<p>
</p>Privacy Policy
<p>Last Updated: April 1, 2020<br>
</p>
<p>Albertsons Companies, Inc.
including its subsidiaries and affiliated entities (“Company,” “we,” “us’,” or “our”), respects your privacy and is committed to protecting it.
This Privacy Policy describes what personal information is collected through our websites, online services, and stores, how that information is used, to whom it’s disclosed, how it is safeguarded, and the choices you have regarding the collection and use of such information.
Unless indicated otherwise, this Privacy Policy applies to personal information collected through our websites, microsites, mobile applications, stores, products, services, programs (including loyalty or rewards programs), or otherwise through any interaction you have with us (collectively “Services”).
Additional practices or terms may apply to special offers, promotions, contests or specific services, such as those provided by our pharmacies.
You should also refer to any separate notices we provide regarding those terms or practices.</p>
Consent To Privacy Policy
<p>By accessing our website to obtain information or Services.
by providing solicited or unsolicited personal information to us online, at any of our retail or office locations, or through one of our mobile applications.
by enrolling in one of our customer loyalty or other programs, or through otherwise using or accessing our Services you are consenting to our use of such information, subject to applicable laws, and agreeing to the terms of this Privacy Policy.</p>
<p>This Policy addresses these topics:</p>
<ol>
<li>What Is “Personal Information”?</li>
<li>What Information Do We Collect?<ol>
<li>Personal Information You Provide</li>
<li>Automatically Collected Information</li>
<li>Other Information</li>
<li>Health Information</li>
<li>Information Pertaining to Children</li>
</ol>
</li>
<li>How Do We Use Personal Information?<ol>
<li>Primary Business Purposes</li>
<li>Advertisements</li>
<li>Text Messaging Services</li>
<li>Loyalty Programs</li>
</ol>
</li>
<li>What Choices Do You Have Over How Your Personal Information Is Used?</li>
<li>What Information Do We Share And For What Purpose?</li>
<li>How Do We Protect Personal Information?</li>
<li>Where Is Personal Information Stored And Processed?</li>
<li>Will There Be Changes To This Policy?</li>
<li>How To Contact Us<ul>
<li>• California Consumer Requests</li>
<li>• Nevada Consumer Requests</li>
</ul>
</li>
Supplemental Privacy Statement For California Consumers</ol> 1.
What Is Personal Information?
<p>By “personal information” we mean any information that can be directly associated with, or used to identify, a specific person.
This may include information such as an address, phone number, email address, or fax number.
a user name or other online registration information.
and a financial account or credit card number, as well as other information (e.g., employment-related or transactional information, purchase history, tastes and/or preferences) when coupled with a person’s identifying information.</p>
2.
What Personal Information Do We Collect?
2.1.
Personal Information You Provide
<p>We may request or give you the opportunity to provide personal information when you shop in our stores or online, register as a user of our website or one of our mobile applications, sign up for our programs, offers, or sweepstakes, take a survey, use our products or Services, cash a check, contact us about a prior purchase, apply for or inquire about employment with us, or email, call, or otherwise communicate with us.
The types of personal information you provide differs based on how you choose to interact with us, but may include your name, address, phone number, email address, date of birth, identification information (which, in some situations, may include your social security number), personal preferences, payment card information, purchase and ordering information, demographic information, citizenship and work history information, and any other information you choose to provide.</p>
2.2.
Automatically Collected Information
<ul>
<li>
<p>
<b>Location Information.</b> We and/or our service providers may collect your location information when you access our Services.
For information on how to opt out of this collection see “Opt-Out Choices” below.</p>
</li>
<li>
<p>
<b>Navigational Information.</b> When you access our Services, your computer, phone, or other device provides navigational information, such as browser type and version, service-provider identification, IP address, the site or online service from which you came, and the site or online service(s) to which you navigate.</p>
</li>
<li>
<p>
<b>Transactional Information.</b> When you shop in our stores or online or register for or use any of our online, mobile, or other Services, transactional and other information such as the date of your purchase, the items purchased, the dollar amount or value of the transaction.
registration for or service usage.
their descriptions and, if applicable, your IP address, browser type, domain names, access times, operating systems, mouse clicks and movements, and scrolling activities may be collected automatically or “passively” by us or by one or more of our service providers.
For example, we may use analytics tools that collect information about the use of our websites and user traffic.</p>
</li>
<li>
<p>
<b>Device Information.</b> We may also use beaconing technology to collect mobile device information such as the device type, model and operating system version.
identification numbers assigned to your mobile device (e.g., the ID for Advertising on Apple devices and the Advertising ID on Android devices).
mobile network information.
and website or app usage behavior.</p>
</li>
<li>
<p>
<b>Audio and Video Information.</b> We and/or our service providers may collect audio or video records which are used for quality control, training, security, and analytic purposes when you call us or visit one of our stores.
For instance, we may use video monitoring technology at our stores for fraud and theft prevention, analytics, and security.
We may or may not be able to associate such information with you.</p>
</li>
<li>
<p>
<b>Cookies, Web Beacons, and Similar Technologies.</b> We and/or our service providers may collect and store information using cookies, local shared objects (or Flash cookies), web beacons, Uniform Resource Locators (URL), and similar technologies to manage our websites and email messages and to collect and track information about you and your activities online at our websites over time and across third-party websites or online services including, but not limited to, your computer’s IP address and operating system, your browser type, the site from which you linked to our site, the time and date of your visit, how you use and interact with our Services, your preferences, and what products and services you purchase.
