Sam’s Club Applicant Privacy Notice

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We recently updated our Privacy Notice.

Updates include:

• Updated Notice for consistency with other notices in our corporate family. pdated directions to submit a privacy request.
• Added California specific information about our potential use of Automated Decision-Making Technologies (ADMT).
• Added details to inform applicants on how they can confirm we are honoring certain requests related to their personal information.   

Sam’s Club Applicant Privacy Notice Summary

This Notice applies to personal information collected by Walmart Inc. and its family of companies, during the recruitment and hiring process. Personal information is information that identifies you or reasonably can be linked to information that identifies you. The Notice applies on the websites and mobile services (i.e., mobile apps) for the Walmart Inc. family of companies where it is posted. If you are offered and accept a position with the company, this information will become part of your personnel file and its use will be governed according to our internal associate policies and procedures, and the terms of this Notice will no longer apply.

This Notice describes how we handle your personal information, the reasons we do so, and the rights you have regarding your information if you are a California resident.

We may collect or receive (and may have collected or received during the 12-month period prior to the last Updated date of this Notice) the categories of personal information listed below. Not all categories will be collected or received for every individual.

• Basic Personal Identifiers, such as name telephone number, physical address, email address, national identification numbers, driver’s license numbers, and signatures.  
• Device Information 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, email, or advertisements (for example keystroke patterns which help us determine if it is you or a bot who is interacting with us.)
• Communications, such as content of emails, text messages, interactions with our bot (AI assistant chatbots) 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 bank account and routing numbers.  
• Health and Health Insurance Information, such as prescription numbers and health insurance identification numbers.
• 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.
• 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 information related to any assessment you may take as part of the interview screening process upon hire or during your tenure for promotion opportunities

We may obtain and combine personal information from different sources, as provided below:

Provided Directly by You or a Member of Your Household

Walmart collects personal information directly from you as part of your employment. For example, information that you give us when you fill out an employment application or enroll in benefits programs, or it can be information that you give us when you interact with services such as OneWalmart or fill out your Workplace profile. We may also collect photographs or audio/visual recordings on Walmart property, or during events and activities relating to your employment with Walmart.

Collected Through Automated Means

We collect personal information from you automatically when you use certain websites Walmart operates, like OneWalmart.com. This information may not identify you directly. For example, we may collect IP address, browser, or operating system information, and referring website. Our websites may use cookies, which are small text files stored on your computer that help us to maintain your session or provide other interactive features. You can turn off cookies through your browser. However, turning off cookies may limit some functionality of the site, such as changing the layout of your personalized content. The site may also use web beacons, which allow us to know if you visited a certain page. 

Additionally, we collect information from you when you use company equipment, systems, and applications. For more information and more detailed guidance on the use of Walmart systems, access the Policies page on OneWalmart.

We may collect your personal information from technology we use in our stores and corporate facilities, such as our facility cameras. We operate cameras on company property for security and operational purposes, for example, to help us improve the design of our stores to better serve our customers and associates. Additionally, we collect telematics data in corporate vehicles. Telematics data involves the use of installed hardware to collect and transmit data about a vehicle which may include the vehicle’s location, use, and maintenance needs.

Automated License Plate Readers (ALPR) may also be in use on our properties, where permitted by law. Personal information is collected from ALPRs to help ensure security, prevent theft and fraud, assist with parking enforcement, and to help maintain the safety of individuals and properties. See our ALPR Privacy Notice for additional information.

Obtained from Other Companies within Our Corporate Family 

We may collect your personal information from another organization within our corporate family of companies, such as with Walmart.

Information Collected from External Third-Party Sources

We receive information about you from third party sources to assist us with employment-related activities, and other legal matters. For example, we may collect information from employment background agencies for the purpose of conducting a background check. Examples of the types of information contained in a background check may include your criminal, employment, and educational history, as well as information about your character, general reputation, personal characteristics, mode of living, credit standing, and more. Before requesting a background check, Walmart will obtain your informed and specific consent by asking you to sign a Fair Credit Reporting Act Authorization and Disclosure Form. More information, including market-specific details, can be found in the "Additional Resources" section below.

