PRIVACY POLICY FOR ADVERTISERS

1. 1. THE PERSONAL INFORMATION WE COLLECT

Throughout this Policy, we use the term “personal information” to mean information that directly or indirectly identifies you or is reasonably capable of being associated with you.  The table in this Section lists the categories of personal information that we collect and have collected in the last 12 months (including “sensitive personal information as that term is defined in applicable privacy laws); the categories of sources from which we collect personal information; and our purposes for collecting the information.

Under some privacy laws, certain types of personal information listed above are considered “sensitive personal information” and are protected by additional rights and obligations.  As described in the above table, we collect the following types of sensitive personal information:  portions of your financial account, debit card, or credit card number necessary for us to process your payments in combination with any required security or access code, password, or credentials allowing access to an account (which we use to complete your transactions); login credentials; and precise geolocation (which we use to conduct analytics).  Where required by law, we will obtain your consent before collecting sensitive personal information, or we provide you with a right to limit the use and disclosure of such information, as described in Section 6 (“Your Privacy Rights”). If you provide consent, you may withdraw your consent at any time.  

1. 2. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information from various sources.  For example, we collect and obtain personal information:

• Directly From You.  We collect information that you provide us when you submit it on our Site.  This includes details such as your name, address, phone number, email address, username and password, and portions of your payment card information necessary to process your transactions.  

• When You Contact Us.  If you contact us by phone or email regarding your advertisements or the Advertising Services, we collect information such as your name, email address, telephone number, and other information made available during our interaction.  We keep recordings and transcripts of your calls, chats and communications with us for quality assurance, training, fraud prevention, and customer support purposes.

• Via Digital Tracking Tools.  Like many businesses, we automatically collect information about you through third-party tools and technologies such as browser cookies, flash cookies, pixel tags, server logs, and web beacons (“Digital Tracking Tools”).  These Digital Tracking Tools automatically collect information about you when you interact with us online, or with third parties that use or integrate with our online platforms.  We also use third-party tools known as “session replay” technologies, which allow us to understand how users interact with our online properties.  These tools recreate a “replay” of a user’s online experience, including clickstream and other interactions with our content, which helps us de-bug our Sites, perform analyses, and improve our operations.  For more details about how we use Digital Tracking Tools, please see Section 3.  

1. 3. HOW WE USE DIGITAL TRACKING TOOLS

Like many businesses, we use Digital Tracking Tools to automatically identify, collect and link information about you and your activities over time on various platforms.  Examples of Digital Tracking Tools we use include cookies such as Google Analytics, which provides us analytics and performance measurement services.  

When you interact with us online, these Digital Tracking Tools automatically collect personal information such as: your browser type and settings; device attributes such as type and model; operating system; software and hardware information; IP address; mobile device identifiers; unique device and online identifiers including device serial numbers, IMEIs and UDIDs; Internet Service Providers; MAC address; mobile carriers; entry/exit URLs; your clicks within our Site; language settings; time zones; other software or services in use; the date and time you visit our Site; the areas or pages that you visit; the amount of time you spend viewing or using the Site; the number of times you return to the Site; clickstream, keystrokes, or usage data from our Site; and in some cases, your precise geolocation.  

We use these Digital Tracking Tools, and the data they collect, for purposes such as identifying you; performing analytics; measuring our performance; maintaining the security of our Site; fixing bugs; remembering your preferences; and providing support for basic Site functions.

You may be able to limit or opt out of some Digital Tracking Tools using the following resources:  

• You can remove Google Analytics from your browser by installing the Google Analytics browser add-on, available here.  You can learn about Google’s practices here.  

• Some browsers or operating systems allow you to adjust your settings to limit or block certain Digital Tracking Tools.  You should refer to your browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable cookies, and options for controlling your tracking preferences.  Please note, you may need to separately disable cookies on each browser and device you use to access the Advertising Services.  Some browsers offer a “Do-Not-Track” feature.  We may not respond to Do-Not-Track requests or headers from some browsers.    

• To learn more about your choices with respect to the collection and use of your data by Digital Tracking Tools and participating companies, you can visit the Digital Advertising Alliance’s “Your Ad Choices” opt-out pages, available here and here.  

• You can download the free “AppChoices” app from the Digital Advertising Alliance to control how much information about your interests is used for in-app advertising on your mobile device by participating companies.  More information is available here.

1. 4. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for our business purposes, which include, for example:    

• Providing and improving the Services.  We use your personal information – such as your contact and transaction details – to fulfill, validate and manage your transactions; process payments; and provide and improve our Advertising Services.  We also use personal information to analyze and improve the performance, usage and operations of our Advertising Services using internal or external software and tools; and to better understand who is using the Advertising Services and how.  