We may also use device identifiers, web storage, and other technologies to collect information about your interactions with our content and Services.
We deliver a customized experience and do not currently respond to “Do Not Track” signals of web browsers.</p>
</li>
</ul>
<p>These technologies help us to recognize you, customize or personalize your shopping experience, associate your online navigational information or purchases and interactions (both online and offline) with any personal information you provide (such as name, address, phone number, survey response, and email address), and analyze the use of our Services and solutions to make them more useful to you.
These technologies also allow us to aggregate demographic and statistical data and compilations of information, which may or may not include personal information, and provide this information to our service providers.</p>
2.3.
Other Information
<p>We may obtain information about you from other parties such as demographic marketing information, address verification, or mailing list information and may combine it with other personal information pertaining to you.</p>
2.4.
Health Information
<p>We collect protected health information in our capacity as a pharmacy health care provider which includes your prescription and personal information, prescription history and profile information for fulfillment of pharmacy orders, and other health-related information that you, your doctor, or your insurance carrier provides to us.
This information is most often used to process your prescriptions, provide you with health care information or services, or to contact you with questions and respond to your inquiries pertaining to our pharmacy Services.
The information collected or maintained by our pharmacies is subject to our Notice of Privacy Practices that more specifically describes how we may use or disclose your protected health information.
You may click here to access our Notice of Privacy Practices.
A copy may also be obtained from any of our pharmacies or by contacting us (see the “How to Contact Us” section below).</p>
2.5.
Information Pertaining To Children
<p>Our Services are not directed to and we do not intend to, or knowingly, collect or solicit personal information online from children under the age of 13.</p> 3.
How Do We Use Personal Information?
3.1.
Primary Business Purposes
<p>We or our service providers on our behalf may use your personal information for a variety of business purposes including:</p>
<ul>
<li>Providing customer service, including responding to your requests or inquiries.</li>
<li>Processing and completing your transactions including, as applicable, order confirmation, billing, enrollment in our loyalty or other programs, and delivering products or Services.</li>
<li>Personalizing your experience with our Services with content and offers that are tailored to you, including special offers from other companies.</li>
<li>Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information.</li>
<li>Including you in market research, surveys, promotions, sweepstakes, and contests.</li>
<li>Improving our Services such as the way offers are made for our Services based on the purchasing decisions of our customers and improving the interactions visitors have with our Services.</li>
<li>Evaluating your shopping experience or existing products and Services or to create new items.</li>
<li>Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement.</li>
<li>Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online.</li>
<li>Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems, or to meet legal obligations.</li>
<li>Processing and evaluating your application and related materials you submit as a job applicant.</li>
<li>Interacting with you when you contact us as a vendor or on behalf of another business.</li>
<li>Enabling you to interact with content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment.</li>
<li>Creating aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.</li>
<li>Enforcing our Terms of Use and other agreements.</li>
</ul>
3.2.
Advertisements
<p>We may contract with advertising company service providers to collect information about online use and interactions with the Services, over time and across other websites and Services, for use in delivering tailored online display and banner advertising to your device(s) on other websites and online services.
To serve this advertising, these companies place, use, or rely on the technologies described above, including cookies, clear gifs, device identifiers, and similar technologies to obtain information about interactions with us through our Services and interactions with other online services.
These companies use the information they collect to serve ads to your device(s) that are targeted to your interests.</p>
<p>We may also work with third-party platforms, directly or through our service providers, to serve ads to you as part of a customized campaign on these platforms.
As part of these ad campaigns, information about you, such as your email address and phone number, is converted into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and to serve you advertising that is customized to your interests.
Note that the third-party platforms may offer you choices about whether you see these types of customized ads.</p>
<p>Additionally, we and/or a service provider may use automatically collected information to allow other parties to serve ads to you on our websites or mobile applications or to serve our ads to you on another party’s website.
If you “click through” to or otherwise visit third-party websites or mobile applications, they may also collect information about you and your visit.
This Privacy Policy does not apply to, and we are not responsible for, the practices of other third parties that collect your personal information.
We encourage you to check the privacy policies of other third parties whose information you find on our website to learn about their practices with respect to the collection, use, disclosure, and protection of your personal information.</p>
<p>For information about opt-out programs that these advertising companies participate in and to opt out of the use of website browsing data for interest-based advertising by companies that participate in these programs, click the following: NAI Opt Out or DAA Opt Out.
To opt out of the use of data collected from the mobile applications on your device to serve ads that are targeted to your interests, consult the settings on your device.
You can also click the preference icon that may appear on some of our advertising served through use of these technologies.</p>
<p>We may also use analytics providers, such as Google Analytics, to measure traffic and usage trends and to help us better understand your use of, and interaction with, our Services.
For more information on how Google uses data when you use our Sites, click here.</p>
3.3.
Text Messaging Services
<p>When you sign up for one of our text messaging programs, you are expressly consenting to receive text messages on your cell phone or other mobile device about our products, Services, and/or programs which may be sent by automated means.
