Smart Foodservice's Privacy Statement
Personal Information We Collect from You
Categories and Types of Personal Information We Collect
We collect the following categories and types of personal information:
- Contact Information: name, mailing address, and phone number;
- Other identifying information: IP address, social media handle, password, security questions and answers, operating system, web browser, phone device ID;
- Financial Information: credit card, debit card and bank account information (including account number, routing number, balance information and transactional data associated with your account);
- Geolocation data;
- Demographic information: date of birth, marital status, gender, income, hobbies, interests, race, national or ethnic origin, languages spoken;
- Internet or other electronic activity: mouse clicks, scrolling activities, website pages visited and time and duration on websites;
- Commercial information: transactional history and products purchased, considered or viewed on our website or in our stores; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.
Categories of Use
- Transactional Purposes: We use your contact information, financial information, and commercial information to:
- Keep a record of our interactions with you when we communicate online, over the telephone, and by other methods in which we provide customer service;
- Process your registration with our Service; and
- Process and complete your transactions including, as applicable, order confirmation, billing, enrollment in our loyalty or other programs, and delivering products or services.
- Analytical Purposes: We use your internet activity and browsing history to analyze preferences, trends and statistics.
- Marketing and Promotional Purposes: We use your contact information, commercial information, demographic information, internet or other electronic activity, and inferences to:
- Provide you with newsletters, articles, product or service alerts, new product or service announcements, discounts, event invitations, and other information;
- Contact you about programs, products, or services that we believe may be of interest to you, or sharing special offers from other companies;
- Administer sweepstakes and promotions; and
- Provide you with personally tailored coupons, programs, offers, content and ads.
- Maintenance and Improvement of Services and Website: We use your contact information, commercial information, and internet activity and browsing history to:
- Respond to your inquiries on order status, services questions and complaints, technical issues, etc.;
- To collect feedback from you about our Services; and
- Help us diagnose technical and service problems and administer our stores, websites and apps.
- Review and content creation purposes: We use your photos, graphics and videos to enable reviews of our products and to display content that you have created and allowed us to display on our website and Services and on social media.
- Legal, Security and Safety Purposes: We use your personal information to comply with federal, state, and local laws in addition to maintaining the safety and security of your physical and digital selves, including to:
- Confirm your identity for security safeguard purposes;
- Prevent, investigate, or provide notice of fraud, unlawful or criminal activity, or unauthorized access to or use of personal information, our website or data systems, or to meet legal obligations;
- Alert you about a product safety announcement, recall or correction of an offer, promotion or advertisement; and
Sources of Personal Information
We collect information from the following sources:
We collect information directly from you. We collect contact information, financial information, and demographic information directly from you.
We collect information about you from third parties. We collect your personal information from third parties, such as product vendors, advertising companies and government agencies to deliver quality services to you. These companies may share your information with SWS depending on the consent agreements you have with them at the time of your interactions together. This Policy does not apply to the personal information collection and sharing consent you have given them. Personal information collected from third parties may be combined with the personal information collected via our Services to compile a comprehensive profile of you, your preferences, and your shopping habits.
We may combine information you give us online and in our stores. We may also combine that information with publicly available information and information we receive from or cross-reference with third parties. We use that combined information to enhance and personalize your shopping experience with us, to communicate with you directly about our products and events that may be of interest to you, and for other promotional and commercial purposes.
When We Share Information with Third Parties
Our Service Providers
We may contract with companies or persons to provide certain services including credit card processing, shipping, data analysis and management, advertising and promotional services, etc. We call them our Service Providers. We provide our Service Providers with the information needed for them to perform these services. We also ask our Service Providers to confirm that their privacy practices are consistent with ours.
We may share personal information with businesses controlling, controlled by, or under common control with SWS.
Law Enforcement and Courts
In certain instances, we may disclose your contact information when we have reason to believe that it is necessary to identify, contact or bring legal action against persons or entities who may be causing injury to you, to SWS or to others. We may also disclose your contact information when we believe the law or legal process requires it.
