class.
• Video Recordings: For security and loss prevention purposes, stores have a video monitoring system in place at all times that may capture your image. Additionally, video conference calls which you attend may be recorded for training and educational purposes.
• Call and Chat Recordings: Audio recordings and notes about your call or chat and what you shared during your conversations with human resources or other departments.
• Social Media Information: If you use social media (e.g., LinkedIn) to connect with us, information you share via your posts or information you have approved via the social media platform or network to share.
• Personal and Financial Information: This includes financial payment or payroll information, such as your banking and direct deposit information, salary, tax information and forms, expense reimbursement records, paid time off balances, benefits information, such as your benefits elections, beneficiaries, spousal or partner information and dependent information, or other information we collect for human resources or other business purposes.
• Health and Insurance Information: Medical condition, physical disability, mental disability, personal information collected and analyzed concerning your health, including medical and insurance information, and insurance policy numbers.
• Biometric information: In some locations, scan of your finger, hand, face, retina, iris or voiceprint may be utilized for devices, systems or software to unlock or use a device, to securely enter or exit, to enter time, or for other business purposes, and then stored on a device or on a server.
• Professional or Employment Information: Your resume, cover letter and any information you may share regarding your qualifications; ethnicity information voluntarily provided in the hiring process; recruitment information, including your references, employment application, consumer reports and background checks; performance information, including performance reviews and metrics, such as sales, attendance records, and disciplinary actions; information related to visas and work authorizations; information you share about your educational qualifications and anticipated graduation date where applicable.
• Internet or electronic network activity information: This includes your use of technology on Buckle's networks and systems, including your corporate network log-in and passwords, network activity, online browsing activity, internet service provider or IP address, mail, email, company device and network text messages and messaging systems, software and application activity and other information about your personal or company-provided phone, tablet, computer or device with which you apply to Buckle or access Buckle teammate resources and platforms.
• Sensitive Personal Information: This includes your government issued identification numbers (such as your social security number, passport number, driver's license number, etc.), biometric information, and health conditions or self-identifiers you voluntarily provide.

How We Collect Your Information: Sources

We collect information about you when you are in one of our stores, on our website(s), through our emails, using our corporate-owned devices, speaking to our teammates during telephone and video conference calls, or utilizing social media. We also collect information about you from third parties.

• Information you provide to us: You may provide the various types of information when completing a job application, during recruiting events and interviews, during teammate onboarding, including information provided directly to Buckle or via third-party service providers (such as payroll and benefits services), as well as information gathered while performing your job duties and in conversations and dealings with human resources and business operations. As a contractor, your information is collected throughout the duration of your contract, including information obtained when operating on Buckle's network, if applicable.
• Information we collect automatically: When you visit or interact with Buckle's Career website, we or our service providers may use a variety of technologies that automatically or passively collect information about your activity and the device used to access the portal. These practices are further described in our privacy policy for consumers here.
• Information provided by third parties: We may collect information from other sources, such as your previous employers or references, to update or supplement the information you provide.
• Information we combine: We may combine any of this information we receive from and about you.
• Information collected by video: When you attend events or other activities offered to teammates, applicants, consultants and contractors, we may capture video and photography that may include your voice and image. These images and recordings and videos may be used in media, including commercial internet sites, in print or other places for any lawful purpose without notice or compensation to you.

How We Use Your Information: Business Purpose

The information we collect about you helps us support Buckle's human resources department and other business operations, including, but not limited to the following business purposes:

• Determination of Employment or Contract: We use the information to determine your qualifications for employment or a contract and to contact you about the same.
• Legal and Compliance Purposes: Your information may be used when implementing internal policies, responding to suspected fraud or other illegal activity. Your information may be disclosed in summary or aggregate form to government regulators as required by law and utilized by Buckle in its diversity and inclusion efforts.
• Employment Performance: Information may be used to perform applicable job functions and duties, management tasks, such as determining and evaluating performance, and for training purposes.
• Administrative and Operational Purposes: Your information may be used to distribute payroll and benefits, managing your personnel file, conducting audits and providing support and other troubleshooting IT related or otherwise.
• Security Purposes: Your information may be used to protect teammates, applicants, consultants, contractors, guests, the public, vendors, Buckle and its property.
• Emergency Purposes: Your information may be used in an emergency, such as contacting appropriate persons in an emergency situation.
• Buckle does not collect any of your sensitive personal information for the purpose of inferring characteristics about you.

How We Share Your Information

Buckle does not share your personal information for monetary consideration, but we do share your information with third parties who perform and provide services on our behalf. These third parties are prohibited from using the information we share with them for any purpose other than the services we have contracted with them to perform on our behalf. A non-exhaustive list of categories of third parties is set forth below:

• Service Providers: We have engaged certain service providers to perform human resources and/or business operations functions on our behalf, which includes our Buckle Careers website and our human resources management tools.
• External Third Parties: This may include legal, regulatory or other external third parties when legally required or obligated, or to protect the rights and property of Buckle, its teammates, guests, vendors and the public. For example, if we become aware or have a good faith belief that we must share information about you in connection with an investigation of fraud or other illegal activity, we will disclose the specific information about you to the appropriate legal authorities to protect Buckle and Buckle's guests, teammates, and vendors, and the public.
• Business-Related Purpose: We may share information for business-related purposes involving Buckle assets.
• At your direction: We will share information as directed by you.
• Other purposes: We may share information for purposes disclosed at the time you provide your information and for any other lawful purpose.

Retention of Your Personal Information

Buckle retains your personal information for the length of time needed to carry out the business purposes described in this Policy. We also retain information for related business purposes, security, legal compliance, and disputes and claims handling, consistent with our retention policies and as permitted by applicable law.