Text messages will only be sent to the mobile phone number used to opt into the applicable text message program.
Some programs may send you up to the specified number of messages per month, dependent on the program, and each program in which you enroll will increase the total number of messages you receive each month.
Details on how many messages you should expect to receive are provided at the time of enrollment.
In some instances, you may have the opportunity to reply to a message, which may result in additional response messages.
Your consent to enrollment in any text message program is not a condition of purchase.
For information about a text message program you may text HELP to the applicable short code.</p>
<p>Message and data rates may apply.
This means that your carrier may charge you for each message we send to you or that you send to us.
It is your responsibility to know whether your carrier will charge you a per-message fee.
We do not charge a fee for our text message programs and assume no responsibility for charges by your carrier you may incur when you sign up to receive text messages from us.</p>
<p>You may opt out of a text message program at any time by texting the word STOP to the applicable short code from an enrolled device.
You will receive a final confirmation message that will confirm that you will no longer receive text messages from the applicable text message program unless you opt back into such program.
Different instructions may apply to health care text messages related to our pharmacy Services.</p>
3.4.
Loyalty Programs
<p>As part of our Services, we also offer loyalty programs that, individually or in combination with each other, use information to provide rewards and/or provide exclusive discounts or offers to program participants.
The program details below provide important information about participants’ rights and obligations in Company-sponsored loyalty programs.
All programs may not be available in all areas, and program functionality may vary by geographic location.
All participants are bound to these program details.</p>
<p>Certain Company divisions and/or select locations may run limited-time promotions offering additional single purchase and/or cumulative rewards.
Where offered, these promotions may be subject to additional or different advertised terms.</p>
<p>Loyalty Program Participation<br>
Participation in one or more of our loyalty programs is open, where offered, to everyone over the age of 13 who signs up or otherwise chooses to participate.
Though registration may be required for participation in some of our programs, membership is not considered to be exclusive to the registered individual and multiple people are permitted to use a single membership account.
For instance, participants are free to share their membership number or other account information with family and friends to receive in-store discounts and collectively earn and use Points and redeem special offers.
For this reason, information collected through our loyalty programs is not attributable to any individual or household.</p>
<p>Special Promotions<br>
We may make special offers available to loyalty program participants from time to time.
If applicable, the terms and conditions for such special offers will be disclosed at the time of the offer or promotion.
Please review those terms and conditions carefully, as there may be important conditions or limitations.
Availability of any special offer is subject to change without notice.</p>
<p>Communications<br>
We may contact loyalty program participants regarding any matter related to the Program.
These Program communications may be in addition to general marketing which you may receive from us.
Even if a participant opts out of marketing communications, the account may still continue to receive relationship/operational communications related to the Program.</p>
<p>General Terms<br>
Participation in a loyalty program and its benefits are offered at our sole discretion and may vary from brand to brand and location to location.
We may change a loyalty program, including any special promotions, benefits, or these program details at any time and for any reason.
We also reserve the right to alter loyalty program benefits and special promotions based on account activity, volume or purchases, geographic location, or other non-discriminatory factors.
We can delay enforcing our rights under a loyalty program without losing them.
In addition, our failure to exercise rights on any one occasion, or even on more than one occasion, does not constitute a waiver of our rights for any future occasion.
All waivers must be in writing.
Participants are solely liable for any applicable federal, state or local income, sales, use, or other taxes arising out of the accrual or use of Points or Rewards.</p>
Club Card
This program allows participants to receive instant advertised discounts on in-store purchases at participating locations.
To activate the discounts, the participant must either swipe or scan a membership card or enter a 10-digit phone number in the pin pad during checkout.
Participants who enter a cell phone number that is not linked to a just for U® account may receive one or more invitations by text to register for just for U to earn Points and redeem offers on Club Card purchases and otherwise combine program benefits where available.just for U<sup>®</sup>
This program allows participants to earn Points for every dollar spent on eligible purchases while also receiving offers for additional discounts on specified products at participating locations simply for using a valid Program account.
Points are accumulated to earn Rewards that may be redeemed on future gas or grocery purchases as described below.
To participate you must register online or through our mobile application or obtain consent to use the existing account information of another registered participant.<p>Earning Points and Rewards<br>
One Point will be awarded for each whole dollar spent on eligible grocery and pharmacy purchases and two Points will be earned for each whole dollar spent on eligible gift card purchases.
For example, if you spend $5.25 in a participating Company store on groceries while using a valid Program account, you will earn 5 Points.
Each 100 Points earned within a calendar month is converted into one Reward.</p>
<p>Eligible purchases exclude: (1) beer, wine and tobacco (and spirits in certain states).
(2) fuel and automotive services.
(3) bus passes, commuter passes, fishing or hunting licenses, ski passes, postage stamps, lottery tickets, amusement park passes, and event tickets.
(4) any financial instrument that can be redeemed for goods or Services at participating Company stores - including (but not limited to) financial services (Western Union), gift certificates/cards, money orders, and credit or debit cards issued by MasterCard®, Visa®, NetSpend®, etc..
(5) mobile phone cards.
(6) all fuel partner gift cards.
and (7) all fluid items in the refrigerated dairy section—including fluid dairy substitutes.