• Communicating with you.  We use your personal information – such as your contact information – to respond to your inquiries; to provide you with information about your account and our Advertising Services; and to otherwise communicate with you as needed or permitted to run our business.  

• Performing business reporting, analysis, and research.  We use information about your transaction history with us, your location, and your use of the Advertising Services to engage in reporting, analytics, and research that helps us operate or improve our business.  We also use your information to better understand who is using the Advertising Services; and to help us analyze and improve the performance, usage and operations of our Advertising Services overall.  We use external software providers and tools (such as Google Analytics and Adobe Analytics) to help us perform these assessments.    

• Preventing fraud, complying with applicable laws, protecting our business, and similar purposes.  We may use your name, contact information, IP address, and other personal information to protect the security or integrity of the Advertising Services and our business; to prevent fraudulent activity; to investigate potential security incidents; to assist law enforcement; to protect our rights and/or the rights of third parties; and/or to comply with our legal or regulatory obligations.  We may also use aggregated, anonymized, pseudonymized, or de-identified personal information for any legally permissible purpose.

1. 5. HOW YOUR PERSONAL INFORMATION IS DISCLOSED

In addition to the specific situations discussed elsewhere in this Policy, we disclose your personal information to others for various business purposes.  Recipients of such information include:  

• Service providers, contractors, and authorized vendors.  We disclose your personal information to service providers, contractors, and authorized vendors we use to perform business services for us.  For example, we share your personal information with vendors we use to assist us with processing your payments, analytics, and maintaining our IT, security, and other business systems.  

• Affiliated and related entities.  We disclose your personal information to our affiliates, business units, and/or subsidiaries for operational, promotional, marketing, and other business purposes consistent with this Policy.  In addition, we may sell or purchase business assets during the normal course of operations.  If another entity acquires our business and/or of any of our affiliates, personal information we have collected about you may be transferred to that entity.  If any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to external parties.  

• Legal authorities and consultants.  We may disclose your personal information to government authorities, law enforcement, regulators, insurance providers, consultants, or other authorized parties.  We share your information with these parties to defend or protect ourselves in legal matters, and to comply with applicable laws, regulations, governmental and quasi-governmental requests, investigations, court orders, subpoenas, and other legal processes.  We also share your information with these parties in connection with suspected illegal or fraudulent activity associated with our Advertising Services; to protect against harm to us, to the Advertising Services, or to others; and to detect or protect against security incidents.  

The following table lists the categories of personal information we have disclosed for various business purposes in the last 12 months; the categories of third parties to whom we have disclosed this information; and our purposes for disclosing the information. We do not sell your personal information or share your personal information for cross-context behavioral advertising, and have not done so in the prior 12 months. We also do not knowingly sell or share the personal information of children under the age of 16 and have not done so in the prior 12 months.

1. 6. YOUR PRIVACY RIGHTS

Data privacy laws afford you certain rights with respect to your personal information.  These privacy rights are described below.  If you would like to exercise any of the privacy rights described here, please follow the instructions in Section 7 (“How to Exercise Your Privacy Rights”).  Subject to certain limitations, you have rights to:

• Know/Access Your Personal Information, Confirm Processing, and Receive Portable Data (“Right to Know/Access”):  At or before the point of collection, you have the right to know and access the personal information we have collected about you, including the categories of personal information we collect; the categories of sources from which the personal information is collected; the business or commercial purposes for collecting, selling, or sharing personal information; the categories of third parties to whom we disclose personal information; and the specific pieces of personal information we have collected about you.  This includes the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the information to a person without impediment, where the processing is carried out by automated means.

• Delete Your Personal Information:  You have the right to request that we delete your personal information (subject to certain exceptions, such as other laws that may require us to preserve certain information). 

• Correct Your Personal Information:  You have the right to request that we correct inaccurate personal information that we maintain about you.

• Opt Out of Sharing for Targeted Advertising and Selling of Personal Information: We do not share your personal information for cross-context behavioral advertising or sell your personal information. We do not knowingly sell or share the personal information of minors under the age of 18.  Please contact us if you have any questions.

• Request Limited Use and Disclosure/Opt-Out/Withdraw Consent for Sensitive Personal Information:  You have the right to request that we limit the use and disclosure of your sensitive personal information to certain permitted purposes under data privacy laws, such as (i) to provide the goods or services reasonably expected by an average consumer who requests those goods or services;  (ii) to prevent, detect, and/or investigate security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information; (iii) to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for those actions; (iv) to ensure the physical safety of natural persons; (v) for short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a current interaction with us; (vi) to perform services on our behalf; (vii) to verify or maintain the quality or safety of a service or device; and/or (viii) for purposes that do not infer characteristics about you.  You may also opt-out of the processing of your sensitive personal information or withdraw your consent for us to process your sensitive personal information.

