F500 Retail & Grocery · Specialty Retailers: Apparel · Structural / no discrete incident
Gap
Headline
Gap, Old Navy, Banana Republic and Athleta share one company and one loyalty infrastructure, so a customer shopping across four apparently different brands at four price points is building a single profile that also…
Not independently verified. Verification status: Unverified - heuristic first draft. Publish state: draft unverified.
Gap, Old Navy, Banana Republic and Athleta share one company and one loyalty infrastructure, so a customer shopping across four apparently different brands at four price points is building a single profile that also reveals household composition and income band. Gap's private-label and co-branded credit cards for Old Navy, Gap, Banana Republic and Athleta are issued and serviced by Barclays Bank Delaware (Gap ended its Synchrony program in April 2022), so disputes on a store card go to Barclays rather than the retailer.
- Severity
- Evidence tierUnassigned
- Claims confirmed
- Last verified2026-08-04
Primary source. None recorded — Unverified - heuristic first draft.
Terms
Arbitration
Not independently confirmed this pass — standard binding arbitration + class action waiver expected.
Data sharing
Not independently confirmed this pass with a specific named data-privacy lawsuit or breach; recommend checking against the general retail-industry vendor-breach patterns (Snowflake, MOVEit, Salesforce/ShinyHunters) documented extensively for peer retailers throughout this tracker.
Fees and billing
Not itemized this pass.
Contacts
Privacy contact. Not recorded.
Legal notice. PUBLIC COMPANY (GAP). Service route: c/o General Counsel / Corporate Secretary, San Francisco, California — the corporate address on the SEC Form 10-K cover page is the official address of record. Confirm the exact street address on the current 10-K at sec.gov/edgar, and check the state-of-incorporation registered agent (usually Delaware; most large filers use The Corporation Trust Company or Corporation Service Company) via the Secretary of State business-entity search. A registered agent MUST accept service, which is why it is the reliable channel when a company publishes no privacy address.
Mailing address. Not recorded.
Evidence
No claims have been itemized for this row yet.
No sources are on file for this row yet.
Source vault
Link status: Candidate - not yet fetched
| Document | Last fetch | |
|---|---|---|
| Privacy policy See Gap's own published privacy policy | Not fetched yet | NOT CONFIRMED |
| Terms of service See Gap's own published terms of service | Not fetched yet | NOT CONFIRMED |
| Website gapinc.com | Not fetched yet | — |
| Primary source No URL recorded Verification: Unverified - heuristic first draft | Not fetched yet | — |
Enforcement
No enforcement actions are linked to this row.
State statute
Headquarters on file: California. Provisions of CCPA/CPRA on file:
| Provision | Type | Source |
|---|---|---|
| Right to Deletion Cal. Civ. Code § 1798.105 | hard | source |
| Right to Correction Cal. Civ. Code § 1798.106 | hard | source |
| Right to Know / Access Cal. Civ. Code § 1798.110 | hard | source |
| Right to Limit Use of Sensitive Personal Information Cal. Civ. Code § 1798.121; Cal. Code Regs. tit. 11, § 7027 | hard | source |
| Right to Data Portability Cal. Civ. Code § 1798.130(a)(3)(B)(iii) | hard | source |
| Privacy Policy / Privacy Notice Requirements Cal. Civ. Code § 1798.130(a)(5); Cal. Code Regs. tit. 11, § 7011 | hard | source |
| Sensitive Personal Information — Categories Cal. Civ. Code § 1798.140(ae) | hard | source |
| Service Provider and Contractor Contract Requirements Cal. Civ. Code § 1798.140(ag); Cal. Code Regs. tit. 11, § 7051 | hard | source |
| Applicability Threshold (2025 CPI-Adjusted) Cal. Civ. Code § 1798.140(d) | threshold | source |
| Privacy Risk Assessment — Mandatory for High-Risk Processing (Eff. Jan. 1, 2026) Cal. Civ. Code § 1798.185(a)(15); Cal. Code Regs. tit. 11, §§ 7150-7157 | hard | source |
| Right to Opt Out of Sale or Sharing Cal. Civ. Code §§ 1798.120, 1798.135 | hard | source |
| Sale vs. Sharing Distinction Cal. Civ. Code §§ 1798.140(ad), 1798.140(ah) | hard | source |
| Enforcement — CPPA and AG; Civil Penalties (2025 CPI-Adjusted) Cal. Civ. Code §§ 1798.155, 1798.199.90; Cal. Bus. & Prof. Code § 17206 | hard | source |
| Notice at Collection Cal. Code Regs. tit. 11, § 7012 | hard | source |
| Cybersecurity Audit — Annual Independent Audit Requirement (Eff. Jan. 1, 2026) Cal. Code Regs. tit. 11, §§ 7120-7124 | hard | source |
| Automated Decision-Making Technology (ADMT) — Notice, Opt-Out, and Access Rights Cal. Code Regs. tit. 11, §§ 7200-7222; Cal. Civ. Code § 1798.185(a)(16) | hard | source |