Tawa Supermarket, Inc. and our affiliates are committed to protecting your privacy. We recognize that privacy is an important issues for our customers and employees and we want to be transparent about how we collect, use, and disclose your personal information—this Privacy Notice provides you with notice of our processing activities and your rights under the law. Personal Information generally means any information that identifies you as an individual person, along with other information we associate with it. This includes information that is maintained by us in a manner that identifies you or your household. Personal information does not include publicly available information or information that is de-identified or aggregate consumer information.

By using any of our websites and mobile applications in the United States (collectively, “Sites”) or otherwise providing Personal Information to us, you agree to this Privacy Policy. This Privacy Notice is intended for individuals in the United States who are over the age of 16. If you live outside of the United States and choose to use the Sites connected with this Privacy Notice, you do so at your own risk and understand that your information will be sent to and stored in the United States.

Application
This Privacy Notice applies to Tawa Supermarket, Inc., Tawa Inc. (Retail), Tawa Services, Inc., Welcome Market, Inc., Welcome California Market, Inc., and Welcome Services, Inc.

1. The Information We Collect and How We Use It
We may collect Personal Information from you in a variety of different situations, including, but not limited to on our website, your mobile device, through email, in physical locations, through the mail, and/or over the telephone. The following chart describes the type of information we collect, the source of that information, our purposes for using the information, and the third parties with whom we may share the information.

Classification of Information: Account Information: First name, last name, email address, password, physical addresses, phone number and age.
Source of Information: Consumers or when they sign up for an account. Shopping apps, like AppCart.
Purposes for Collecting This Information: Our or our service providers’ operational purposes. Our commercial purposes.
Third Parties With Whom We May Share This Information: Internet Service Providers (ISPs). Sweepstakes/Contest service providers and/or sponsors. Ecommerce providers.

Classification of Information: Rewards Card Information: Account Information and rewards card number (which we assign), purchase history (including prices paid for items).
Source of Information: Consumers when they sign up for a rewards card. Shopping apps, like AppCart.
Purposes for Collecting This Information: Our commercial purposes.
Third Parties With Whom We May Share This Information: Ecommerce providers.

Classification of Information: Payment and Credit Information: We may collect credit card and other payment method details.
Source of Information: Consumers or their agents when they make purchases through us. Shopping apps, like AppCart.
Purposes for Collecting This Information: Our or our service providers’ operational purposes.
Third Parties With Whom We May Share This Information: Payment processors. Ecommerce providers.

Classification of Information: Shopping History Information: Order history, favorite items, saved recipes, shopping lists.
Source of Information: Consumers Online Shopping Service Providers. Shopping apps, like AppCart.
Purposes for Collecting This Information: Our or our service providers’ operational purposes.
Third Parties With Whom We May Share This Information: Ecommerce providers.

Classification of Information: Safety and Security Information: Information (including likeness) via closed circuit television systems, internet systems, electronic surveillance systems and other security and technology systems.
Source of Information: From the consumer or directly via our security systems.
Purposes for Collecting This Information: Our or our service providers’ operational purposes.
Third Parties With Whom We May Share This Information: Ecommerce providers.

Classification of Information: Internet and Network Activity: We log IP addresses, the URL of your request, device type/model, your general location (obtained from your IP address), operating system, browser type, user agent, and preferred language for browsing, and information that is provided in the HTTP header. We use cookies and similar technologies to gather information related to how you interact with our websites, platforms, and online content.
Source of Information: Consumers (via their devices).
Purposes for Collecting This Information: Our or our service provider’s operational purposes. Third Parties With Whom We May Share This Information: Internet Service Providers (ISPs). Data Analytics Providers (Google Analytics). Online Shopping Providers. Ecommerce providers.

Classification of Information: Location Information: If your device settings permit, we may automatically collect information about your precise location when you access our website. We may be able to identify your general location from your IP address.
Source of Information: From the consumer or the consumer’s device
Purposes for Collecting This Information: Our or our service providers’ operational purposes. Our commercial purposes.
Third Parties With Whom We May Share This Information: ISPs. Data Analytics Providers. Ecommerce providers.

Classification of Information: Employment Opportunity Information: Information you provide as part of your application, interview, assessment process. Information from third parties in connection with your application, such as referees and recruiters. Information related to pre-employment background checks and as part of the onboarding process.
Source of Information: From applicants, references, referral sources, background check providers, professional/educational institutions.
Purposes for Collecting This Information: Our or our service provider’s operational purposes.
Third Parties With Whom We May Share This Information: Employment evaluation service providers.