Sales tax payments and redemption value deposits are not purchases and are not eligible to earn Points.
For pharmacy purchases, only out-of-pocket costs (e.g., prescription co-pays) are eligible to earn Points.</p>
<p>Tracking Account Status<br>
Account details, such as Points earned, can be tracked by logging into the registered account through our mobile apps or websites or by reviewing the receipt from the account’s most recent transaction.</p>
<p>Redeeming Rewards for Gas or Groceries<br>
For Gas Rewards, one Reward equals 10 cents off per gallon.
Gas Rewards savings in a single transaction are limited (i) to 25 gallons (20 gallons in Jewel-Osco) for one vehicle per transaction––subject to rounding for applicable in-store fuel transactions and (ii) to the maximum per-gallon Gas Rewards discount at participating stations (usually 20 cents per gallon) and $1.00 off per gallon at participating Company stations.
To find a participating station, click here.
To use Gas Rewards, you must establish eligibility before pumping fuel.
Gas Rewards will be available for use at participating fuel retailers approximately one hour after being earned.
Gas Rewards may only be redeemed at participating fuel stations.</p>
<p>Grocery Rewards may be used only in the stores that offer such rewards (e.g., if offered by our Southern California Vons stores, Grocery Rewards items must be redeemed and picked up at Vons locations in Southern California).
Once you elect to apply earned Rewards toward a Grocery Rewards offer and confirm your selection, the applicable Rewards are deducted from your Account and cannot be used for another Grocery Reward offer or for Gas Rewards or be reinstated in any way.
You may claim your redeemed Grocery Rewards item through the end of the following calendar month (e.g., Grocery Rewards items redeemed and confirmed in April are available to pick up through the end of May).</p>
<p>There may be a lag between the time when you redeem your Rewards and when your Rewards balance is updated.
Attempting to reuse Rewards that have already been applied may result in a negative Rewards balance until you accumulate enough Rewards to eliminate such deficit.</p>
<p>Rewards and Points Expiration<br>
Rewards earned during each calendar month may be used only until the end of the following calendar month, after which such Rewards expire (Rewards earned in January, for example, expire at the end of February).
Moreover, any remaining Point totals less than 100 Points expire at the end of each calendar month.</p> 4.
What Choices Do You Have Over How Your Information Is Used?
<p>We give you choices about the information we collect and how we communicate with you.</p>
<ul>
<li>
<p>
<b>Printed Materials.</b>To opt out of receiving printed marketing materials at your postal address, such as advertisements, flyers or postcards, write to us at Albertsons Companies, Attn: Albertsons Customer Support Center, M.S.
10501, P.O.
Box 29093, Phoenix, AZ 85038 or submit your request online by clicking here.
Please be sure to include your name and mailing address exactly as they appear on the printed marketing materials you received.</p>
</li>
<li>
<p>
<b>Emails.</b> To opt out of receiving marketing materials via email, please send an unsubscribe request to our Customer Support Center by clicking here or click on the unsubscribe link at the bottom of the email that was sent to you and follow the directions on the resulting web page.</p>
</li>
<li>
<p>
<b>Facsimiles.</b> You may opt out of receiving communications sent by fax by using the methods provided in the communication or by contacting our Customer Support Center by clicking here.</p>
</li>
<li>
<p>
<b>Voice or Text Messages.</b> To opt out of receiving calls from our live representatives by telephone, contact our Customer Support Center by clicking here.
If you have consented to receive prerecorded voice messages or text messages, you may opt out of receiving them by using the method provided in the prerecorded voice message or text message or by contacting us at the address below.</p>
</li>
<li>
<p>
<b>Google Analytics.</b> You may opt out of the aggregation and analysis of data collected about you on our website by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.</p>
</li>
<li>
<p>
<b>Mobile Push Notifications/Alerts.</b> With your consent, we may send push notification or alerts to your mobile device.
You can deactivate these messages at any time by changing the notification settings on your mobile device.</p>
</li>
<li>
<p>
<b>Location Information.</b> You may have the ability to turn location-based services on and off by adjusting the settings of your internet browser or mobile device or, for some devices, by revoking permission for our mobile app to access your location information.</p>
</li>
<li>
<p>
<b>Cookies, Web Beacons, and Similar Technologies.</b> Your browser may offer the ability to block or delete cookies from your device.
Simply follow your browser’s instruction on how to block and clear cookies.
Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove Flash cookies.
To learn how you can manage your Flash cookie settings, please visit Adobe’s website.
Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Services.
We also offer AdChoices on some of our websites which provides you with the ability to opt out of certain third party services that may involve tracking.
For more information, click on the AdChoices link listed under “About This Site” on our websites that offer this service</p>
</li>
<li>
<p>
<b>Custom Audience Campaigns.</b> As noted above, we sometimes work with third-party platforms to serve ads to you as part of a customized campaign on those platforms.
You may be able to opt-out of receiving these ads by adjusting your preferences within these third-party platforms.</p>
</li>
</ul>
5.
What Personal Information Do We Share And For What Purpose?
<p>We do not sell or rent your personal information to third parties or disclose to them the personal information we collect for their own direct marketing or other purposes.
