Walmart Customer Spark Community Privacy Notice

Last Updated: September 30, 2024

This Privacy Notice supplements the Walmart Customer Privacy Notice and it describes how and why Walmart, Inc. (“Walmart”) collects, uses and discloses your Personal Information (as defined below) in connection with your participation in the Walmart Customer Spark Community (“Spark Community”) and access and use of the Spark Community Sites (“Spark Community Sites”). The Spark Community Sites include the website associated with the Spark Community currently located at Walmart - Customer Spark and the materials and services available on or through it, as well as any mobile applications offered by Walmart that provide access to the Spark Community’s functionality and services.

By registering for a Spark Community Account (“Spark Account”), and by continuing to use your Spark Community Account and accessing the Spark Community Sites, you acknowledge and agree that you understand that, in addition to Walmart, you are interacting with Walmart’s suppliers or third parties who are provided access to or participate in the Spark Community (“Walmart Clients”) and you direct us to disclose your personal information, as outlined below, to Walmart Clients and their designees.

This Notice covers personal information collected via the Spark Community, the Spark Community Sites or your Spark Account.

We may collect or receive the following categories of personal information. Not all categories may be collected or received about every individual:

• Basic Personal Identifiers, such as name, telephone number, physical address, email address, national identification numbers, driver’s license numbers, and signatures
• Device and Online Identifiers, such as account login information, Mac address, IP address, cookie IDs, mobile ad IDs, and social media information
• Internet and Other Network Activity Information, such as information about your browsing or search activity as well as your interactions with our websites, mobile applications, emails, or advertisements such as keystroke patterns (these tell us if it’s you who is interacting with us, or a bot)
• Commercial Information, such as purchase and transaction history information (such as products or services you have purchased, rented, or returned), product testimonials, travel and vacation information, and sweepstakes and contest entries
• Communications, such as the content of emails, text messages, or other communications, call logs, and calendar information, where Walmart is a party to the exchange
• Demographic Information, such as age, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information, family health, number of children, number of cars owned, and software or virtual assets owned
• Financial Information, such as credit or debit card numbers, financial account numbers, and information related to your rewards account
• Biometric Information, such as voice prints, imagery of the iris or retina, face geometry, and palm prints or fingerprints
• Geolocation, such as data about the location of your device, which may be imprecise (i.e. inferred from your device’s IP address). If you provide your consent, this data may be precise. For more information about precise geolocation, see the “Walmart collects information in the following ways” section below.
• Sensory Information, such as audio, visual information, and other sensory information such as photographs and audio and video recordings
• Background Information, such as background checks and criminal convictions
• Inferences, such as individual preferences and characteristics. This may include inferences related to shopping patterns and behaviors, intelligence, and aptitudes
• Any other information you choose to provide, such as via surveys or during discussions with Walmart or Walmart Clients or their designees. This may include, at your discretion, health and safety-related information.

Walmart collects information in the following ways:

• Directly from you, for example, when you submit information through the Spark Community Sites or your Spark Account, or complete one of our surveys or other activities. We also collect information directly from you when you use features on our website or the Spark app that enable us, with your consent, to access the camera on your computer or mobile device to enable you to upload photos. You must give us your permission before we access photos on your computer or mobile device, and you can opt out of providing access to them at any time by adjusting the settings on your device.
• You also passively provide us information in other ways through technology. Some of this information may be linked to you personally. This information includes device and online identifiers, along with internet and other network activity information, which helps the Spark Community Sites work correctly and supports our analytics efforts. You may be able to control our collection of some of this information via your device or browser settings.

Other sources from which we may collect information include:

• Another company within our family of companies
• An external third-party source
• Another solution or asset
• Other sources, when it is appropriate, to help us correct or supplement our records, improve the quality or personalization of our services, increase the appeal and relevance of advertising, and to prevent or detect fraud

Walmart may use personal information for a variety of business purposes, including:

• Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services. These services may be in connection with your Spark Account, such as for rewards redemption.
• To conduct auditing and monitoring of transactions and engagement
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us
• Helping to ensure security and integrity and prevent fraud
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them
• Debugging to identify and repair errors
• To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
• To conduct research and development, including undertaking internal research for technological development and demonstration
• To fulfill our legal function or obligation
• Advertising and marketing, including content and images from Customer Spark interviews and testimonials.

We may use sensitive personal information for each of the purposes described above and to make inferences about customers, which we may use to promote certain products or services.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

You may use the Global Privacy Control (GPC) to opt out of the processing of personal information for purposes of Targeted Advertising or the sale of your personal information through the use of the GPC. If you notify us of your opt-out preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal, and when you log in to your account from that device, the opt-out will extend to your account, as well. Our Sites will not respond to other types of “do not track” signals. For opt out rights related to specific states, see the State Privacy Rights section below.