In addition to the above, there may be some circumstances where we may need to collect additional information. For example, if a shopper or other person at our stores requires medical or emergency assistance, we may collect and share information about individuals in order to assist with the situation. If you enter into a contest, sweepstakes, or other promotion, we may collect personal information from you in order to administer the event. In doing so, we may disclose your information to our co-sponsors, service providers, and other third parties in accordance with the event’s purpose and as described in the official rules or terms.

2. Our Operational and Commercial Purposes
As part of operating a grocery chain, we undertake a multitude of operations which require the processing of personal information. For example, our business purposes include: (1) facilitating purchase transactions for goods and services and to prevent transactional fraud; (2) providing customer support, including responding to inquiries and investigating your concerns; (3) engaging in quality control in order to improve our offerings to you; (4) administering membership, rewards, and other incentive programs, (5) conducting marketing and sales promotions; (6) contacting you to inform you about benefits or information relating to your employment or potential employment; (7) ensuring the safety and security of our guests, our staff, and all other persons visiting stores; (8) preventing prevent, detect, and investigate fraud, cyber incidents, or other illegal activity; (9) communicating with you and others in relation to your use of our services, including providing legal updates; (10) administering our record-keeping for legal, tax, and operational purposes; and (11) responding to law enforcement requests and as required by applicable law, court order, or governmental regulation.

3. Our Rewards Program
We offer a Rewards Program to consumers in certain areas to earn points for shopping at our stores, subject to the Rewards Program terms and conditions. We will not require an applicant to provide a driver’s license number or social security account number as a condition of entering into our Rewards Program, but may verify a customer’s age for purposes of allowing them to join the Rewards Program.

4. Your Use of Online Shopping Apps
When you use third-party shopping apps to make purchases from us, we collect personal information about you from those apps in order to provide our goods and services, and to facilitate your use of those third-party apps and services. We have partnered with AppCard to make your optimize online shopping experience. By using AppCard when you interact with us, you authorize us to provide personal information to and through AppCard in order to facilitate the transactions you request. We do not control how AppCard processes your personal information. You can find AppCard’s privacy policy here: https://appcard.com/biz/privacy-policy/

5. Disclosure of Your Personal Information
In order to provide you our service and to fulfill our business and commercial purposes, we may disclose your personal information. In addition to the recipients described in Section 1, we may disclose your information to our trusted third party service providers, including but not limited to our cloud service providers, web development, analytics, and security providers, communications providers, and internal and external advisors or auditors. When doing so we will, when appropriate or required by applicable law, put in place appropriate contracts containing standard data protection clauses to protect that information and the rights of individuals. We may share your personal information among TAWA affiliates, owners and operators of our affiliated companies. We also will disclose your personal information to any agents our third parties to whom you authorize us to disclose it.

We may disclose personal information in the following circumstances: (1) in order to comply with an applicable federal, state, or local law; (2) in order to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) to cooperate with law enforcement agencies concerning conduct or activity that web reasonably and in good faith believes may violate federal, state, or local law; (4) to exercise and defend legal claims; (5) when such disclosure is pursuant necessary to protect the rights and freedoms of other individuals; (6) as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of any one of our legal entities, and (7) in any other manner permitted by law, including engaging in protected speech.

Links

Links to web sites that are not operated by or for us (“Third Party Sites”) are provided solely as a convenience to you. If you use these links, you will leave our website. This Privacy Notice does not apply to Third Party Sites. We have not reviewed the Third Party sites, do not control and are not responsible for any of their content or their privacy policies, if any. We do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the Third Party Sites listed on or linked to from our website, you should understand that you do so at your own risk.

6. Security
We are committed to protecting the security of any personal information you provide. For these reasons, certain financial information, such as credit card data, will generally be transferred over a Secured Socket Layer (SSL) connection (provided that it is supported or enabled on your browser). In spite of these protections, any information submitted over the Internet could be intercepted or otherwise corrupted during transmission, and we cannot guarantee the complete security of any data submitted over the Internet. Sensitive personal information is stored on servers or locations protected by procedures and technology designed to block reasonably foreseeable intrusions by unauthorized third parties. The servers are under our control at all times but maybe hosted, managed or otherwise maintained by third party service providers with whom we contract. These third party service providers have no right to use or access this data other than in performing their services for us.