While we do not sell or rent your personal information, we disclose personal information for business purposes as described below:</p>
<ul>
<li>
<p>
<b>Our Subsidiaries.</b> Our subsidiary entities may also collect and share the personal information described in this Privacy Policy with their parent, subsidiary, and affiliate entities for use in the ways described in this policy.</p>
</li>
<li>
<p>
<b>Service Providers.</b> We may disclose your personal information to our service providers to help handle parts of our business because of their expertise, resources, or scale.
They help us do things like fulfill orders, process your payments and requests, verify your information, monitor activity on our Services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, administer and send mobile messages, serve ads on this and other services, provide consulting services, and otherwise perform actions consistent with the uses described above.
We may also use them to host our sites, microsites, mobile sites, and mobile applications, conduct market research, or send you information regarding our products or Services or those of other companies with whom we conduct business.</p>
</li>
<li>
<p>
<b>Legal Process and Emergency Response.</b> We may also disclose specific information about visitors to our Services if we have a good-faith belief that it’s necessary or authorized under the law or to protect our customers, the public, or our business.</p>
</li>
<li>
<p>
<b>Certain Business Transfers.</b> Your personal information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, or joint venture, or for the financing or sale of Company assets and could be transferred to another party as one of the business assets in such a transaction.
It may also be disclosed in the event of insolvency, bankruptcy, or receivership.</p>
</li>
</ul>
6.
How Do We Protect Personal Information?
<p>We use various physical, electronic, and procedural measures designed to protect your personal information from unauthorized access, disclosure, or misuse.
We use strong encryption when transmitting your sensitive personal information.
However, because no data security systems are completely secure, we do not warrant that any personal information that you provide to us will be secure or safe from unauthorized access.
If you provide any personal information to us, you do so at your own risk.</p>
7.
Where Is Personal Information Stored And Processed?
<p>We are based in the United States.
When we obtain information about you, we may transfer, process, and store such information in the United States and other countries.
By using our websites and mobile applications, you consent to the transfer to, and to the processing and storage of your information in, countries outside of your country of residence, which may have different data protection laws than those in the country in which you reside.</p>
8.
Will There Be Changes To This Policy?
<p>We will modify this Privacy Policy if our practices change or if the law requires it.
We will notify you of such changes by posting the modified version on our website and indicating the date it was last modified.
The date this Privacy Policy was last modified is at the top of this page.
We encourage you to visit our website periodically to view the latest version of this Privacy Policy.</p>
9.
How To Contact Us
<p>If you have questions or comments about this Privacy Policy or other privacy-related matters, you may contact us as follows:</p>
<p>
<b>Mailing Address:</b>Albertsons Companies, Inc.<br> Attn: Albertsons Privacy Office <br> 250 Parkcenter Blvd.<br> Boise, ID 83706</p>
<p>
<b>Email Address:</b>privacyoffice@albertsons.com</p>
<p>
<b>Toll-free Number:</b>(877) 251-6559 (toll free)</p>
<ul>
<li>California Consumer Requests
</li>
</ul>
<p>Use our online form to submit a privacy request.</p>
<ul>
<li>Nevada Consumer Requests
</li>
</ul>
<p>Use our online form to submit a privacy request.</p>
<p> </p>
<p>© 2020 Albertsons Companies.
All rights reserved. </p>
UPDATED Supplemental Privacy Statement For California Consumers
<p>Effective: January 1, 2021 .
Updated: February 2, 2021</p>
<p>If you are a California Consumer, this Supplemental Privacy Statement (“CA Statement” or “Notice”) also applies to you and appends the terms of our Privacy Policy.
Capitalized terms used but not defined herein, shall have the meanings ascribed to such terms in California Civil Code § 1798.100, et seq.
(together with the regulations thereunder, the “CCPA”), as applicable.</p>
<p>Consistent with the CCPA, information concerning job applicants, current and former employees and independent contractors (collectively, “Personnel”), and subjects of certain business-to-business communications acting solely in their capacity (“B2B data subjects”) as representatives of another business is exempt from some or all of the requirements of the CCPA. .
This Notice does not apply to B2B data subjects, and only Sections 1 and 2 apply to Personnel. .
Publicly available information is also not treated as Personal Information (“PI”) under the CCPA, so this notice is not intended to apply to that data and your Consumer privacy rights do not apply to that data.</p>
<p>Sections 1 and 2 of this Notice cover our Collection, use, disclosure, and Sale of California Consumers’ and our Personnel’s PI for the twelve months preceding January 1, 2021, and will be updated annually.
Our practices in calendar year 2021 may change.
However, if our practices are materially different such that we think a Consumer would reasonably expect notice, we will provide notice in connection with the applicable collection and use in other applicable privacy policies and notices.
Section 4 of this Notice describes the rights California Consumers have under the CCPA and how to exercise them, but does not apply to Personnel.</p>
<p>
<b>
<i>This Notice reflects our good faith understanding of the law and our data practices as of the date posted (set forth above). .