California Privacy Rights

If you are a resident of California, the California Consumer Privacy Act of 2018, as amended, (“CCPA”) gives you the following rights related to your personal information (as defined in the CCPA):

• Right to Know: The right to know what personal information Buckle has collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom Buckle discloses personal information, and the specific pieces of personal information Buckle has collected about you. (“Right to Know”);
• Right to Delete: The right to delete personal information Buckle has collected from you, subject to certain exceptions (“Right to Delete”);
• Right to Correct: The right to correct inaccurate personal information that Buckle maintains about you, subject to certain exceptions (“Right to Correct”);
• Right to Opt-Out: The right to opt-out of the sharing of your personal information by Buckle (“Right to Opt-Out”); and
• Right to Nonretaliation: The right to not receive discriminatory treatment by Buckle for the exercise of your privacy rights under CCPA.

These California resident rights are subject to certain exceptions as outlined in the CCPA, such as providing certain medical information, instances where a request would conflict with federal or state law or would be impossible or would involve disproportionate effort to respond. Buckle will comply fully with any requests to access, delete, or correct in accordance with all applicable exceptions or exemptions. In order to make a request to exercise your Right to Know, Right to Correct, Right to Delete or Right to Opt Out under CCPA, please contact us, or have an authorized agent contact us, through any of the following methods:

• Fill out an interactive web request form:
• Right to Know: Click here to submit your request for access to your data.
• Right to Correct: Click here to submit your request to correct your data.
• Right to Delete: Click here to submit your request for the deletion of your data.
• Right to Opt-Out: Click here to submit your request to opt out of the sale or sharing of your personal information.
• Call our Guest Services department to make your request at (800) 607-9788

For Requests to Know, Correct and Delete, you are required to verify your identity before we will process your request. This may include, but is not limited to, responding to an email we send you or providing additional information (if necessary) after you submit your request.

An authorized agent may make a request on your behalf by (i) providing evidence of your written permission to do so, including but not limited to a valid Power of Attorney, and (ii) verifying his/her own identity with us. Further instructions are included in the interactive webforms listed above or can be provided by Guest Services by calling (800) 607-9788.

Security & Fraud

Buckle has implemented several security measures on its various applicant and teammate platforms, but you should be aware that 100% security is not always possible. Buckle has made every effort to ensure that the information transmitted to us online is secure through the use of standardized encryption protocols, such as transport layer security (TLS).

In addition, Buckle does not require you to disclose more information than is reasonably necessary to apply for or hold an employment position with Buckle.

Notices

Third Party Privacy Policies

If services are provided directly by a third party using a link from our website to theirs, the third party's privacy policy and “do not track” practices apply; Buckle is not responsible for the privacy practices or the content of such third-party websites.

Children Under 13

This website, including its mobile applications and tools, if any, is not marketed to, and does not knowingly collect or maintain personal information from, children under the age of 13.

Minor Applicants' Privacy

We value our relationship with applicants of all ages. Therefore, we will not gather or use personal information from any applicants who indicate they are younger than the required age for the state of employment or position applied for. We may collect information regarding teammates' dependents for employment-related purposes, including benefit related matters.

Terms & Conditions, Third Party Websites, Do-Not-Track Signals, Revisions and Contact Info

• Your application and employment with Buckle is subject to our consent policy, Buckle's Teammate Handbook, and related employment policies, respectively.
• Buckle's websites may contain links to third party websites, applications or online services, and those third parties may have privacy policies of their own. Third parties' privacy links are provided solely for your convenience and information. Buckle is not responsible for the privacy practices or the content of those third parties.
• Buckle does not respond to “do not track” settings in your web browser.
• If we materially alter our Policy, we will notify you of such changes by posting a notice on Buckle's application webpage and the Buckle teammate center. Your submission of an application and/or your acceptance and continued employment with Buckle is deemed your agreement that your information may be used in accordance with this new Policy.
• For questions or concerns about this Policy, or for applicants or teammates that aren't residents of California who would like to make a request related to the exercise of a legal right under state law, please contact us:
• Email: privacy.officer@buckle.com
• Phone: (800) 607-9788
• Mail: The Buckle, Inc., Attention: Privacy Officer, PO Box 1480, Kearney, NE 68848

Please note that requests may require verification of identity and authenticity.

ARBITRATION AND CLASS ACTION WAIVER

PLEASE READ THIS SECTION CAREFULLY AS IT MAY AFFECT YOUR LEGAL RIGHTS. IT CONTAINS PROCEDURES FOR FINAL BINDING ARBITRATION WHICH REQUIRES YOU WAIVE THE RIGHT TO A TRIAL IN COURT WITH A JURY, AND WAIVER OF ANY AND ALL RIGHTS TO PROCEED IN A CLASS, COLLECTIVE, CONSOLIDATED OR REPRESENTATIVE ACTION (“Class Action”).

Except where prohibited by law, you agree (i) to waive the right to trial by jury and the ability to participate in a Class Action regarding this Policy; (ii) that any dispute with Buckle regarding this Policy will be resolved through negotiation with Buckle, and if agreement cannot be reached through negotiation, resolution will be sought on an individual basis only through binding arbitration in the State of Nebraska as conducted by the American Arbitration Association (“AAA”), JAMS, or any other company selected by mutual agreement of the parties, and (iii) that the laws of Nebraska will govern the substantive resolution of the matter.

Please be advised that all claims and disputes arising under this Policy must be arbitrated on an individual basis and not on a class basis. Claims of more than one teammate, applicant, consultant or contractor cannot be arbitrated (or litigated in the case where arbitration is prohibited by law) jointly or consolidated with those of any other individual.

Effective Date

This Buckle Teammate, Applicant, Consultant and Contractor Privacy Policy supersedes all prior policies and is effective February 6, 2023.