Notice To California Residents

CALIFORNIA CONSUMER PRIVACY NOTICE

This California Consumer Privacy Notice (“Notice”) supplements the  U.S. Online Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Notice does not apply to  Aldi Inc. personnel.   Sections 2-5 of this Notice do not apply to job applicants.

This Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1.    Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Notice) the following categories of personal information about you:

• Identifiers: Identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers.
• Protected Classifications:    Characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, disability, and military and veteran status.
• Commercial Information:   Commercial information, including records of personal property, products or services purchased, obtained, or considered, payment information (as described in our Online Privacy Notice), other purchasing or consuming histories, tendencies, or preferences, information from communications that we exchange, including when you contact us with questions, feedback, complaints, or otherwise, research data that you provide when you agree to participate in our surveys or research activities, such as your survey responses.
• Audio/Visual Information:   Security camera footage from our stores, voice recordings of conversations when you call our call center with questions, feedback, complaints, or otherwise.
• Online Activity:  Internet and other electronic network activity information, information regarding your interaction with websites, applications or advertisements, device data such as the operating system type of the device.
• Geolocation Information:    Postal address, general location information (such as city, state or geographic area).
• Inferences:    Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, attitudes, abilities, and aptitudes.
• Other Information:   Information we may collect which we will use as described in our U.S. Online Privacy Notice or as otherwise disclosed at the time of collection.

We may use (and may have used during the 12-month period prior to the effective date of this Notice) your personal information for the purposes described in our  U.S. Online Privacy Notice  and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
• Debugging to identify and repair errors that impair existing intended functionality
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
• Managing career opportunities with ALDI.

2.    Sources of Personal Information

During the 12-month period prior to the effective date of this Notice, we may have obtained personal information about you from the following categories of sources:

• Directly from you
• Your devices
• Our affiliates
• Vendors who provide services on our behalf
• Our joint marketing partners
• Online advertising services and advertising networks
• Data analytics providers
• Operating systems and platforms
• Social networks
• Data brokers

3.    Sharing of Personal Information

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

We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information:

• Identifiers  

Category of Third Party:

• Affiliates  
• Vendors who perform services on our behalf
• [Payment processors]
• [Business partners]
• Joint marketing partners
• Data analytics providers
• Social networks
• Online advertising services and advertising networks

Category of Personal Information:  

• Protected Classifications

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf
• Business partners
• Joint marketing partners
• Data analytics providers
• Social networks
• Online advertising services and advertising networks

Category of Personal Information:

• Commercial Information

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf
• Payment processors
• Business partners
• Joint marketing partners
• Data analytics partners
• Social networks
• Online advertising services and advertising networks

Category of Personal Information:

• Audio/Visual Information

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf

Category of Personal Information:

• Online activity

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf
• Business partners
• Joint marketing partners
• Data analytics providers
• Social networks
• Online advertising services and advertising networks

Category of Personal Information:

• Geolocation information

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf
• Business partners
• Joint marketing partners
• Data analytics providers
• Social networks
• Online advertising services and advertising networks

Category of Personal Information:

• Inferences

Category of Third Party:  

• Affiliates
• Vendors who perform services on our behalf
• Data analytics providers
• Online advertising services and advertising networks
• Data brokers

Category of Personal Information:

• Other Information

Category of Third Party:

• Affiliates
• Vendors who perform services on our behalf
• Business partners
• Retail and trade partners
• Joint marketing partners
• Data analytics providers
• Social networks
• Online advertising services and advertising networks
• Data brokers

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Notice, we may have shared personal information about you with the following additional categories of third parties: Government entities.

4.    Sale of Personal Information

We do not share or sell your personal information to third parties in exchange for monetary consideration.   We may allow certain third parties (such as online advertising services or marketing analytics) to collect certain personal information (Identifiers, Online Activity, Inferences) for online advertising purposes and to provide third-party social network features and functionality on our sites and services.   You have the right to opt-out of this disclosure of your information, which may be considered a “sale” under California law.  

We do not have actual knowledge that we sell personal information of minors under 16 years of age.

5.    California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access:  You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion:  You have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale:  You have the right to opt-out of the sale of your personal information.

Shine the Light Request:  You also may 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.

How to Submit a Request: To submit a request, please complete the Data Subject Request Form (https://dm.cms.aldi.cx/is/content/prod1amer/Data_Subject_Access_Request_Form_CCPApdf)  and follow the instructions on the form for submission, or submit a request to https://new.aldi.us/about-aldi/contact-us  (https://new.aldi.us/about-aldi/contact-us) and attach the completed Data Subject Request Form, or call us at  833-602-2534.   To submit a Shine the Light request, please submit a request at  https://new.aldi.us/about-aldi/contact-us (https://new.aldi.us/about-aldi/contact-us). For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section above.

Verifying Requests:  To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.   If you request access to or deletion of your personal information, we may require you to provide any of the following information: your name, your email address and your phone number.   In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information:  If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.   To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.