We may use your personal information for various purposes, including:

• Fulfilling requests and obligations related to recruiting and employment purposes.
• Performing services, including creating and maintaining your account.
• Conducting business analysis, such as analytics, projections, identifying areas for operational improvement, including training our AI.
• Conducting auditing and monitoring of engagement. 
• Protecting, verifying and maintaining the safety, quality, security and integrity of our systems, processes, assets and other properties, and our business.
• Fulfilling our legal functions or obligations. 
• Updating operational and technical functionality. 
• Undertaking activities to verify or maintain the quality or safety of our services or devices to improve, upgrade, or enhance them. 
• Helping to protect against and prevent fraud and other illegal activity, claims, and other liabilities.

Some examples of the recruiting and employment purposes described above are to:

• Process your application.
• Evaluate you for current and future employment opportunities, based on your skills, qualifications, and interests.
• Communicate with you and inform you of employment opportunities.
• Fulfill our legal obligations.
• Conduct continued evaluation of background checks.
• Improve our recruitment and hiring process, including performing analysis of our applicant pool.
• Carry out internal record keeping.
• Carry out equal opportunities monitoring.
• Conduct investigations related to company policies.

We also may use the information in other ways for which we provide specific notice at the time of collection.

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.

California Automated Decision-Making Technologies Pre-Use Notice: We may use Automated Decision-Making Technologies to help us make decisions that could have a significant impact on you. If we implement those technologies, we will provide you with notice and you will be able to exercise any rights available to you as described in the “What Are Your California Privacy Rights?” section and accessible through “Your Privacy Choices”. 

Within Our Corporate Family of Companies

All of the categories of personal information that we collect have been shared with other companies, including those within our corporate family, for a business purpose. We will only share your personal information within our corporate family of companies as permitted by law, except in the following circumstances:

Vendors for Business Operations

From time to time, we may utilize vendors for business operations to administer certain programs, benefits, or administrative functions on behalf of Walmart related to our recruitment and hiring processes. We require our vendors for business operations to keep confidential the information that we obtain from you as an applicant. We do not allow our vendors for business operations to use or share your information for any purpose other than providing services on our behalf, without your affirmative consent.

Sharing for Legal Requirements and Protection of Our Companies and Others

We may share your personal information in certain other circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or our rights or the rights of our customers, our applicants or associates, or other persons. Examples include:

• Protecting the health or safety of individuals.
• Addressing crimes committed on Walmart property.
• Identifying and addressing fraud or financial risk.
• Responding to a request form from law enforcement, search warrant, subpoena, or other valid legal inquiry.
• Responding to a court or other investigative body in the case of an alleged breach of an agreement or violation of law. 
• Assist with fraud prevention and potential criminal activity.

Business Transfers

In the event that all or a part of our business is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), personal information about you could be shared with the successor business. We will use reasonable measures to help ensure that any successor treats your information in accordance with this Notice.

During the 12-month period prior to the last Updated date of this Notice, we may have disclosed your personal information with certain categories of third parties as described in the sections below.

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

We may disclose your personal information with 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 Walmart policy. We dispose of the information we collect in accordance with Walmart’s retention policies and procedures.

Biometric Retention Schedule 
Walmart will permanently destroy your biometric identifiers and biometric information when the first of the following occurs: (i) the initial purpose for collecting or obtaining such biometric data has been satisfied; (ii) within three years of your last interaction with us; or (iii) as otherwise required by applicable law.

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.

Walmart does not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age. For more information about treatment of children’s personal information, see the Sam's Club Privacy Notice.

Cameras         

To ensure the safety and security of our applicants, customers, associates, and assets, closed circuit television and cameras are used throughout Walmart facilities and other property (including vehicles). These cameras are used for purposes such as safety and security, asset protection, operations improvement, and deterrence and investigation of misconduct. Cameras will only be used in areas where an individual has an expectation that the individual could be recorded.

Equipment and Systems

We have a reasonable interest in ensuring that company equipment and systems, as well as data, are protected and used properly. Accordingly, to the extent allowed by applicable law, we monitor or record any and all use of company equipment and systems, including use for personal purposes.