You may access and change certain information associated with your account at any time by logging in. Please keep your password in a safe place and do not provide it to anyone. We strongly encourage you to check the accuracy of your personal information regularly as we will use your contact information to communicate with you regarding products or services that you have requested. We will not be liable for any problems or difficulties that arise as a result of your failure to keep your information up to date.

7. Your Marketing and Ad Choices
Email Marketing: We understand that your time and attention is precious to you. If you would like to opt-out from receiving marketing emails from us or our affiliates you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of most promotional e-mail messages

Third Party Cookies: We and/or our service providers may collect and store information using cookies, local shared objects (or Flash cookies), web beacons, Uniform Resource Locators (URL), and similar technologies to manage our websites and email messages. We may also collect and track information about you and your activities online at our websites over time. You can use your web browser to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.

Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. However, because there is not yet a defined response to do-not-track requests, our Site does not respond to your browser’s do-not-track request. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

Google Analytics: We use Google Analytics for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookies with a randomly-generated ClientID in your browser. This ID contains no identifiable information like email, phone number, name, etc. We also send Google your IP Address. We use Google Analytics to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. You can use Google’s privacy controls to opt-out of analytics cookies set by Google.

8. Children’s Privacy
We are committed to complying with the Children’s Online Privacy Protection Act (COPPA) which protects children under the age of 13 from online data collection without parental consent. Our website and services are not directed to children under the age of 16 and we do not knowingly collect personal information from children under the age of 16. If we receive personal information that we discover was provided by a child under the age of 16, we will promptly destroy such information. Parents are encouraged supervise their children’s online activities and consider the use of other means to provide a child-friendly online environment. Additional information is available on the Direct Marketing Association’s home page at http://www.the-dma.org. If you would like to learn more about COPPA, visit the Federal Trade Commission home page at http://www.ftc.gov.

9. Agreement and Changes
By submitting your personal information on our through our website, you agree to the collection and use of your personal information on the basis described above. If you do not agree, please do not provide any personal information via our website. If we decide to update our Privacy Policy, we will indicate this next to the Privacy Policy link on the front page of our Site. If there are material changes to the Privacy Policy, we will prominently post and/or communicate such changes prior to implementing them. Information collected under previous versions of our Privacy Policy will then become subject to the terms of our new Privacy Policy.

10. California Privacy Rights
If you reside in California, you have specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.

Categories of Personal Information Collected

In the preceding twelve months from the Effective Date of the policy, we have collected the following categories of personal information, as described above and as defined in the California Consumer Privacy Act (California Civil Code § 1798.100, et. seq.), about California residents:

• Identifiers;
• Personal Information described in California Civil Code § 1798.80(e)
• Characteristics of protected classifications
• Commercial Information
• Internet and Network Information
• Geolocation data
• Sensory Information (audio, visual, electronic)
• Professional or employment related information
• Education information
• Inferences drawn from other information

We have in the last 12 months disclosed for a business purpose the following categories of personal information: (i) Identifiers; (ii) Personal Information described in California Civil Code § 1798.80(e); (iii) Characteristics of protected classifications; (iv) Commercial Information; (v) Internet or network information; (vi) Geolocation data; (vii) Sensory information; (viii) Professional or employment related information; (ix) Education information; and (x) Inferences drawn from other information.

• Access Rights: You have the right to request that we disclose what personal information about you it collects, uses, discloses, and sell.
• Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
  To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by either calling us at 1-800-600-TAWA [8292] or by submitting an email to legaldept@tawa.com.

Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Upon submitting a request, we will attempt to verify your identity by matching the identifying information provided by you (or your authorized representative) to the personal information already maintained by us. The type of information you must provide depends on the type of request you make. Alternatively, we may use a third party verification service to verify your identity. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

The Right to Opt-Out/Opt-In to Sale of Your Personal Information: The California Consumer Privacy Act defines the “sale” of personal information in a way that may include many types of disclosures not normally considered a sale. We do not disclose personal information to third parties in exchange for money. While we share personal information with third parties, we do not do so in exchange for valuable consideration. As such we do not knowingly sell personal information to third parties.

The Right Against Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

Authorized Agents

If you are using an authorized agent to submit a request to know or request to delete, you must provide the authorized agent written permission to do so. Written permission must be submitted to us as part of the verification process and the agent must also verify their own identity with us using the verification methods described above. We may deny requests from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

11. Contact Us
If you have questions or concerns about our privacy policy, you can contact us at legaldept@tawa.com.