Technical information about the computer and mobile devices you use when consuming our Services is sometimes automatically collected by us or our third-party technology partners. Cookies, web beacons, scripts, application logs, fingerprinting technologies, and geo-location tracking are among the common methods in which we’re able to learn how you’re utilizing our Service as you interact with our websites, mobile apps, and other digital channels.
Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.
We use Google Analytics on the Site and Services to collect usage data, to analyze how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
We do not knowingly collect personal data from children below the age of 18. Please contact us using the methods in the Contact Us section below if you believe your child has provided their personal information and the child’s information will be promptly deleted from all storage locations.
Advertising and Online Tracking
We may work with third-party companies for advertising purposes in the following ways: to serve advertisements across third party sites; to track your activity when you visit the Services; and to identify the device you use to visit the Site. We share such information with these companies, we may also allow third-party companies to serve ads and collect certain anonymous information when you visit the Services. These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser “Do Not Track” signals, but several of our third-party partners who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/.
California and Nevada Customer Privacy Rights
If you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”) and Shine the Light law (“STL Rights”). This section describes those statutory rights and how you can exercise them with SWS.
CCPA Rights Requests
Right to Know and Right to Deletion
You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months.
You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:
- Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;
- Security: to detect data security incidents;
- Error Correction: to debug or repair any errors;
- Legal: to protect against fraud or illegal activity or to comply with applicable law or a legal obligation, or exercise rights under the law, such as the right to free speech; or
- Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).
Please note that if we delete your personal information, many of our services will not work the same. For example, you will no longer be able to make an unreceipted return, you will lose your loyalty account and points you will lose your shopping lists, you will not be able to accrue loyalty points moving forward, your previous opt out requests will not be saved, you will not have an account, and your shopping cart items, order history, and saved preferences and information will no longer be available.
To submit a request to know or a request to delete, you can either call our toll free number at 800-730-7627 or Click Here. In order to verify your identity, we will respond to your inquiry via email. You will have three days to acknowledge the email and confirm your identity. In order to designate an authorized agent to act on your behalf, you or your agent must submit a power of attorney or proof of guardianship through our webform Click Here. Once your request has been submitted, a verification of identity will be sent to the email provided on the request. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information.
Do Not Sell My Personal Information (California and Nevada Customers)
Personal Information that We Sell
We may sell (as “sell” is defined in the applicable statute) the following categories of personal information:
- Characteristics of protected classifications under California and federal law;
- Internet/electronic activity;
- Commercial information; and
- Inferences drawn from the categories described above in order to create a profile about you to reflect your preferences, characteristics, preferences, behavior and attitudes.
We do not knowingly sell the personal information of minors under the age of 18.
Right to Opt Out of Sale
You have the right to opt out of the sale of your personal information to third parties, as “sale” is defined under CCPA. If you exercise your right to opt out of the sale of your personal information, for at least 12 months, we will not request that you authorize the sale of your personal information again. However, if you change your mind and would like to allow us to sell your information, you may write to us to authorize us to do so.
To submit a request to opt out of the sale of your personal information, please Click Here. In order to designate an authorized agent to act on your behalf, the agent will need to submit the request on your behalf. When prompted, they will need to provide evidence of authorization, such as Power of Attorney, along with your full name, email address and phone number, so that we can verify your identity.
We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.
STL Rights Requests
To opt out of sharing your Personal Information with third parties for their direct marketing purposes, please e-mail us at SWSprivacy@smartandfinal.com and clearly state your request, including your name, mailing address, e-mail address and phone number.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Services, we cannot and do not guarantee the security of any information you transmit on or through the Services, and you do so at your own risk.
Processing in the United States
Please be aware that your personal information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using our Services, you are agreeing to the collection, use, transfer, and disclosure of your personal information and communications will be governed by the applicable laws in the United States.
Please feel free to contact us with any privacy questions or requests for more information on this Policy by email at firstname.lastname@example.org or by mail at:
Smart Foodservice Warehouse Stores LLC Attn: SWS Privacy 600 Citadel Drive Commerce, CA 90040
Please do not include any sensitive personal information in your email or letter. Regular postal mail and many email communication platforms have inadequate methods for protecting data sent through these methods.
Last Revision Date: [December 30, 2019]