Walmart Customer Spark Community Privacy Notice

Last Updated: November 21, 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, government-issued identifiers (e.g., national identification numbers, driver’s license numbers), , and signatures.
• Device and Online Identifiers, such as account login information, Mac 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 asfor example keystroke patterns (these tellwhich help us determine if it is’s you or a bot 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.

Provided Directly by You or a Member of Your Household

• Directly from you, for example, Wwhen you submit information through the Spark Community Sites or your Spark Account, or complete one of our surveys or other activities we obtain personal information directly from you. . We also collect personal 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.

Collected Through Automated Means

• 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.

Obtained from Other Companies within Our Corporate Family

• We may obtain your personal information from another company within our corporate family, such as Sam's Club.

Obtained from External Third-Party Sources

• We may obtain personal information about you from other sources 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. We also may obtain device and browsing information, from third parties for marketing purposes.

Collected from Another Solution or Asset

• For example, when you speak to customer service, we collect your personal information using call recording technology in accordance with applicable law.

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 use information that may be considered Sensitive Personal Information under state laws for each of the purposes described above and to make inferences about customers, which we may use to promote certain products or services. Where required by law, Walmart only processes this Sensitive Personal Information with your consent.

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.

We may share all categories of personal information described above with certain categories of third parties, as described below.

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.

Vendors for Business Operations:

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.

For Business Purposes and as Otherwise Permitted by Law:

We disclose personal information for the business purposes described above in “How We Use Your Personal 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.

Within Our Corporate Family of Companies:

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.

Whether you are using our websites or mobile services or visiting our stores, we use reasonable information security measures, including physical, administrative, and technical safeguards. Learn more about measures you can take to help to protect the security of 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.

Many states have enacted comprehensive data privacy legislation. Depending on the state in which you reside, you may exercise certain privacy rights by going to the footer of our website or settings section of our app and selecting the “Request My Personal Information” link. Based on your state, you may be able to request to:

• Access your personal information. You may have the right to obtain your personal data in a portable format that allows you to transmit the personal data to another entity. If your state provides for you to receive additional information regarding certain disclosures we make to third parties, we will provide this detail in our response to your access request.

• Correct your personal information.

• Delete your personal information. A request to delete personal information is subject to certain exceptions, defined by law.

Residents of applicable states may opt out of certain treatment of their personal information 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. 
• 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.
• Opt Out of the Sale of My Personal Information.
• You may also 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.
  

Additional state privacy notices and disclosures:

• California Privacy Notice
• Colorado Privacy Notice

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

We will not discriminate against you for exercising your rights. We will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

We may disclose 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 certain state privacy laws. You have the right to opt-out of the sale or processing of your Personal Information for targeted advertising as described in the State Privacy Rights section.

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.

If we cannot verify your identity, we will notify you, and your request(s) to access, request, or delete your personal information may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.

In some states, you can have authorized agents exercise some of your rights for you. If you would like an authorized agent to exercise those rights, they may use the same links described above to submit requests. We require documentation demonstrating your agent’s authority to submit requests on your behalf. For example, a valid power of attorney or other documentation, including a letter, signed by you (the state resident) authorizing the agent to submit your requests. You can download a sample letter from the request form. Documentation may be uploaded at the time you submit your request on our website or provided to us up to 10 business days after. If you submit your request by calling, you can email your forms to consumerprivacy@wal-mart.com.

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.