Accordingly, we may from time-to-time update information in this and other notices regarding our data practices and your rights, modify our methods for responding to your requests, and/or supplement our response to your requests, as we continue to develop our compliance program to reflect the evolution of the law and our understanding of how it relates to our data practices.</i>
</b>
<i>
</i>
</p>
<p>
<b>This statement addresses these topics:</b>
</p>
<ol>
<li>Collection And Use Of Personal Information</li>
<li>Sharing Personal Information<br>
</li>
<li>Deidentified Patient Information<br>
</li>
<li>California Consumer Privacy Rights<br>
</li>
</ol>
<p>During the twelve months prior to the effective date of this Privacy Policy, dependent upon how you have interacted with us, we may have:<br>
</p>
<p>
<b>1.
Collection And Use Of Personal Information</b>
</p>
<p>During calendar year 2020, depending on how you have interacted with us, we may have:</p>
<p>(a) Collected the following categories of PI about you:</p>
<ul>
<li>
<b>Identifiers </b>such as name, alias, postal address, unique personal identifier (such as pixels, cookies, web beacons), social security number, IP address, email address, phone number, passport number, customer number, account name, ID card information, or other similar identifiers;</li>
<li>
<b>Personal records</b>, such as physical characteristics or descriptions, signature, education, employment history, bank account information, medical information, financial information, or health insurance information;</li>
<li>
<b>Characteristics</b> such as age, race, color, ancestry, national origin, marital status, religion, sex, veteran or military status, medical condition, and mental or physical disability;</li>
<li>
<b>Commercial information</b>, such as records or personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;</li>
<li>
<b>Online usage information</b>, such as Internet and other electronic network activity information including, but not limited to, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement;</li>
<li>
<b>Geolocation data;</b>
</li>
<li>
<b>Sensory information</b>, such as audio, visual, and similar information.
and</li>
<li>
<b>Inferences</b> drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.</li>
</ul>
<p>There may be additional information that we collected that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA, but will not include it when we are required to describe our practices by category of PI.</p>
<p>As permitted by applicable law, we do not treat Deidentified data or Aggregate Consumer Information as PI and we reserve the right to convert, or permit others to convert, your PI into Deidentified or Aggregate Consumer Information. .
We have no obligation to re-identify such information or keep it longer than we need it for our own purposes. </p>
<p>(b) Collected PI about you from the following categories of sources:</p>
<ul>
<li>Directly from you.
For example, when you create an account, make a purchase, apply for or accept an employment position with us, etc.</li>
<li>Your friends, family, or associations, including through their use of the Services.</li>
<li>Directly and indirectly from activity on our Services, and Third Party social media pages and other services.
For example, see the types of collection in the “Automatically Collected Information” section above.</li>
<li>Service Providers who provide services on our behalf such as those used to fulfill orders, process your payments and requests, verify your information, monitor activity on our Services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, administer and send mobile messages, serve ads on this and other services, and provide consulting services.</li>
<li>Third Party data providers.</li>
<li>Creation by us.</li>
</ul>
<p>(c) .
Collected PI about you for one or more of the following Business Purposes:</p>
<ul>
<li>Providing customer service, including responding to your requests or inquiries.</li>
<li>Processing and completing your transactions including, as applicable, order confirmation/re-scheduling, billing, enrollment in our loyalty or other programs, and delivering products and/or Services.</li>
<li>Personalizing your experience with our Services with content and offers that are tailored to you, including special offers from other companies.</li>
<li>Providing you with newsletters, articles, product or service alerts, new product or service announcements, savings awards, event invitations, and other information.</li>
<li>Including you in market research, surveys, promotions, sweepstakes, and contests.</li>
<li>Improving our Services, the manner in which offers are made on our Services, the purchasing decisions of our customers, and the interactions visitors have with our Services.</li>
<li>Evaluating your shopping experience or existing products and Services or to create new items.</li>
<li>Alerting you about a product safety announcement or recall or correction of an offer, promotion, or advertisement.</li>
<li>Keeping a record of our interactions with you if you place an order or otherwise deal with our representatives over the telephone or online.</li>
<li>Verifying and validating your identity or otherwise preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems or to meet legal obligations.</li>
<li>Enabling you to interact with content service providers, whether by linking to their sites, viewing their content within our online environment, or by viewing our content within their online environment.</li>
<li>Creating aggregated, pseudonymized, or anonymized information for analytical and statistical purposes.</li>
<li>Enforcing our Terms of Use and other agreements.</li>
</ul>
<p>Additional Business Purposes for which we Collect, and may disclose, PI include sharing PI with Third Parties for other than a Sale or one of the foregoing Business Purposes as required or permitted by applicable law, such as to our vendors that perform services for us, to the government or private parties to comply with law or legal process, to the Consumer or other parties at the Consumer’s request or direction, for the additional purposes explained in our online Privacy Policy or at the point of collection, and to assignees as part of a merger or asset sale (“Other Business Purposes”).
Subject to restrictions and obligations of the CCPA, our vendors may also use your PI for some or all of the above listed Business Purposes, and engage subcontractors to help them perform services for us. .
In addition, we may Collect, retain, use and disclose your PI as required or permitted by applicable law. .
We treat all of these purposes as Other Business Purposes.</p>
<p>
<b>2.
Sharing Personal Information</b>
</p>
<p>We may disclose your PI to a Service Provider for a Business Purpose, or, at your direction, with Third Parties such as sponsors of promotions, sweepstakes or contests.
