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NOTICE TO CALIFORNIA APPLICANTS

 
This California Privacy Notice is effective as of March 7th, 2024.
 
This notice supplements ALDI, Inc’s (“ALDI”) job applicant privacy policy and applies only to California residents who are applying for a position with ALDI as an employee or independent contractor (“California Applicants”).  This California Applicant Privacy Notice sets forth the disclosures and rights for California Applicants regarding their Personal Information, as required by the California Consumer Privacy Act of 2018 ("CCPA") as amended by the California Privacy Rights Act of 2020, and any implementing regulations adopted thereunder. Terms (including defined capitalized terms) used in this California Applicant Privacy Notice have the same meanings given in the CCPA and the associated regulations, unless otherwise defined.
 

EXERCISING YOUR CALIFORNIA RIGHTS

California Applicants have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you ("Right to Know"); (2) that we delete the Personal Information we collect from you ("Right to Delete"); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”), (4) to opt-out from the sharing of your Personal Information and Sensitive Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), (5) to opt-out from the sale of their Personal Information and Sensitive Personal Information (“Right to Opt-Out of Sale”), and (6) that we limit the use or disclosure of your Sensitive Personal Information to purposes set forth in the statute, including that use which is necessary and anticipated to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services (“Right to Limit The Use and Disclosure of Sensitive Personal Information”), all subject to the meanings and exceptions set forth in the CCPA. More information on each of these rights is below.
 

Verifying Your Requests

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may ask you to log in to your applicant portal account. We may also ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. We will only use any such information to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
 
Pursuant to the CCPA, we will not require you to verify your identity, beyond asking for the information necessary to complete your request, when you exercise your Right to Opt-Out of Sharing, Right to Opt-Out of Sale, or Right to Limit the Use and Disclosure of Sensitive Personal Information.

 

Authorized Agents

If you are an authorized representative submitting a request on a California Applicant’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may, but are not required, to submit a copy of a power of attorney under Probate Code sections 4000-4465.  In either case, please also indicate in your email the nature of your request. The consumer’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request.  We may also ask the California Applicant to directly confirm with us that they provided you permission to submit a request. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the California Applicant’s behalf, we may deny the request.
 

Right to Know

To exercise your Right to Know, please submit your request at complete this form  or by calling us at 1-833-602-2534.
 
In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the California Applicant whose Personal Information is the subject of the request. We will not provide you specific pieces of information that include the Personal Information of other persons, nor will we disclose certain pieces of information that the law requires us not to or that we determine is a high security risk, including your social security number, driver’s license number, financial account number, health insurance or medical information number, account passwords, security questions and answers, or unique biometric data, as applicable.
 

Right to Delete

To exercise your Right to Delete, please submit your request at complete this form or by calling us at 1-833-602-2534.
 
Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.
 

Right to Correct Inaccurate Information

If you would like to exercise your Right to Correct, please submit your request at complete this form or by calling us at 1-833-602-2534.
 

Right to Limit The Use and Disclosure of Sensitive Personal Information

As disclosed in the chart below, we may collect certain information in connection with your application for a position with us that is considered Sensitive Personal Information under California law. Under the CCPA, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when sensitive personal information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to California Civil Code § 1798.121. ALDI’s use and disclosure of applicants’ Sensitive Personal Information is not used for such purposes and/or falls within this list of exceptions and we therefore do not offer such opt-out right at this time.
 

Do Not Sell or Share

ALDI does not sell, or share for cross-context behavioral advertising, the Personal Information or Sensitive Personal Information of its applicants.
 

Data Retention

ALDI will retain all categories of Personal Information described in this privacy notice for as long as is reasonably necessary to fulfill the purposes set forth in this privacy notice or that you authorized after collection, or as otherwise required by law. If you are offered and accept a job with ALDI, the Personal Information we collected during the application and recruitment process will become part of your personnel record, and we may use it in connection with your working relationship with ALDI consistent with our personnel privacy policy.
 
In determining how long we retain your Personal Information, we take into account our legal and regulatory obligations (such as legal requirements to retain your information, financial reporting obligations, and equal opportunity or anti-discrimination reporting obligations), the nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Personal Information, and whether we may need to retain the Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce our agreements.
 

