Grocery Outlet Bargain Market Privacy Policy

Last modified: July 2, 2014

Introduction

Grocery Outlet Inc. and its affiliated or subsidiary companies (collectively “Grocery Outlet”) understand that you care about how we collect, use, and share information.  This Privacy Policy applies to all information we collect when you apply to our Aspiring Operator in Training Program (AOT Program) and thereafter if you are accepted into AOT Program and interact with us through online portals or applications.  For example, you may provide information to us through websites (such as ownagroceryoutlet.com), applications (such as Cornerstone, OttoLearn, Zoom, Salesforce), or communicate with us by phone, email, and other similar ways we communicate with you (collectively our “Communication Channels”). This Privacy Policy explains:

  • The types of information we collect about you.
  • How we use and protect that information.
  • The types of information we may share with others and under what circumstances.
  • The choices you have regarding our collection, use, and sharing practices.

We also include specific disclosures for residents of California.

This privacy notice does not form part of any contract to accept you into the AOT Program, to hire you as an employee, or to contract with you to provide services. We may update this notice at any time, but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

Information We Collect

Information you give us: Some of the Communication Channels may include features that permit you to enter information about you or may request information directly from you. We collect and store any information you enter on our Communication Channels or provide to us in writing. This includes:

  • Financial qualifications, professional history, references, citizenship, information provided via assessment tools, and personal information (such as your name, address, phone number, and email) throughout the AOT Program application process with us and thereafter if you are accepted into the AOT Program.
  • Any information or data you provide by interacting in our online Communication Channels, or by commenting on content posted on our Communication Channels. Please note that these comments are also visible to other users (e.g., employees of Grocery Outlet, TSOs and other AOTs) of the Communication Channels.
  • Information you provide when you complete a survey administered by GOI.
  • Information you provide that is related to your application or participation in the AOT Program.
  • If you contact us, we may keep a record of that correspondence and any contact information provided.

How We Use Your Information

We will only use your information as permitted by law. Situations in which we use your information include:

  • In order to assess your application for qualification to the AOT Program.
  • In order to provide training and education classes to you and assess your progress in the AOT Program if you are accepted.
  • To improve and grow our business, including, but not limited to conducting data analytics studies and similar processes to better understand the effectiveness of our recruiting and training for and implementation of the AOT Program.

We may use any and all of the information collected for any of the purposes described in this notice, unless limitations are listed. We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the information was collected. 

How We Secure the Information We Collect From or About You

We use a combination of physical, technical, and administrative safeguards to protect the information we collect in writing and also collect through the Communications Channels.

Unfortunately, the storage and processing of information via internet-connected computers can never be completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information stored or processed by us.

Our Sharing of Your Information

  • Service Providers:
    • We engage vendors to perform functions on our behalf including, but not limited to: website, software, and data storage, content management, database management, technical integration, marketing automation, analytics, site optimization, conducting surveys, and similar services. There are limited circumstances in which the service provider collects data directly from you when their privacy policies may also apply.
  • Other Independent Operators: We may share information you provide to us to other Independent Operators who act as TSOs in the AOT Program.
  • To our affiliates, subsidiaries, and other Grocery Outlet companies.
  • Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
  • Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
  • To other external parties when required by law or to protect GOI or other persons, as described in this privacy notice.

Additional Information About our Data Collection and Sharing Practices

Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies and analytics providers. These third parties will not be able to relate this data to identifiable individuals.

Combination of Information: We may combine information from the Communication Channels together and with other information we obtain from our business records. 

Your California Privacy Rights

California Shine the Light: We do not share your information with other companies for direct marketing purposes.

California Consumer Privacy Act

The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Persons with disabilities may obtain an alternative version of this policy.  Please send your request to privacyrequest@cfgo.com or call 1-888-501-1217.

Right to Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of the categories of Personal Information we collect and the purposes for which those categories of Personal Information will be used.  This notice should be provided at or before the time of collection.  The categories we use to describe the information are those enumerated in the CCPA.

  • Personal Identifiers:
    • We collect your name, phone number, email address, contact address, Social Security number, Driver’s license, citizenship, when you apply to the AOT Program.
    • You supply us with financial information and information about your business experience and similar information relevant to your AOT Application.  
  • Protected Classifications:  We do not collect your gender, racial or ethnic origin, or sexual orientation.
  • Commercial Information: We collect business information related to your past experience when you apply to the AOT Program.
  • Biometric Information:  We do not collection information about your physiological, biological, or behavioral characteristics.
  • Audio, electronic, visual, thermal, olfactory, or similar information:  We may record your calls or voicemail if you contact us by telephone, but if we do, you will receive notice beforehand.  We use this information to improve our customer service, train employees, investigate complaints and incidents, and maintain the security of our locations, personnel, and customers.

We may use any of the categories of information listed above for business purposes, operational purposes, for administering the AOT Program, or any purposes compatible with the context in which the Personal Information was collected. 

We may share any of the above-listed information with companies that we engage for business purposes to conduct activities on our behalf.  

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed

You have the right to obtain information regarding the categories of personal information we collect, sell, or disclose. That information is provided in this privacy notice.  We collect the categories of information described in the Information We Collect About You section above.  The categories we use to describe the information are those enumerated in the CCPA.

Right to Request Deletion of Information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Opt Out of Sale of Personal Information to Third Parties

Please know that we do not sell your personal information to any third parties in the way that you would normally think of such a transaction.  The CCPA defines “selling” personal information as disclosing it to an external party for monetary or other benefit. This definition is so broad that it includes any time we share your personal information with any vendor if we do not have an agreement in place with that vendor not to use your information solely to provide services to us.  You have the right to opt out of any sale of data by GOI to third parties. Please note that your right to opt out does not apply to our sharing of data with service providers who are parties we engage to perform a function on our behalf and are legally and contractually obligated to use the data only for that function. 

Right to Information Regarding Participation in Data Sharing for Financial Incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights.  We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we offer a one-time discount if consumers sign up for our email marketing list and some of our stores may offer “enter to win” drawings for prizes.  Participation in these incentives is voluntary, and if you participate in these incentives outside of the AOT program, you may opt out of this data sharing at any time.

How to Submit a Request

You may submit a request to exercise your rights through one of two means:

  • By sending us an email at privacyrequest@cfgo.com.
  • By calling us at 1-888-501-1217.

Transferring Your Personal Information Abroad

Your personal information will be stored and processed in the United States. GOI and its service providers may also transfer information that we collect about you, including personal information, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These jurisdictions may not have the same data protection laws as your jurisdiction. Wherever your personal information is transferred, stored or processed by us, we will take commercially reasonable steps to safeguard the privacy of your personal information.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: support@groceryoutlet.zendesk.com, or via telephone at: (888) 501-1217