• Opt Out of Automated Profiling: We do not engage in automated processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Please contact us if you have any questions.

• Non-Retaliation/Non-Discrimination:  You have the right not to be discriminated against for exercising your privacy rights.  This includes (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; (e) retaliating against you for exercising your privacy rights; and (f) violating existing United States anti-discrimination laws.

• Right to Appeal: You may appeal a denial of your privacy rights request. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal you may submit a complaint to the Attorney General of your state.

In addition to the above, some states provide additional privacy rights that you may be eligible to exercise. These include:

• Oregon Residents – Right to Obtain List of Third Parties (eff. July 1, 2024):  As of July 1, 2024, if you are an Oregon resident, you will have the right, at our option, to receive a list of specific third parties, other than natural persons, to which we have disclosed your personal information or any personal information.

• California Residents – ‘Shine the Light’ Law: Under California’s “Shine the Light” law, a California resident with whom we have an established relationship has the right to request information about our disclosure of personal information to affiliated companies or third parties for their direct marketing purposes, within the immediately preceding calendar year, subject to certain exceptions.  

• Nevada Residents:  Nevada residents have the right to request that we do not sell certain personal information to select third parties for monetary consideration, even if their personal information is not currently being sold.  

1. 7. HOW TO EXERCISE YOUR PRIVACY RIGHTS

Please follow the instructions below if you would like to exercise your privacy rights.

• Requests to Know/Access, Obtain List of Third Parties, Delete, or Correct Your Personal Information

  To exercise your Rights to Know/Access, Obtain List of Third Parties, Delete, or Correct your personal information, please submit your request through our web form.  If you are unable to submit your request using the web form, you can call us at (866) 683-1102 or email privacy@petco.com for assistance.

  When you submit a request to Know/Access, Obtain List of Third Parties, Delete, or Correct your personal information, we will verify your identity by matching the information provided by you with the information we have in our records.  In some cases, we may need to request additional information in order to verify your identity, or as necessary to process your request or protect against fraud.  If we are unable to adequately verify your identity or the legitimacy of your request, we will notify you or the requester.  If you fail to timely respond to our request to verify your identity, your request may be denied.  Please note that, even if your Right to Delete request is granted, we may retain certain limited information where necessary under applicable law, such as to fulfill a contract with you, to comply with other laws, to prevent fraud, for dispute resolution, to protect information security, and/or to enforce our Terms of Use and other agreements.  You may submit a request to Know/Access at no charge up to two times every 12 months.

  If permitted or required by applicable law, you may designate an authorized agent (which may include a guardian or conservator as used herein) to make a request to Know/Access, Obtain List of Third Parties, Delete, or Correct your personal information on your behalf.  Authorized agents may exercise these rights on your behalf by submitting their request through our web form, selecting “Authorized Agent of Consumer” and following the instructions provided. If an agent submits a request for you, the agent must present signed permission to act on your behalf.  To prevent fraud, you will be required to independently verify your own identity directly with us, and to confirm with us that you provided the agent permission to submit the request. This verification process is not necessary if your authorized agent provides documentation reflecting that the agent is acting as a conservator or has power of attorney to act on your behalf under California Probate Code sections 4121-4130.  

• Requests to Limit the Use and Disclosure of Sensitive Personal Information

  To exercise your Right to Limit the Use and Disclosure/Opt Out/Withdraw Consent for Sensitive Personal Information, please submit your request through our webform. You may also call us at (866) 683-1102 or email privacy@petco.com for assistance.  

  If permitted or required under applicable law, you may designate an authorized agent (which may include a guardian or conservator as used herein) to submit this request on your behalf. Authorized agents may exercise this right on your behalf by submitting their request through our web form, selecting “Authorized Agent of Consumer” and following the instructions provided. If an agent submits a request for you, the agent will be asked to present signed permission to act on your behalf. To prevent fraud, you will be required to independently verify your own identity directly with us, and to confirm with us that you provided the agent permission to submit the request. This verification process is not necessary if your authorized agent provides documentation reflecting that the agent is acting as a conservator or has power of attorney to act on your behalf under California Probate Code sections 4121-4130.  

• Requests to Opt Out of Automated Profiling

  While we do not believe we use your personal information for automated profiling in furtherance of decisions that produce legal or similarly significant effects under applicable privacy laws, in an abundance of caution, we provide you the ability to opt out of automated profiling. To exercise your Right to Opt Out of Automated Profiling, please submit your request through our web form. You may also call us at (866) 683-1102 or email privacy@petco.com for assistance.  

