• The Scintilla Privacy Notice was expanded to include the Scintilla In-Store application.

This Privacy Notice describes what personal information we collect through the Scintilla platforms, including Scintilla In-Store (collectively referred to as “we”, “us”, or “our”), how we collect and use your personal information, who we disclose it to and why, the measures we take to protect your personal information, and the choices you may have regarding our use of your personal information. It applies exclusively to data collected via Scintilla and its associated websites or applications and does not extend to other Walmart platforms or services.

We may collect or receive the categories of personal information listed below, which may depend on the services you may use, as well as your device and account settings. Not all categories may be collected about every individual:

• Basic Personal Identifiers, such as name, telephone number, physical or mailing address, email address, and employee or vendor number.
• Device and Online Identifiers, such as account login information, MAC address, IP address, cookie IDs, and mobile ad IDs.
• Internet and Other Network Activity Information, such as information about your browser or search activity as well as interactions with our websites, mobile applications, emails, or advertisements (for example keystroke patterns which help us determine if it is you or a bot who is interacting with us).
• Communications, such as content of emails, text messages, interactions with our bot (AI assistant chatbot), 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.
• 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.
• Sensory Information, such as audio, visual information, and other sensory information such as photographs and audio and video recordings.
• Employment Information, such as the name of your employer, occupation, title, licenses and professional memberships. This may also include metrics related to your use of our services, like check-in and check-out times at our stores and facilities.
• Financial Information, such as credit or debit card numbers, and financial account numbers.
• Inferences, such as individual preferences and characteristics, or your advertising goals.
• Any other information you choose to provide, such as via surveys or during discussions with Walmart or Walmart clients or their designees.

We may obtain and combine personal information from different sources, types of technology, and devices. It may be:

• When you submit information through Scintilla, or complete one of our surveys or other activities we obtain personal information directly from you.
• We also collect personal information directly from you when you use features on Scintilla that enables us, with your consent, to access the camera on your computer or mobile device to enable you to upload photos or videos. You must give us your permission before we access photos or videos on your computer or mobile device, and you can opt out of providing access to them any time by adjusting the settings on your device.

• We may automatically collect personal information from devices that you use to interact with Scintilla, 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 Scintilla websites, pages you visited on Scintilla, time spent on those pages, information you searched for on Scintilla, when and for how long you visited the Scintilla, and similar information, which we collect through cookies, beacons, and other technologies.
• If you have consented to the collection of your precise geolocation, it will be used to determine where you are within or around a particular store or facility. You can control our ability to do this by adjusting the location-sharing settings on your mobile device at any time. You also may adjust your mobile device’s Bluetooth settings to disable the sharing of Bluetooth location-related data. However, disabling precise geolocation may have a significant impact on your ability to participate in Scintilla In-Store.
• 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.
• The information we automatically collect will be associated with any personal information that you have provided to us.

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.

Scintilla may use the personal information it collects about you for a number of purposes, including:

• Performing services, including maintaining and servicing your account, providing customer service or personalization.
• Fulfilling requests and obligations related to our relationship.
• Performing and providing advertising and marketing services.
• Conducting business analysis, such as analytics, projections, and identifying areas for operational improvement.
• Undertaking activities to verify or maintain the quality or safety of our services and to improve, upgrade, or enhance them, such as training our AI.
• Fulfilling our legal function or obligations.
• Debugging to identify and repair errors.
• Conducting research and development, including undertaking internal research for technological development and demonstration.
• Helping to ensure security/integrity and 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.

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

Vendors for Business Operations: We disclose personal information about you to vendors to perform services on our behalf.

Within Our Corporate Family of Companies

We may disclose your personal information with other retail companies (e.g., Walmart and Sam’s Club) within our corporate family for them to use in ways that are consistent with this Privacy Notice.

Employees of Walmart Suppliers or Scintilla In-Store Users:

We may share information related to your presence at our facilities, such as geographic location or time of check-in or –out, with the Walmart suppliers for whom you provide a service.

Legal Requirements and Protections of Our Company and Others:

We may disclose your personal information when required by law or legal process, or when we believe it will help protect the safety, property, or rights of individuals or Walmart. Examples include:

• Enforce our Terms of Service.
• Protecting the health or safety of individuals.
• Addressing crimes committed on Walmart property.
• Identifying and addressing fraud or financial risk.
• Responding to a request from law enforcement, search warrant, or other valid legal inquiry.
• Responding to a court or other investigative body in the case of an alleged breach of an agreement or violation of law.
• Assist with fraud prevention and potential criminal activity.

Business Transfers: If we plan to merge, sell, or reorganize our business, we may disclose your personal information, along with personal information of others that interact with Scintilla 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.

Aggregated, Non-Identifying Information: Scintilla may share aggregated information that is not individually identifiable (or personal information) with third parties for any purpose including industry analysis and demographic analysis. For clarity, we do not de-identify or aggregate photos, videos and audio recordings.

Other than as described above, we will not share your personal information with third parties.

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

Category of Third parties:	Categories of Personal Information:
Those to whom we are legally required to share.	Device and Online Identifiers Employment Information Financial Information Individual Preferences and Characteristics Internet, Application, and Network Activity governance Personal Identifiers Sensory Information Communications
Vendors who provide services to us (e.g. technology providers, cloud storage providers, etc.).	Device and Online Identifiers Employment Information Financial Information Individual Preferences and Characteristics Internet, Application, and Network Activity governance Personal Identifiers Sensory Information Communications

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

Scintilla 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 Scintilla to better understand how you interact with it, and to monitor aggregate use of Scintilla by its users. Unlike persistent cookies, session cookies are deleted from your computer when you log off of Scintilla and close your browser.

We also may use "pixel tags," "web beacons," and other technologies on Scintilla to collect usage, demographic, and geographic location data, which allow us to count users who have visited certain pages of Scintilla, 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. 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/.

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.

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 policy. We dispose of the information we collect in accordance with our retention policies and procedures.

By using Scintilla 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 Scintilla 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.

Scintilla is directed to operations in the United States. Scintilla does not offer services in Europe or the European Economic Area.

Scintilla is a general audience platform and website intended for business-to-business use and 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 resident of California, you have additional rights described in our Walmart Supplier Privacy Notice “What Are Your California Privacy Rights” section.

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

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