A. Types of Information We Collect; Sales/Sharing of Personal Information
We collect the categories of Personal Information identified below.
| Category | Examples |
|---|---|
| Identifiers and biographical information | A real name, postal address, unique personal identifier, Real Rewards member identifier, online identifier, birthday information (month and day), Internet Protocol (IP) address, email address, unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, advertising identifiers (for example, IDFAs and IFAs) or similar identifiers. |
| Personal Information categories listed in the California Customer Records statute | Payment card details. |
| Commercial information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, and your responses to our survey questions. |
| Internet or other similar network activity | Browsing history, search history, computer or mobile-device operating system and browser type; type of mobile device and its settings; referring website (a site that has led you to ours) or application; online activity on other websites, applications or social media; information on a consumer’s interaction with a website, application, or advertisement; communications to us or regarding us on social media; and activity related to how you use our online services, such as access dates and times, the pages you visit on our sites or in our mobile apps. |
| Geolocation data | Physical location, including to help you find a store location near you in our Mobile App. |
| Audio, electronic, visual, thermal, olfactory, or similar information | Images collected via CCTV in our store locations. |
| Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, predispositions, behavior and attitudes. |
We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you or for any purpose other than the permissible purposes set forth in the regulations implementing applicable privacy laws. Such purposes include providing our services and verifying, maintaining the quality of, and improving our services.
B. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information:
- To provide you with the products and services you request, including to fulfill orders and process payments for our products and services as well as communicate with you about your orders, purchases or accounts with us, requests, questions, and comments. For example, if you provide us with Personal Information in order for us to provide you with rewards through our Loyalty Program, we will use that information to determine the rewards for which you qualify and provide you those rewards through our mobile app or other methods as disclosed.
- To provide online services to you, which includes our websites or mobile apps.
- To provide customer support, including to process any concerns about our services.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To market to you, improve our services, and the following additional legitimate business interests: (a) use analytics and profiling technology to personalize your experience, deliver content (including advertising) tailored to your interests and how you use our online services or in-store technologies, manage our business, help diagnose technical and service issues, administer our online services and in-store technologies, identify users of our online services, identify a device for fraud prevention purposes, gather demographic information about our customers, and determine usage patterns of our services; (b) maintain, manage, and improve our products, offers, promotions, and online services and other technology; (c) send you e-mails or text messages about our products and services, competitions, offers, promotions or special events that we believe may interest you; (d) to send you e-mails or text messages about the products and services of our business partners; (e) provide location-based services; (f) deploy cookies and similar technologies; and (g) provide online services to you, which includes our websites or mobile apps.
- To conduct surveys on customer satisfaction.
- To carry out our obligations and enforce our rights arising from the Loyalty Program, Ordering Application, Contests, Sweepstakes, Games or any other contract between you and us.
- As necessary or appropriate to protect the rights, property or safety of us, our customers or others and ensure the security of our networks and systems.
- To respond to law enforcement requests and as required by applicable law, court order, legal request, governmental regulations, law enforcement investigation or an investigation on a matter of public safety.
- As described to you when collecting your Personal Information or as otherwise set forth under applicable privacy laws.
We may use the information we collect about you in other ways, which we will tell you about at the time we collect it or for which we will seek your consent. We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing notice to you.
Lawful Basis for Processing: The law of certain jurisdictions requires us to set out the lawful basis that we rely on to collect and use your Personal Information as described in this Consumer Privacy Policy. Where applicable, the lawful bases upon which we rely on in order to collect and use your personal information are as follows:
- Consent: We may collect, use, and disclose your Personal Information on the basis of the consent that you provide us at the point of information collection or disclosure. You have the right to revoke your consent at any time. Where we required by applicable law, we will obtain consent prior to processing your Personal Information.
- Contractual Necessity: We may collect and use certain personal information where it is either necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This may include personal information used to provide you with our products and related services and related transaction information.
- Compliance with a Legal Obligation: We are subject to various legal requirements in the jurisdictions in which we operate, and we may use, disclose, and retain your Personal Information if necessary for us to comply with a legal obligation arising under an applicable law to which we are subject.
- Legitimate Interests: We may collect and use your Personal Information to the extent necessary to carry out our legitimate interests (or those of a third party), provided that such interests do not outweigh your interests or fundamental rights and freedoms. For example, we may collect and use your Personal Information in reliance on a legitimate interest in managing our relationship with you; conducting and managing our business; providing you with customer support; conducting market research; developing and enhancing our Services as well as our products and services; detecting and preventing fraud and other harmful activities; and monitoring and maintaining the security of our data, systems, and networks.
C. Data Retention Policy
We will retain your Personal Information for as long as reasonably necessary to provide you with our services that you request, for marketing purposes unless you opt out as described in our Consumer Privacy Policy, or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and when we consider our approach we take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.