LIDL PRIVACY POLICY. Effective Date: June 11, 2015

Transcription

1 LIDL PRIVACY POLICY Effective Date: June 11, 2015 Thank you for visiting Lidl US, LLC's (3500 S. Clark Street, Arlington, VA 22202) website (collectively, "Lidl," "we," or "us"). We are committed to providing you with a comprehensive online service and we respect your privacy. This Privacy Policy explains our policies and practices regarding personally identifiable information we collect about you through our website, online features and services that link to this Privacy Policy (collectively, "website"). This Privacy Policy does not apply to information collected by us offline or through any other means, or by any third party (including our affiliates and subsidiaries) that do not link to this Privacy Policy. Personal Information We Collect About You We may collect the following categories of personally identifiable information ("Personal Information") you provide to us: Name Job Title Company Name Business Address Business Phone Number Business Address Mobile Phone Number We may also automatically collect the following categories of information from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our website ("Device Information"): Referring website IP Address Device Identifier Time and date of website access User agent HTTP code Bytes served Browser and operating system Cookies Clear Gifs Log Files We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to comply with applicable law and internal company policies. Also, under some laws, certain types of Device Information described above may be considered personally identifiable information, and in such cases we will treat it as Personal Information.

2 How We Use Your Personal Information We may use Personal Information collected about you in order to: Provide you with the services offered on our website; Respond to or follow-up on your comments, inquiries or other requests; Improve the quality of our website and tailor it to your preferences; Communicate with you about special offers and other marketing communications We also use your Personal Information for compliance with our company policies and procedures, for accounting and financial purposes, and otherwise consented to by you and as required or permitted by law. If you do not provide us with information as described above, we may not be able to fulfill the applicable purpose of collection, such as to respond to your inquiries or provide our website to you. Please note processing your Personal Information for marketing purposes is not essential for maintaining the relationship we have with you. As detailed below, you control the choice of receiving marketing information from us, and your decision to not receive marketing information from us will not affect your ability to receive any other services you may request from us. How We Share Your Personal Information We may share your Personal Information with our affiliates, subsidiaries, business partners, third party service providers and authorities in the following circumstances: Lidl Affiliates, Subsidiaries and Business Partners. We may share your Personal Information with our affiliates, subsidiaries and business partners in the US and worldwide. By visiting or using our website, you consent to this transfer of your Personal Information throughout the Lidl network of entities and our business partners. Service Providers. We may share your Personal Information with third parties who perform functions on our behalf (e.g., hosting or operating our website, sending marketing communications, processing job applications, and data analysis. We do not authorize these third parties to use your Personal Information for purposes other than for which it has been provided, and do not authorize these third parties to disclose your Personal Information to unauthorized parties. We require these third parties to maintain appropriate security to protect your Personal Information from unauthorized access or processing. As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, government agencies and other third parties, where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of Lidl or others, or to respond to emergencies. Business Transfers. We may transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

3 We may share your Personal Information with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. We do not share, sell, rent or trade your Personal Information to our affiliates, subsidiaries, service providers or business partners for their own direct marketing purposes, unless we have explicitly given you the option to opt-in or opt-out of such disclosures. Cookies and Similar Technologies We may use or recognize the following "cookies" and similar technologies to help provide you a better, more personalized user experience: Cookies. Cookies are small pieces of information that a website transfers to your computer. We use both session ID cookies (expire when you close the browser) and persistent cookies (persist even after you close the browser). We use cookies to help our website run more smoothly and tailor content for you. Most web browsers have options that allow you to control whether or not to accept cookies and give you the option to delete all cookies. However, please note that disabling cookies in your browser may prevent access to some parts of our website. Do Not Track Signals: Our website is not currently configured to respond to a browser s Do Not Track signals. Device IDs. We may collect and store a unique device ID associated with your particular device ("Device ID") to track the number of unique visitors using our website and to enable you to interact with and use our website. We link your Device ID with the technical information accessed through your use of our website for administrative purposes. Clear Gifs (Web Beacons/Web Bugs). We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which helps us to better manage content on our website by informing us what content is viewed or clicked on. Clear gifs are tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, which are stored on a visitor's computer, clear gifs are embedded invisibly on web pages and s and are about the size of a period. We do not tie Device Information gathered by clear gifs to your Personal Information. Log Files. We also gather certain Device Information automatically and store it in log files. For instance, when you visit our website, our web server will automatically recognize some Device Information, including but not limited to, the date and time you visited our website, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Firefox, Internet Explorer), the type of operating system you are using (e.g., Windows or Mac OS), and the domain name and address of your internet service provider (e.g., AT&T, Verizon, AOL). Online Behavioral Advertising We may place or recognize cookies and similar technologies on your browser or device when you visit our website for purposes of serving you targeted advertising (a.k.a. "online behavioral advertising"). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our website and other third-party websites, in order to serve customized advertisements to you as you browse the Internet. As noted