Users Younger than 18

ALDI does not hire employees younger than 18 years of age. We therefore do not knowingly sell, or share for cross-contextual behavioral advertising, the Personal Information of applicants younger than 18 years of age.
 

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California Applicants have the right to not receive discriminatory treatment for exercising their CCPA rights. We will not discriminate against you for exercising your CCPA rights.
 

GPC/Do Not Track

Global Privacy Controls (“GPC”) and Do Not Track (“DNT”) offered by some web browsers are settings that automatically inform websites of your privacy preferences with regard to third party online tracking including exercising your rights and requesting the web application to disable tracking you. When you choose to turn on the GPC/DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to exercise your privacy rights and stop tracking your activity. You can learn more about and set up GPC here and set up Do Not Track here. We comply with GPC as required under applicable law, but because there is not yet an accepted standard for how to respond to browser DNT signals, we do not currently respond to them. 
 

PERSONAL INFORMATION WE COLLECT

The Personal Information we collect about you will depend upon your application, how you interact with us, and how your application progresses through our hiring process. Accordingly, we may not collect all of the below information about you.
 
In addition to the below, we may collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA.

Category of Personal Information Collected

Categories of Sources from which the Information was Collected

Business or Commercial Purpose(s) for which Information is Collected

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose

Identifiers

We may collect this type of information from:
• You;
• Cookies and Tracking Technologies;
• Third party career portals and other business partners.
We may use this type of information for:
• Recruitment and hiring;
• Communication with you;
• Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations
We may disclose this type of information to:
• Service Providers;
• Third parties who may acquire your information as a result of a merger, acquisition or otherwise ownership transition;
• Third parties or affiliated companies when you agree to or direct that we share your information with them;
• Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).

Any categories of Personal Information described in subdivision (v) of Section 1798.140

We may collect this type of information from:
• You;
• Cookies and Tracking Technologies;
• Third party career portals and other business partners.
We may use this type of information for:
• Recruitment and hiring;
• Communication with you;
• Statistical and analytical purposes;
• Compliance with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations
We may disclose this type of information to:
• Service Providers;
• Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition;
• Third parties or affiliated companies when you agree to or direct that we share your information with them;
• Other third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders).

Internet or other electronic network activity information

We may collect this type of information from:
• Cookies and tracking technologies;
• Third-party career portals and other business partners
We may use this type of information to:
• Administer our applications, software, and systems;
• Prevent fraud and enforce ALDI policies;
• Run analytics and for other statistical purposes;
• Comply with legal obligations, including health and safety requirements, requests for information from government agencies, and security investigations
We may disclose this type of information to:
• Service Providers;
• Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition;
• Third parties or affiliated companies when you agree to or direct that we share your information with them;
• Other third parties (including government agencies) as required by law or in connection with court proceedings.

Inferences drawn from any of the information identified above to create a profile about You

We may draw these inferences ourselves or acquire them from third-party data resellers or other business partners. We may use this type of information for:
• Recruitment and hiring;
• Statistical and analytical purposes
We may disclose this type of information to:
• Service Providers;
• Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition;
• Third parties or affiliated companies when you agree to or direct that we share your information with them;
• Other third parties (including government agencies) as required by law or in connection with court proceedings.

Sensitive Personal Information

We may collect the following information:
• Identification numbers such as your social security number, driver’s license number or passport number;
• Your racial or ethnic origin (solely for reporting purposes);
• Your membership in a union;

We may collect this type of information from:
• You
We may use this type of information for:
• Compliance with our legal obligations, including reporting obligations to and other requests for information from government agencies;
We may disclose this type of information to:
• Service Providers;
• Third parties (including government agencies) as required by law or in connection with court proceedings (such as pursuant to subpoenas or court orders);
• Third parties who may acquire your information as a result of a merger, acquisition, or other ownership transition.
 

More Information

For more information about our privacy practices for ALDI applicants, please refer to the general Applicant Privacy Policy, found HERE.



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