  If permitted or required under applicable law, you may designate an authorized agent (which may include a guardian or conservator as used herein) to submit this request on your behalf. Authorized agents may exercise this right on your behalf by submitting their request through our web form, selecting “Authorized Agent of Consumer” and following the instructions provided. If an agent submits a request for you, the agent will be asked to present signed permission to act on your behalf. To prevent fraud, you will be required to independently verify your own identity directly with us, and to confirm with us that you provided the agent permission to submit the request. This verification process is not necessary if your authorized agent provides documentation reflecting that the agent is acting as a conservator or has power of attorney to act on your behalf under California Probate Code sections 4121-4130.  

• Appealing a Denied Privacy Right Request

  You may be eligible to appeal certain denied privacy rights requests by calling us at (866) 683-1102, emailing privacy@petco.com, or following the instructions we provided by email at the time your request was denied.

• Oregon Residents – Right to Obtain List of Third Parties (eff. July 1, 2024) 

  To exercise this right, please follow the instructions above for submitting a Right to Know/Access request, and enter “Oregon” in the “State of Residence” field in our web form.

• California Residents –  ‘Shine the Light’ Law

  To exercise this right, please contact us by writing to us at Petco, 10850 Via Frontera, San Diego, CA 92127, Attn: Privacy Team: Shine the Light.  

• Nevada Residents

  If you are a Nevada resident and wish to exercise your privacy rights, please email privacy@petco.com.

1. 8. CCPA/CPRA STATISTICS

Each year, we compile and publish information about the number and types of privacy requests we receive under the California Consumer Privacy Act, as modified by the California Privacy Rights Act effective January 1, 2023.  You can click here to view our latest report.

1. 9. HOW TO UPDATE YOUR INFORMATION & COMMUNICATION PREFERENCES

You may correct or update certain personal information by contacting us using one of the methods listed below under “Contact Us.”  

If you would like to stop receiving emails, mail, or other communications from us, please follow the instructions in this Section.  Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable.  

If you do not want to receive emails from us regarding special promotions or offers, you may (i) click the unsubscribe link in the footer of any of our promotional emails; or (ii) contact us using one of the methods in Section 15 (“Contact Us”).  Please note, you may still receive transactional emails from us after unsubscribing to our marketing content.  

1. 10. DATA SECURITY

We have taken certain physical, administrative, and technical steps designed to safeguard the personal information we collect from and about our customers.  However, please be aware that despite these measures, no e-commerce platform, website, application, or system is 100% secure.  You should take reasonable steps to protect your personal information against unauthorized access to your password, phone, and computer by, for example, signing off after using a shared computer; choosing a unique password for each account that no one else knows or can easily guess; and keeping your log-in and password private.  We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

1. 11. RETENTION PRACTICES

We store personal information for as long as reasonably necessary to carry out the purposes for which we originally collected it, and for other legitimate business purposes, including meeting our legal, regulatory, and other compliance obligations.  We have established an internal policy for retiring unnecessary data after the initial purpose for which we collected it has expired, among other factors.  Under that policy, we use several criteria to determine how long we retain your information, including applicable legal requirements; best practices; industry standards and recommendations; storage costs; and similar factors.  

1. 12. TRANSFER OF DATA FROM OUTSIDE THE UNITED STATES

We are located in the United States, and therefore collect, process, and store your information in the United States.  If you use any of our Advertising Services from outside of the United States, information that we collect from or about you will be transferred to and stored on servers inside the United States.  Your use of the Advertising Services or provision of information to us constitutes your consent to the collection, transfer, use, processing, sharing, and storage of your information in the United States.  

1. 13. CHILDREN

Our Advertising Services are directed at a general audience and are not targeted to children.  We do not knowingly collect personal information from children.  If we learn that we have collected personal information from an individual under age 18, we will use reasonable efforts to promptly remove such information. If you believe that we may have information from a child, please contact us at privacy@petco.com.

1. 14. CHANGES TO THIS POLICY

We may revise and update this Policy from time to time.  When we make a material change that affects your privacy rights, we will provide appropriate notice to you by email, by posting the updated Policy on our Sites, or by any other reasonable means.  You will be deemed to have accepted any updates or modifications to this Policy by, among other things, continuing to access or use the Advertising Services.  We encourage you to check this page frequently to review the Policy currently in effect and any changes that may have been made.  If we upgrade, supplement, or replace the Advertising Services with additional offerings or features, this Policy will apply to such upgrades.  

1. 15. CONTACT US

If you have any questions regarding this Policy, you can contact us by emailing privacy@petco.com or writing to us at Petco, 10850 Via Frontera, San Diego, CA 92127, Attn: Privacy Team.