Walmart Claims Services Privacy Notice

• Updated Notice for consistency with other notices in our corporate family
• Updated the “What Personal Information Do We Collect?” and “State Privacy Rights” sections

Walmart Claims Services, Inc. (d.b.a. "Claims Management, Inc." in some locations) is the casualty claims administrator for Walmart Inc., its subsidiaries and affiliates (collectively, "Walmart") and Walmart's insurance carriers. We recognize the importance of information privacy. We strive to manage personal information in accordance with our core value of respect for the individual. This Notice describes:

• Why we collect your personal information.
• How your information is used and protected.
• When and with whom we disclose your information.

If you have any questions about this Privacy Notice, please contact us as described in the “Contact Us” section below.

We collect personal information from you and others to appropriately administer Workers' Compensation and liability claims involving Walmart. We also must adhere to various legal requirements concerning claims administration and reporting—including reporting of Workers' Compensation claim data, Medicare reporting requirements, Child Support Lien Network data matching, claim fraud detection and prevention, and applicable HIPAA requirements.

“Personal information” is information that identifies you or reasonably can be linked to information that identifies you. Some laws define “personal information” differently, and we use those definitions when they are applicable.

We may collect or receive the categories of personal information listed below. Not all categories of personal information will 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 and driver’s license numbers), and signature.
• Device and Online Identifiers, such as account login information, MAC address, IP address, and cookie IDs.
• Internet and Other Network Activity, such as information about your browsing or search activity as well as your interactions with our websites, mobile applications, emails, or advertisements.
• Commercial Information, such as purchase and transaction history information (such as products or services you have purchased, rented or returned).
• 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 and debit card numbers, claims information, and financial account numbers.
• 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. 
• Health and Health Insurance Information, such as prescription numbers and health insurance identification numbers.
• Sensory Information, such as audio, visual, 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, such as inferences related to shopping patterns and behaviors.

We may obtain and combine personal information from different sources, types of technology, and devices. This information may be collected from various places, including in our stores, online, and from third parties.

Provided Directly by You or a Member of Your Household

You share information with us in various ways, such as when you visit our stores, engage with associates in Walmart Claims Services, or use our websites or applications.

When you engage in these activities, you may share different types of personal information with us, such as your name, email address, physical or postal address, phone number, date of birth, and location information.

Collected Through Automated Means

We may collect your personal information from technology we use in our stores and other facilities, such as our facility cameras. We operate cameras in stores and other facilities for security and operational purposes, for example, to help us improve the design of our stores to better serve our customers.

Some of this information may be linked to you personally. This information helps us effectively partner with you and conduct our business.

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

Obtained From External Third-Party Sources

Examples of third-party sources are entities that help prevent or detect fraud and entities that provide documentation concerning your claim including, but not limited to, records from healthcare providers.

Walmart Claims Services, Inc. uses personal information to provide you with services and to operate and improve our business.

For example, we use it for:

• Fulfilling our legal function or obligations, such as administering claims.
• Helping to ensure security and integrity and prevent fraud.
• Conducting business analysis, such as analytics, projections, and identifying areas for operational improvement, such as maintaining public safety
• Medicare reporting
• Workers' Compensation data reporting to regulatory agencies
• Fraud detection and reporting
• Data matching with the Child Support Lien Network (CSLN)
• Reporting to Walmart and its insurance carriers
• Claim processing
• We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

We may combine and associate personal information collected or inferred about you from multiple online and in-store sources (including other companies and services in the Walmart corporate family) to better achieve these purposes.

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

All of the categories of personal information that we collect have been shared with other companies, including those within our Walmart Inc. corporate family, for a business purpose. When we disclose, the information will be used in ways that are consistent with this Notice. We may disclose information about you with insurance carriers and vendors for business operations who perform services on our behalf. These vendors for business operations are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. In addition, we may disclose information about you to disability or benefit plans sponsored by Walmart and the administrators of and vendors for business operations for such plans for purposes of administering disability benefits for which you may be entitled.

Legal Requirements and Protection of Our Company and Others

We may share your personal information in certain other circumstances. These include situations when we believe in good faith that the law requires it or that the disclosure is necessary to protect the safety, property, or other rights of our associates, or any other person. Examples include:

• Protecting the health or safety of customers and associates;
• Addressing crimes committed on Walmart property;
• Identifying and addressing fraud or financial risk;
• Providing personal information from cameras to law enforcement at their written request;
• Responding to a search warrant or other valid legal inquiry; and
• Responding to an investigative body in the case of a breach of an agreement or violation of law.

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

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

Aggregate Information

We may disclose aggregate and statistical data that does not identify you personally. We may do this for actuarial analysis, research, and benchmarking purposes.

Business Transfers

If we plan to merge, sell, or reorganize our business, we may disclose your personal information, along with personal information of other Walmart customers as part of the business arrangement. (This may also include transfers of personal information made as a part of insolvency or bankruptcy proceedings.) We will use reasonable measures to help ensure your information is handled in accordance with this Privacy Notice.

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.

We use reasonable information security measures, including physical, administrative, and technical safeguards. Learn more about measures you can take to help protect the security of your personal information.

California Consumer Privacy Act

• If you are a current or former Walmart associate and reside in California, see the Walmart Associate Information Privacy Notice for information about your California privacy rights.
• If you are a Walmart customer and reside in California, see the Walmart California Consumer Privacy Act Notice.

Additional Customer State Privacy Rights

Many states have enacted comprehensive data privacy legislation (learn more about specific state privacy rights by reviewing our FAQs). 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 “Your Privacy Choices” 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.
• Opt Out of the Processing of Your Personal Information for Purposes of Targeted Advertising. This right is not offered because Walmart Claims Services does not process your personal information for purposes of targeted advertising.
• Opt Out of the Sale or Sharing of Your Personal Information.

Additional state privacy notices and disclosures:

• Nevada Consumer Health Data Privacy Notice
• Washington Consumer Health Data Privacy Notice
• See Appendix 1 in the Walmart Customer Privacy Notice (Online and In-Store) for additional details regarding what pieces of personal information are sold or shared and whether those pieces of personal information are used for targeted advertising.

If we decline to take action on one of your rights, depending on your residency, you may be able to submit an appeal by going to our Privacy Request page, entering your Privacy Request ID and Zip Code, and selecting the appeal option.

We will not discriminate or 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, 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 Cannot 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 will 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?

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 globalprivacy@wal-mart.com with the subject line “Walmart Claims Services Data Subject.”

We will provide notice of significant updates, but please check our Privacy Notice periodically for changes. We will always post the date our Privacy Notice was last updated at the top of the Notice.

Please feel free to contact us with any questions or comments about this Notice or about how your information is handled. You can contact us via the phone number or address below:

Walmart Claims Services, Inc.
Attn: Compliance Office
PO Box 14731
Lexington, KY 40512-4731
Tel: (800) 527-0566