In 2020, we disclosed the following categories of PI for a Business Purpose to the following categories of recipients:</p>
<ul>
<li>
<b>Identifiers:</b> Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, compliance, tech performance measurement, and other Service Providers;</li>
<li>
<b>Personal records:</b> Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, compliance, tech performance measurement, and other Service Providers;</li>
<li>
<b>Characteristics:</b> Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, compliance, and other Service Providers;</li>
<li>
<b>Commercial information:</b> Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, and other Service Providers;</li>
<li>
<b>Online usage information:</b> Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, compliance, tech performance measurement, and other Service Providers;</li>
<li>
<b>Geolocation data: </b>Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, compliance, tech performance measurement, and other Service Providers;</li>
<li>
<b>Sensory information: </b>Retail security, compliance, and other Service Providers.
and• Inferences: Marketing/advertising agencies, analytics &.
retail merchandising and marketing mix measurement providers, and other Service Providers.We do not believe that we Sold any PI of California Consumers in 2020.
See Section 4(c) below for information as to how to opt-out of future Sales.<br>
</li>
</ul>
<p>
<b>3.
Deidentified Patient Information</b>
</p>
<p>We collect and deidentify certain health care patient information in our capacity as a pharmacy health care provider.
In some instances, we disclose, license, and/or sell the deidentified information derived from this health care patient information.
To deidentify this health care patient information, we use either the deidentification methodology: (1) described in Section 164.514(b)(2) of Title 45 of the Code of Federal Regulations, commonly known as the HIPAA safe harbor method.
or (2) described in Section 164.514(b)(1) of Title 45 of the Code of Federal Regulations, commonly known as the HIPAA expert determination method.
As such, this deidentified information is not PI. </p>
<p>
<b>4.
California Consumer Privacy Rights</b>
<br>
(a) Right to Know:</p>
<ul>
<li>Specific Pieces</li>
</ul>
<p>You have the right to make or obtain a transportable copy, no more than twice in a twelve-month period, of your PI that we have Collected and are maintaining for the period that is 12 months prior to the request date.
To make a request, click here, or call us at (877) 251-6559 (toll free).
You will be asked to provide your name, email address, country of residence, state, and request details. .
A confirmation email will be sent to the email address you provide to begin the process to verify your identity.
To protect your privacy and security we require verification of your identity to a high degree of certainty based on information we already have about you.
If you cannot meet that standard, we will treat your request as a “categories request” as explained in the next section.</p>
<p>To protect your security and the rights of others, we may not be able to provide you all of the PI we may have on you.
See Section 4(f) below for more details.</p>
<ul>
<li>Categories</li>
</ul>
<p>California Consumers have the right, no more than twice in a twelve-month period, to request that we disclose the categories of PI collected in the prior 12 months.
the categories of sources from which such PI is collected.
the business or commercial purpose for such collection or its sale (if applicable).
the categories of third parties with which the businesses shares such PI, and, for each category of such PI, the categories of recipients of business purposes disclosures and, if applicable, of sales.</p>
<p>To make a request, click here, or call us at (877) 251-6559 (toll free).
You will be asked to provide your name, email address, country of residence, state, and request details.
A confirmation email will be sent to the email address you provide to begin the process to verify your identity.
To protect your privacy and security we require verification of your identity to a reasonable degree of certainty based on information we already have about you.
If you cannot meet that standard, we will refer you to this Notice where you can review our categories disclosures generally in Sections 1 and 2 above</p>
<p>(b) Right to Delete</p>
<p>Except to the extent we have a basis for retention under the CCPA, you may request that we delete your PI that we have Collected directly from you and are maintaining. .
Our retention rights include, without limitation, to complete transactions and provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.
Note also that we are not required to delete your PI that we did not Collect directly from you.
To make a request, click here, or call us at (877) 251-6559 (toll free).
You will be asked to provide your name, email address, country of residence, state, and request details.
A confirmation will be sent to the email address you provide to begin the process to verify your identity and to confirm that you want to delete your information.
To the extent that we are able to sufficiently verify your identity and have a basis for retaining some of the PI you requested that we delete, we will explain the basis for the retention and will only retain it for such purpose and for so long as the retention purpose continues to exist.</p>
<p>Rather than exercising a deletion request, you may alternatively exercise more limited control of your PI by instead opting out of e-mail marketing communications by following the unsubscribe instructions on the footer of those emails. </p>
<p>(c) “Do Not Sell My Personal Information”</p>
<p>While California law also allows for California residents to opt out of the sale of their PI, we do not believe that we currently Sell PI of California Consumers as those terms are defined by the CCPA, but reserve the right to do so in the future. .
However, we offer California Consumer’s the ability to opt-out of future Sales here or call us at (877) 251-6559 (toll free). .
Although we believe that Third Party cookies we permit to be associated with our online Services restrict their data processing to what is permitted by Service Providers under the CCPA as to California Consumers, and thus do not result in a Sale of PI by us, to learn more about cookie choices here<b>.</b>
</p>
<p>(d) Verification Process</p>
<p>After you (or a qualified agent which you duly authorize) submits a request to know or delete your PI, we are required to Verify your request to ensure that the request is not fraudulent (“Verifiable Consumer Request”)”.
Thus, upon receiving your request we will take measures to verify that the request is legitimate.
These verification efforts may require additional information from you which may include information you have provided us in the past.
