Kroger Co. Zero Hunger Zero Waste Foundation Website Privacy Policy

Last Revised: September 2023

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. The Kroger Co. Zero Hunger Zero Waste Foundation, an Ohio nonprofit corporation (collectively with its subsidiaries, “Foundation,” “we,” “us,” and “our”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”).

This Policy describes:

• The types of information we collect from you or that you may provide when you visit our website available at: https://zerohungerzerowastefoundation.org/index.html as well as any websites and blogs directly owned by the Foundation (collectively, our “Website”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you and this Website, and information gathered when you interact with our advertising on third-party websites if such advertisements include links to this Policy.

This Policy does not apply to information collected by us offline or through any other means, including on any other website operated by the Foundation or any third party, or information collected by any third party through any application or content (including advertising) that may link to or be accessible from the Website (for further information, see below, “Third-party Websites”).

Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Website Terms of Use; Other Agreements

This Policy should be read in conjunction with any applicable Terms of Use, into which this Policy is incorporated by reference.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share personal information about you in accordance with this Policy. Personal information is information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user, household or device (“Personal Information”).

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you communicate with us.
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.
• Directly and indirectly from activity on our Website. For example, from Website usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as contacting the Foundation to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, credit card information or other sensitive personal data, unless required for our services.

Please note that donations are made through our trusted third-party partner, OneCause, and any donor information you provide is done through a website owned and controlled by OneCause. You can access OneCause’s Privacy Policy here.

4. Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

5. How We Use Your Information

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to:

• providing the information, products and services you request;
• security, credit or fraud prevention purposes;
• providing you with a personalized experience when you use this Website;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of this Website;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of this Website;
• improving our products and services;
• improving our marketing and promotional efforts; and
• any other purpose identified in an applicable privacy notice, click-through agreement or other agreement between you and us.

6. How We Disclose Your Information

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to a third party for a business purpose. When we disclose your Personal Information, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Legal Reasons.
  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements, policies, or the Terms of Use;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Foundation employee.
• Sale of Business or Merger. There are circumstances where the Foundation may decide to buy, sell, or reorganize its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Foundation will ensure your information is used in accordance with this Policy.

7. Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

9. Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen (18). We do not target the Website to minors, and would not expect them to be engaging with our Website or services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on “DONATE” you will be taken to another website that we do not control, but is instead owned by OneCause. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

11. Your Rights Under California Law

• Shine the Light law. Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.
• Do Not Track Signals. Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising. Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser.
• WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information.

Your Consumer Rights

If you are a consumer in a state that provides consumer rights, please be advised that the Foundation is not a “business” or “controller” as that term is defined under applicable state laws, and therefore does not afford consumers these rights with respect to their Personal Information. Regardless, all Personal Information will be processed in accordance with the Policy.

12. For Website Users or Visitors Outside of the United States

We do not warrant or represent that this Policy or the Website’s use of your Personal Information complies with the laws of any jurisdiction outside the United States. Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

13. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. Please also notify us of any actual or suspected unauthorized use.

14. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the products and services we offer through this Website. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

15. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us at KrogerZeroHungerZeroWasteFoundation@kroger.com.