Oregon Consumer Privacy Act Notice

Updated: June 19, 2024

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Oregon Consumer Privacy Act Notice Summary

This Oregon Consumer Privacy Act Notice supplements the information in the Sam’s Club Privacy Notice and applies solely to Oregon consumers who interact with Walmart, inc. in an individual or household capacity at our Sam’s Club retail stores and our websites, mobile apps, and services where this Privacy Notice is posted. This Oregon Notice uses certain terms that have the meaning given to them in the Oregon Consumer Privacy Act (the “OCPA”).

Categories of Personal Information Collected

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this Oregon Notice) the categories of personal information listed below. Not all categories will be collected or received for every individual. For more information on the categories of personal data we collect, please see the “What Personal Information Do We Collect?” section of the Sam’s Club Privacy Notice.

Identifiers: Personal identifiers, such as name, telephone number, physical address, email address, national identification numbers, driver’s license numbers, and signatures.
Device Information and Online Activity: Device and online identifiers, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information.
Commercial Information: Purchase and transaction history information (such as products or services you have purchased, rented, or returned), health and safety-related information, product testimonials, travel and vacation information, and competition entries.
Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where Sam’s Club is a party to the exchange.
Demographic Information: Demographic information, such as age (including information about children under the age of 13 with respect to certain purchases and services (e.g., tobacco purchases)), 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: Financial information, such as credit or debit card numbers, financial account numbers, and claims information
Biometric Information: Biometric information, such as voice prints, imagery of the iris or retina, face geometry, and palm prints or fingerprints.
Geolocation: Location information, such as geolocation information
Sensory Information: Audio, visual information, and other sensory information such as photographs and audio and video recordings
Background Information: Background and criminal information, such as background checks and criminal convictions
Inferences: Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors, intelligence, and aptitudes
Sensitive Personal Information: Data that reveals a member’s racial or ethnic background, national origin, religious beliefs; mental or physical condition or diagnosis, sexual orientation, status as transgender or nonbinary, status as a victim of crime or citizenship or immigration status; is a child’s personal data; accurately identifies within a radius of 1,750 feet a member’s present or past location, or the present or past location of a device that links or is linkable to a member by means of technology that includes, but is not limited to, a global positioning system that provides latitude and longitude coordinates; or is genetic or biometric data.

Collection, Use and Sharing of Personal Data

We may collect, use and share personal data as described in the chart below:

Category of Personal Data	Processing Purpose(s) (see full list below)	Used for Targeted Advertising?	Sold or Shared
Identifiers	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that provide services to Sam’s Club but also uses for their own purposes Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Device and Online Identifiers	Conducting business analysis Conducting research and development Debugging to identify and repair errors Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.)
Internet and Other Network Activity Information	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services To conduct auditing and monitoring of transactions and engagement	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.)
Commercial Information	Conducting research and development Fulfilling our legal functions or obligations Performing and providing advertising and marketing services Performing services To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	Service providers that receive data to provide services to a Sam’s Club entity (e.g., analytics providers, advertising networks, cloud storage providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Communications	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Demographic Information (certain of which may include sensitive data as defined by the OCPA)	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Financial Information	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Biometric Information	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Geolocation	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Sensory Information	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing services Performing and providing advertising and marketing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Background Information	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	No	Service providers (such as advertising networks, marketplace sellers, analytics providers, etc.) Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity
Inferences	Conducting business analysis Conducting research and development Fulfilling our legal functions or obligations Helping to ensure security and integrity and prevent fraud Performing and providing advertising and marketing services Performing services Recruiting and employment purposes To conduct auditing and monitoring of transactions and engagement Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	Business partners that receive data for their own independent use and not to provide services to a Sam’s Club entity Service providers that receive data to provide services to a Sam’s Club entity (e.g., analytics providers, cloud storage providers, etc.)

Processing Purposes:

Performing services, including maintaining or servicing accounts, providing member service, processing or fulfilling orders and transactions, verifying member information, processing payments, providing financing, providing analytics services, providing storage or providing similar services.
Performing and providing advertising and marketing services, including targeted advertising.
To conduct auditing and monitoring of transactions and engagement, including auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
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.
Conducting research and development, including undertaking internal research for technological development and demonstration.
Fulfilling our legal functions or obligations.
Recruiting and employment purposes.

We use sensitive personal information for each of the purposes described above and to make inferences about members, which we may use to promote certain products or services. Sam’s Club does not process sensitive personal information without 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.

Your Oregon Privacy Rights

If you are an Oregon 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

If you are an Oregon resident, you can make certain requests regarding your personal information, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

Oregon 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 the categories of my personal Information and a list of third parties to which the controller has disclosed personal information

Delete My Personal Information
Correct My Personal Information

Oregon 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

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 Oregon Consumer Privacy Notice, please see the “Contact Us” section of the Sam’s Club Privacy Notice.

View the full Sam’s Club Privacy Notice

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