Privacy Notice - Sam’s Member Access Platform

We recently updated our Privacy Notice

Updates include:

• Updated California Privacy Rights section

This Privacy Notice explains how Sam’s Member Access Platform collects, uses, and shares your personal information. (“Personal information” is information that identifies you or that can reasonably be linked to information that identifies you.) This Notice applies to the personal information we collect on advertisinghelp.samsclub.com and other Sam’s Member Access Platform related sites (“Site”) and does not cover other information collected and processed by the business on other Sam’s Club sites. Sam’s Member Access Platform recognizes that you care about how your information is used, and your privacy is important to us. This Privacy Notice explains the choices you can make about what information we share. Please read this Privacy Notice carefully.

Changes to this Privacy Notice

We ask that you read this Privacy Notice from time to time. Sam’s Member Access Platform may modify this Privacy Notice at any time in its sole discretion. If we make material changes to this Privacy Notice that increase our rights to use personal information that we have previously collected about you, we will notify you either through an email to the address you provided or by prominent posting on the Site and, where appropriate, we will obtain consent from you either through email or the Site.

What Information Do We Collect?

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

• Personal identifiers, such as name and address
• Device and online identifiers and related information, such as telephone number and email address
• Internet, application, and network activity, such as cookie IDs and browser visits
• Employment information, such as occupation, title, licenses and professional memberships
• Financial information, such as monthly campaign budget
• Individual preferences and characteristics, such as your advertising goals

How Do We Collect Information?

We collect information from you in a variety of ways. It may be:

• Provided directly by you or a member of your household
• Collected from a device associated with you or your household
• Collected from an external third-party source

Sam’s Member Access Platform collects personal information about you when you interact with the Site. The information we may collect includes:

• first and last name;
• email address;
• phone number;
• other information you provide us.

Information Collected From a Device Associated With You or Your Household

We may automatically collect personal information from devices that you use to interact with the Site, as well as from your interaction with emails that we send to you. The personal information we automatically collect may include your IP address, browser type, device type, the webpage you visited before coming to the Site, pages you visited on the Site, time spent on those pages, information you searched for on the Site, when and for how long you visited the Site, and similar information, which we collect through cookies, beacons, and other technologies. The information we automatically collect will be associated with any personal information that you have provided to us.

Information We Collect from Third-Party Sources

We may receive personal information about you from other sources to help us correct or supplement our records and help us improve our services to you, prevent or detect fraud, and for other business purposes.

Sam’s Member Access Platform may use the personal information it collects about you for a number of purposes, including:

• To create and maintain your account
• To fulfill requests and obligations related to our relationship
• To conduct marketing and personalization
• To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
• To update our operational and technical functionality
• To fulfill our legal function or obligations
• To protect the security and integrity of our websites, mobile services, and our business
• To help prevent fraud

If you decide at any time that you no longer wish to receive marketing and promotional materials from us, please follow the unsubscribe instructions provided in any of the communications you receive from us. You may also contact us at MAP-Privacy@wal-mart.com to make your request to unsubscribe from further marketing emails from the respective Site.

Sam’s Member Access Platform also may share your personal information with third-party service providers who perform services and functions on our behalf to support our interactions with you.

Sam’s Member Access Platform may share your personal information with other third parties, including law enforcement authorities, where we determine that doing so is appropriate to:

• enforce our Terms of Service;
• protect our property, services, and legal rights and the rights of others;
• provide maintenance services, database management, and similar site-related services;
• prevent physical harm to persons or the property of others;
• prevent fraud or other illegal activity against Sam’s Member Access Platform and others;
• support auditing, compliance, and corporate governance functions;
• comply with subpoenas, court orders, or similar legal processes, including to law enforcement agencies, regulators and courts;
• comply with any and all applicable laws.

Other than as described above, we will not share your personal information with third parties.
Aggregated, Non-Identifying Information: Sam’s Member Access Platform may share aggregated information that is not individually identifiable (or personal information) with third parties for any purpose including industry analysis and demographic analysis.

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

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 disclosed below:

Business Transfers

We reserve the right to disclose, sell, or transfer all information related to the Site, including personal information:

• to a subsequent owner, co-owner or operator of the Site; or
• in connection with a corporate merger, consolidation, or restructuring; the sale of substantially all of our stock and/or assets.

International Transfers

The Site to which this Privacy Notice applies is subject to U.S. law, unless otherwise stated in this Privacy Notice. The Site are directed to operations in the United States. Sam’s Member Access Platform does not offer services in Europe or the European Economic Area. By using the Site or providing us with your information, you are directly transferring your information to us in the United States. In addition, we may transfer the information that we collect through the Site to other countries where we do business. These countries may not have the same data protection laws as the country in which you reside. When we transfer personal information we collect about you to other countries, we will protect that information as described in this Privacy Notice or as otherwise required by law, even though a given country may not have the same privacy and data protection laws as the country in which you reside. You agree to and acknowledge our collection, transfer, and processing of your personal information in accordance with this Privacy Notice.

When you visit the Site, Sam’s Member Access Platform may place pieces of code, commonly referred to as "cookies," or similar technology on your devices. Sam’s Member Access Platform may begin collecting information about you or your activity on devices associated with you through cookies or similar technologies as soon as you visit the Site. By using the Site, you permit Sam’s Member Access Platform to collect and use your personal information from activity on devices associated with you in accordance with this Privacy Notice.

Sam’s Member Access Platform may use cookies for a number of purposes: First, we may use persistent cookies to collect and analyze information about your online activity to help us improve our services. Second, we may use session ID cookies to enable certain features of the Site to better understand how you interact with the Site, and to monitor aggregate use of the Site by Sam’s Member Access Platform users. Unlike persistent cookies, session cookies are deleted from your computer when you log off of the Site and close your browser.

We also may use "pixel tags," "web beacons," and other technologies on the Site to collect usage, demographic, and geographic location data, which allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. Some internet browsers (e.g. Internet Explorer, Safari, Chrome) offer their own opt outs for interest-based advertising. The ad networks and ad service providers we participate with may not recognize these opt outs.

Information about how to opt out of certain online interest-based advertising is available from the Digital Advertising Alliance at http://www.aboutads.info/choices/.

You can request that we review or modify your personal account information by contacting us. If you would like us to modify your account information, please contact us at MAP-Privacy@wal-mart.com. We will use commercially reasonable efforts to honor your request. We may retain a copy of your records as required by law or for legitimate business purposes.

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 Site is a general audience website not directed at children under the age of 13. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.

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. To exercise any of these privacy rights, email B2Bprivacy_2022@wal-mart.com. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

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

1. Provide you with access to a copy of and certain details regarding the personal information we have about you. 
2. Delete your personal information. 
3. Stop selling your personal information or sharing your personal information for cross-context behavioral advertising. 
4. Correct your inaccurate personal information. 
5. Limit the use or disclosure of your sensitive personal information (SPI). 
6. Appeal the result of a data request. 

1. 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 twelve-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 third parties we disclosed it to. 

2. 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 service providers 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.  

3. Stop Selling or Sharing My Personal Information: You have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising and can request that we stop by emailing us or by using the Global Privacy Control as described below.    Note: Sam’s Member Access Platform does not sell personal information.

4. 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.   

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.

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

What If You Can’t Verify My Identity? If we can’t 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’d 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 Received in 2022 To view metrics about our privacy requests, 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 so.

Please contact us if you have any questions or comments about our privacy practices or this Notice. You can reach us online at MAP-Privacy@wal-mart.com or you can write to us at:

Sam’s Club Corporate Privacy Office,
MS #0160
702 SW 8th Street Bentonville,
AR 72716-0160