For more information, including market-specific policies, see the "Additional Resources" section below.

Your Access

When you create a profile through our hiring website or service, you have the ability at any time to access and update the profile information you have given us. Please note once you have submitted an application for a specific job opening, that particular application cannot be edited.

If you are a California 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. We do not offer the option for you to request we stop selling your personal information or sharing it for cross-context behavioral advertising because we do not conduct such selling or sharing of our applicants’ personal information.

As stated in more detail below, you can request that we:

• Provide you with access to a copy of and certain details regarding the personal information we have about you.
• Provide you with access to Automated Decision-Making Technologies, when applicable.
• Opt-out of Automated Decision Making-Technologies, when applicable.
• Delete your personal information.
• Correct your inaccurate personal information.
• Limit the use or disclosure of your sensitive personal information (SPI).

To exercise any of these privacy rights, click “Your Privacy Choices”, or call 1-800-Walmart (1-800-925-6278), press one, and say, "Privacy".

Request to Access My Personal Information: You have the right to request access to the personal information we may have collected about you. 

Requests to access your personal information may be submitted up to two times in a rolling 12-month period. In response, we will return to you the following categories of information, to the extent required by law:

• The categories of personal information we have collected about you.
• The categories of sources from which we collect your personal information.
• The business or commercial purpose for collecting, selling, or sharing your personal information.
• The categories of third parties to whom we disclose personal information.
• The specific pieces of personal information we have collected about you.
• A list of categories of personal information that we have sold or shared for cross-context behavioral advertising, along with the categories of third parties we sold it to or shared it with for cross-context behavioral advertising.
• A list of categories of personal information that we have disclosed for a business purpose, along with the categories of vendors for business operations or contractors we disclosed it to.

Delete My Personal Information: You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct our vendors for business operations to do the same. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of in-store functions that require your personal information. 

Correct My Personal Information: You have the right to ask that we correct the personal information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law.

Limit the Use and Disclosure of SPI: You have the right to ask that we limit our use and disclosure of your SPI to certain purposes permitted by law. If we have processed your request to limit the use and disclosure of your SPI, you can confirm your preference on the same page on which you made the request by selecting “Your Privacy Choices”.

Opt-Out of Automated Decision Making 

You have the right to ask that we not make significant decisions about you using Automated Decision-Making Technologies. When we use these technologies, you can opt out at any time by selecting “Your Privacy Choices” and following the prompts provided.

We will not retaliate 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.

How Do We Verify Your Identity to Complete Your Access, Correction and Deletion Requests:

If you request access to your personal information, including significant decisions we may have made about you using Automated Decision-Making Technologies,, 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.

What If You Can’t Verify My Identity?
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.

How Do I Submit a Request Using an Authorized Agent?
If you would like an authorized agent to exercise your rights for you, 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 California 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.

Number of Requests Fulfilled Last Year
To view metrics about how many requests we received last year, please click How Many California Consumer Privacy Act Requests Did We Fulfill Last Year?

Shine the Light

California residents also have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties. To exercise this right, contact us at the address below.

Notice of Financial Incentive
If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do sow.

To contact our Customer Service Team about this Privacy Notice or about how we handle your personal information, visit our Store & Corporate Feedback page and select “Company Feedback and Questions.”

Alternatively, write to us at:  

Walmart Corporate Privacy 
702 SW 8th Street , MS #0160 
Bentonville, AR 72716-0160

 
You may discuss questions or concerns about this notice with your management team or your HR business partner. Additionally, you may contact the benefits department, payroll department, or any other group that maintains information about you through this process. Up to date phone numbers are maintained on OneWalmart. If you have a concern you may report it to Global Ethics through www.walmartethics.com, ethics@wal-mart.com, or 1-800-WM-ETHIC.

For current associates, please access the Policies page on OneWalmart for additional information.

This Notice does not create an express or implied contract of employment or any other contractual commitment. Walmart may modify this Notice at its sole discretion without notice, at any time, consistent with applicable law. Employment with Walmart is on an at-will basis, which means that either Walmart or the associate is free to terminate the employment relationship at any time for any or no reason, consistent with applicable law.