We may disclose your personal information outside of Walmart in the following circumstances:

Walmart Clients and their Designees:

In connection with your participation in the Spark Community, and access and use of the Spark Community Sites, you acknowledge and agree that you are directing us to disclose your personal information, as described in the “What Information Does Walmart Collect and How Does It Collect It?” section above, with Walmart Clients and their designees.

In particular, Walmart Clients and their designees may view, use and share, for any purpose and without additional compensation to you, photos, audio and video recordings that you may take or record and upload via the Spark Community Sites, as well as any other information you choose to provide (such as via surveys). Walmart Clients and their designees may view such recordings and information, along with other personal information about you (such as your gender and age), and download and share such recordings and information for any purpose consistent with, or as described in, the Spark Community Sites Terms of Use.

Service Providers:

To provide and protect our services, Walmart may disclose the information we have about you to those businesses that provide services to Walmart. Service providers are permitted by us to use personal information to provide us with services, such as marketing; hosting our online services; evaluating requests or applications for products and services; measuring and optimizing the performance of our online services, including the Spark Community Sites; and helping us prevent and detect fraud and information security risks.

Business Purposes and as Otherwise Permitted by Law:

We disclose personal information for the business purposes described above in “How We Use Your Information” and also as otherwise permitted by law, which may include:

• Any disclosure to which you provided consent if your consent has not been revoked, except as otherwise provided in the Spark Community Sites Terms of Use;
• To law enforcement or governmental agencies, such as to protect the interests of Walmart to prevent or prosecute fraud and other illegal activities;
• In connection with a proposed or actual sale, merger, transfer or exchange of all or a portion of a business or operating unit;
• To comply with a properly authorized civil, criminal or regulatory investigation, or subpoena or summons by federal, state or local authorities;
• To respond to judicial process or government regulatory authorities having jurisdiction over a licensee for examination, compliance or other purposes as authorized by law; and
• Protecting our rights, property, or safety or those of others.

Other Businesses in our Corporate Family:

We may disclose your personal information to other brands and businesses within the Walmart corporate family. When we do, the information will be used in ways that are consistent with this Privacy Notice.

Deidentified & Aggregated Information:

We may also use and disclose for any purpose information that has been de-identified or aggregated in a manner such that it no longer reveals your specific identity (for example, quantitative and statistical data regarding purchasing behavior), except where we are required to do otherwise under applicable law. (For clarity, we do not de-identify or aggregate photos, videos and audio recordings.)

If we are required to treat de-identified or aggregated information as personal information under applicable law, we may use and disclose it for the purposes for which we use and disclose personal information as detailed in this Privacy Notice. In some instances, we may combine de-identified or

aggregated with personal information. If we do, we will treat the combined information as personal information as long as it is combined.

Categories of Personal Information We Disclose to Each Type of Third Party:

We may disclose your personal information to certain categories of third parties, as described below.

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Notice or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or internal policy. We dispose of the information we collect in accordance with our retention policies and procedures.

To help protect your personal information from unauthorized access and use, we use reasonable security measures. These measures include physical, technical and administrative safeguards designed to protect your personal information.

The Spark Community Sites are not directed to children under the age of 13 and Walmart does not knowingly collect personal information from children under the age of 13 via the Spark Community Sites.

California Privacy Rights Act

Notice of Financial Incentive:

If you are a member of the Spark Community, you may voluntarily participate in the Spark Community rewards program by following the instructions in the email invite you receive. If you elect to participate, we will process the personal information you provide in accordance with our California Consumer Privacy Act Notice.

The specific categories of personal information that we may use in connection with your participation in the Spark Community rewards program are: identifiers; personal information described in the California Customer Records statute; characteristics of protected classifications under California or federal law; commercial information; audio, electronic, visual, thermal, olfactory, or similar information; professional or employment-related information; inferences drawn from other personal information. We also may use the following types of sensitive personal information: racial or ethnic origin, if you choose to provide it.

You can opt out of communications or withdraw from this program at any time by: (i) logging into your Spark Community Account and unsubscribing from the program under the Spark Account; (ii) using the footer within the Spark Community invite to unsubscribe; or (iii) directly reaching out to Customer Care.

As part of your participation in the Spark Community rewards program, we may offer you the opportunity to earn points by completing certain activities including, but not limited to, surveys, in-depth interviews, focus groups, and submitting photos and/or videos. These points can be redeemed for Walmart eGift cards. These eGift cards typically range in value from $1.00 to $100.00. For more information about the Spark Community rewards program, please review our Walmart Customer Spark Community Terms of Use.