4 above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following self-regulatory programs for online behavioral advertising, with corresponding user opt-outs: Networking Advertising Initiative - ( Digital Advertising Alliance - ( Digital Advertising Alliance Canada - ( DAA App Choices Mobile App - For mobile devices (e.g., smartphone, tablets), you may consider downloading the DAA AppChoices Mobile App to manage such technology. Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests. Choices If you no longer wish to receive marketing communications from us, you may opt-out of receiving marketing-related s by using the unsubscribe method provided in our communications. If you are having difficulty unsubscribing from our marketing communications, please contact us as detailed under the "Contact Us" heading below. We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain Personal Information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In addition, please note that even if you opt-out of receiving marketing communications, we may need to send you service-related communications and may need to keep Personal Information we have collected about you for record-keeping, research and other purposes. Cross-Border Transfers of Data Some of the parties identified above may be located in countries that do not provide an equivalent level of protection as your home country. 1 Where required, we have taken appropriate measures to allow and secure the transfer of Personal Information about you to these recipients for the purposes described above and in order to comply with local data privacy laws. By using our website, you consent to the transfer of your Personal Information to such countries. Data Security We have appropriate technical, physical and administrative security measures in place to protect your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our website. Any transmission of Personal Information is at your own risk.

5 Access and Correction Rights To the extent required by and in accordance with applicable law, you have the right to be informed of whether we are processing Personal Information about you, and to access, correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your Personal Information. For such inquiries, please contact us as detailed under the "Contact Us" heading below. We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain Personal Information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. Links to Other Websites Our website may contain links to third party websites and online services, where you will be directed to that third party's website or online service. This Privacy Policy only applies to Lidl's website. The fact that we provide a link to a website or online services is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security practices. The operators of these third party websites may collect Personal Information from you which will be used by them in accordance with their own privacy notices. Lidl is not liable for the collection and processing of information on these websites, and we encourage you to read the privacy notices of any such third party websites and online services. Children Under the Age of 13 Our website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the website. We do not knowingly collect personally identifiable information from children under 13. If you are under 13, do not use or provide any information on this website or on or through any of its features or provide any information about yourself to us, including your name, address, telephone number or address. If we learn we have collected or received personally identifiable information from a child under 13 without verification of parental consent, we will delete that information to the best of our ability. If you believe we might have any personally identifiable information from or about a child under 13, please contact us as detailed under the "Contact Us" heading below. Changes to Our Privacy Policy Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our information practices, by prominently posting notice of any updates on our website. If we make any changes to this Privacy Policy that materially impact previously collected Personal Information about you, we will, to the extent we have your address, notify you by . You are responsible for ensuring we have an up-to-date active and deliverable e- mail address for you, and for periodically visiting our Website and this Privacy Policy for any changes. Contact Us

6 Please contact us with any questions about your Personal Information by ing us at or: Lidl US, LLC Attn: Legal / GRC 3500 S. Clark Street, Arlington, VA 22202