For instance, if you have previously provided your name to us, we may ask you for other information (e.g., last four digits of your credit card, email address, phone number, or transaction history) so that we can match the new information you provide with the information we have.
We may also use other verification methods as the circumstances dictate.
If through reasonable efforts we are unable to verify your request to the appropriate degree of certainty, we will notify you.</p>
<p>We will use PI provided in a Verifiable Consumer Request only to verify your identity or your authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.</p>
<p>(e) Agent Requests</p>
<p>Note you can authorize an agent to exercise any of these California privacy rights on your behalf, subject to the agent request requirements of the CCPA.
Note that we will take additional measures to verify the legal authority of your agent.
Agents should contact us here.</p>
<p>(f) Exceptions</p>
<p>Notwithstanding anything to the contrary, we may Collect, use and disclose your PI as required or permitted by applicable law and this may override your CCPA rights.
In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.
Further, to protect your privacy and security we will not provide you with access to or copies of sensitive PI such as government identification or financial account numbers, passwords or answers to security questions or biometric identifiers.
provided, however, that we will inform you if we maintain any such applicable types of PI. </p>
<p>Some PI we maintain about Consumers is not sufficiently associated with enough PI about the Consumer for us to be able to verify that it is a particular Consumer’s PI when a Consumer request that requires verification pursuant to the CCPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). .
As required by the CCPA, we do not include that PI in response to those requests.
If we cannot comply fully with a request, we will explain the reasons in our response, unless we are prohibited from doing so by applicable law. </p>
<p>We will make commercially reasonable efforts to identify Consumer PI that we Collect, process, store, disclose and otherwise use and to respond to your California Consumer rights requests.
In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest that you receive the most recent or a summary of your PI and give you the opportunity to elect whether you want the rest or not.
We reserve the right to direct you to where you may access and copy responsive PI yourself.
We will typically not charge a fee to fully respond to your requests.
provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome.
If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision.
You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
As permitted by the CCPA, we are also not required to search for PI not maintained in a searchable or reasonably accessible format that is used for certain internal purposes only, but we apply this exception we will respond to your request with a description of the categories of PI to which this exception applies. </p>
<p>In addition, as explained above, we will reject requests to the extent we are not able to sufficiently verify your identity, or your agent’s authority.
If we conclude we have a basis for not fully responding to your request, our response to you will explain the basis for the limitation, unless we are prohibited from doing so by applicable law.</p>
<p>(g) Financial Incentives and Non-discrimination</p>
<p>California residents also have the right not to receive discriminatory treatment for the exercise of any of the privacy rights conferred by the California Consumer Privacy Act.
As of the Effective Date of this CA Statement we did not offer any programs requiring you to limit any of your CCPA rights, or otherwise require you to limit your CCPA rights in connection with charging a different price or rate, or offering a different level or quality of good or service.
If we do so, the CCPA requires certain program terms and notices for California Consumer and the material aspects of any such program, and the rights of California participants, will be explained and described in its program terms.
Participating in any such programs will be entirely optional.
We may add or change programs and/or their terms by posting notice on the program descriptions so check them regularly.</p>
<p>Although you may participate in all of our loyalty programs on an anonymous basis (e.g., obtaining but not registering a club card) our loyalty programs allow you to provide us PI (e.g., to use your phone number as your account identifier or providing an email address to receive email communications).
Our loyalty programs provide members with various membership benefits from time-to-time explained at “just for U,” “Monopoly,” and Gas Rewards/ Grocery Rewards / Club Card. .
While membership is optional (you must opt-in and you can terminate at any time, as explained in the program descriptions and terms available by using the links in the prior sentence or by simply calling customer service at 877-723-3929, and you can remain in the program and still opt-out of our promotional emails and exercise your CCPA rights while electing to remain in the program and receive all of its benefits, the collection of PI for account credentials and communications, and to monitor program-related activity and otherwise operate the programs, could be characterized as a “financial incentive” under the CCPA given that we provide member-only benefits and collect PI from some, but not all members, to help facilitate that. .
Accordingly, we provide members notice that we value the PI collected through our loyalty programs as the equivalent of our total program operating expenses (excluding the value of member benefits such as discounts), the details of which we maintain as a trade secret, and we pay these expenses and provide the program benefits to foster a positive relationship with members that is invaluable. .
In addition, we value the PI collected through our loyalty program, as well as the value of the loyalty program, as the equivalent of the value of member benefits, such as discounts and other savings, received by members, which is also a trade secret.
However, we have determined, to the extent we can track relevant consumer activities, that our customers that use our loyalty programs redeem more manufacture coupons and Albertsons offers than do consumers not participating in our loyalty programs, which we conclude benefits them and us mutually. .
Consumers should review the benefits description and program terms linked to in this paragraph above, as well as our full Privacy Policy, which applies to the Identifiers, Personal records, Commercial information, Online usage information, Inferences from program data and other PI we may collect in connection with our loyalty programs so that they can make an informed decision on whether to participate. .
Also, please note that if you make a CCPA deletion request your program PI will be maintained for loyalty program operations, unless you also terminate your applicable loyalty accounts, which you may do at any time by following the instructions in the applicable program terms or calling customer service at 877-723-3929.</p>
<p>
</p>