Colorado Privacy Act

This Colorado Consumer Privacy Notice supplements the information in the Walmart Privacy Notice and applies solely to Colorado consumers who interact with us in an individual or household capacity. This Colorado Notice uses certain terms that have the meaning given to them in the Colorado Privacy Act (the “CPA”).

Collection, Use and Sharing of Personal Data

We may collect, use and share personal data as described in the chart below.  For more information on the categories of personal data we collect, please see the "What Personal Information Do We Collect?" section of the Walmart Privacy Notice.

Processing Purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage or providing similar services
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us
• Helping to ensure security and integrity and prevent fraud
• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them
• Debugging to identify and repair errors
• Conducting business analysis, such as analytics, projections and identifying areas for operational improvement
• Fulfilling our legal functions or obligations

We do not knowingly process personal data from children under the age of 13.  We also do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined in the CPA.

Colorado Privacy Rights

If you are a Colorado consumer who interacts with us in an individual or household capacity (and not in a commercial or employment context), you may have the right to:

(1) request access to, correction of or deletion of your personal data; and

(2) opt-out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data.

In addition, you may have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal data to another entity.

How to Submit a Request

To request access to, correction of or deletion of your personal data, go to the footer of our website or settings section of our app and select the “Request My Personal Information” link. To opt-out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data, go to the footer of our website or the settings section of our app and select the “My Privacy Choices” link.

To submit an opt-out request as an authorized agent on behalf of a consumer, please contact us as described above. If you submit a request through an authorized agent, we may ask for your written permission or a power of attorney. Where you provided your authorized agent with written permission, we may require that you also verify your identity.

How We Verify Your Identity To Complete Your Requests

If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

First name*, Middle initial, Last name*

Address*

Email address

Phone number

*Required field

When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent disclosure of your personal information resulting from fraudulent requests. You may be asked to log into your online account and complete a one-time passcode validation. In the event more documentation is necessary to verify your identity, we will notify you directly.

How to Submit an Appeal

You may appeal our decision with respect to a request you have submitted by going to our privacy request page.

Contact Us

For more information on how to contact us about this Colorado Consumer Privacy Notice, please see the “Who Can I Contact at Walmart About the Privacy Notice?” section of the Walmart Privacy Notice.

Connecticut Privacy Rights

Connecticut residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Request My Personal Information” link:

• Request to Access My Personal Information
• Delete My Personal Information
• Correct My Personal Information

Connecticut residents can exercise the following rights by going to the footer of our website or the settings section of our app and selecting the “Your Privacy Choices” link:

• Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising
• Opt Out of the Sale of My Personal Information

If we decline to take action on one of your rights as a Connecticut resident, you can submit an appeal by going to our privacy request page.

Montana Privacy Rights

Montana residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Request My Personal Information” link:

• Request to Access My Personal Information

• Delete My Personal Information

• Correct My Personal Information

We may sell personal information to third parties or process your personal information for various purposes, including targeted advertising. These kinds of disclosures may be deemed selling under Montana law. You have the right to opt-out of the sale or processing of your Personal Information for targeted advertising as described below.

Montana residents can exercise the following rights by going to the footer of our website or the settings section of our app and selecting the “Your Privacy Choices” link:

• Opt Out of the Sale of My Personal Information

• Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising

If we decline to take action on one of your rights as a Montana resident, you can submit an appeal by going to our privacy request page.

Oregon Privacy Rights

Oregon residents should refer to our Oregon Privacy Notice for more information about privacy practices and their Oregon privacy rights.  

Texas Privacy Rights

Texas residents should refer to our Texas Privacy Notice for more information about privacy practices and their Texas privacy rights. 

Utah Privacy Rights

Utah residents should refer to our Utah Privacy Notice for more information about privacy practices and their Utah privacy rights.

Virginia Privacy Rights

Virginia residents can exercise the following rights by going to the footer of our website or settings section of our app and selecting the “Request My Personal Information” link:

1. Request to Access My Personal Information
2. Delete My Personal Information
3. Correct My Personal Information

Virginia residents can exercise the following rights by going to the footer of our website or the settings section of our app and selecting the “My Privacy Choices” link:

1. Opt Out of the Processing of My Personal Information for Purposes of Targeted Advertising

If we decline to take action on one of your rights as a Virginia resident, you can submit an appeal by going to our privacy request page.

Please check this Privacy Notice periodically for changes. We will provide additional notice of significant updates. We will post the date our Notice was last updated at the top of the Privacy Notice.

If you have questions regarding this Privacy Notice, or about how Walmart handles your personal information, please contact sparkcommunity@walmart.com.