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ONLINE PRIVACY AND SECURITY POLICY

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Health and privacy.
We protect both.
You trust us with your health and wellness needs, and we take that
responsibility seriously. That includes making sure your data is safe and
secure, and that you have control.
Build trust
We care for your wellbeing and your needs
Protect privacy
We don't sell your pharmacy information.
Enhance experience
We use data to bring you personalized offers and deals.
The Privacy Policy covers the type of data we collect and how we use it, as well
as your rights as a consumer. Please don’t hesitate to contact us with any
questions.

--------------------------------------------------------------------------------

Walgreens Privacy & Security Policy

Last Updated: June 27, 2022

This Privacy Policy lets you know how we collect, use, share, and protect
information about you. By interacting with Walgreens through our stores,
websites, mobile applications, and any other Walgreens affiliate websites where
you may interact with Walgreens, you consent to the practices described in this
Privacy Policy. Any changes in our Privacy Policy will appear on this page so
that you are aware of the data we collect and how we use it. We will notify you
of material changes to this Privacy Policy by posting on our websites
notification that the Privacy Policy has been revised and by updating the
effective date of the Privacy Policy. For California residents, there is an
"Information for California Consumers" section in this Privacy Policy.

In some circumstances, Walgreens' use of your information will be subject to the
requirements of the Health Information Portability and Accountability Act
(commonly known as "HIPAA"). For example, if you log in to your pharmacy account
and submit information regarding a prescription order, that information is
subject to HIPAA's requirements. In those circumstances, the Walgreens Notice of
Privacy Practices and not this Privacy Policy will apply. If you have questions
about which policy applies to the information you have submitted, please do not
hesitate to Contact Us.

Our Privacy Program

At Walgreens, we are committed to maintaining our customers' privacy. We take
great care to safeguard the information that we collect to maintain our
customers' privacy. We have provided this Privacy Policy to you to describe
information collection and use practices at Walgreens. This Privacy Policy
describes the choices you can make about the way your information is collected
and used.

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Information We Collect

We want you to understand how information you provide to us is collected and
used. When you interact with Walgreens or use our services, we collect certain
information about you and the services you use. An example of using our
"services" would be when you visit one of our stores or websites. We may collect
and store information from you in the following situations:

Information you provide to us directly, including when you:
 * Make an in-store or online purchase, or other transaction with us;
 * Create an account on one of our websites or mobile application;
 * Participate in our loyalty programs;
 * Participate in a contest, sweepstake, promotion, or survey;
 * Correspond directly with us, such as through our websites, postal mail,
   customer service, or dispute resolution mechanisms; or
 * Post a review or comment on one of our websites, or post other user-generated
   content on one of our websites or mobile application.

Information we collect when you use our services, including:
Device Information
 * We may collect device-specific information when you visit our websites or use
   our mobile applications or services. This includes information such as
   Internet Protocol (IP) address, hardware model, operating system, unique
   device identifiers, mobile network information, location data such as zip
   code, the address of referring websites, the path you take through our
   websites, and other information about your session on our websites. We may
   also associate the information we collect from your different devices, which
   helps us provide consistent services across your devices.

Log Information
 * This includes details of how you used our websites or mobile applications
   including clicks and page information such as the address (or URL) of the
   website or mobile application you came from before visiting our website or
   mobile application, which pages you visit on our website or mobile
   application, which browser you used to view our website or mobile
   application, and any search terms entered.
 * Other information from your interaction with our websites, services, content
   and advertising, including computer and connection information, statistics on
   page views, traffic to and from the websites, ad data and other standard
   weblog information.

Precise Location Information
 * When you use our services on your mobile phone or device and enable location
   services on your mobile phone or device browser, we may collect information
   about your physical location through satellite, cell phone tower, WiFi
   signal, beacons, Bluetooth and near field communication protocols ("precise
   location information"). If you use our mobile application, your device may
   share precise location information when you enable location services for our
   application. To learn how to opt-out of sharing your precise location
   information with Walgreens, go to the "Your Choices" section of this Privacy
   Policy. When you use our mobile application, we may also request access to
   your Bluetooth signal from your device. If you enable our mobile application
   to use your Bluetooth signal, we may be able to determine your device's
   in-store location. To learn how to opt-out of sharing your device's Bluetooth
   signal with Walgreens, go to the "Your Choices" section of this Privacy
   Policy.

In-Store Cameras
 * We use in-store cameras for security purposes and for operational purposes
   such as measuring traffic patterns and tracking in-stock levels.

Cookies, Web Beacons and Similar Technologies
 * "Cookies" are small data files that are sent from a website's server and are
   stored on your device's hard drive either for only the duration of your visit
   ("session cookies") or for a fixed period of time ("persistent cookies").
   Cookies may store user preferences and other types of information. We use
   cookies to provide features and services, such as:
    * Remembering your preferences and allowing you to enter your username less
      frequently;
    * Presenting information that's targeted to your interests, including
      Walgreens content presented on another website;
    * Measuring the effectiveness of our websites, services, content and
      advertising; and
    * Providing other services and features that are available only through the
      use of cookies.

 * The Options/Settings section of most internet browsers will tell you how to
   manage cookies and other technologies that may be transferred to your device,
   including how to disable these technologies. You can disable our cookies or
   all cookies through your browser setting, but please note that disabling
   cookies may impact some of our website's features and prevent the website
   from operating properly.
 * A "Web Beacon" is an electronic image placed in the code of a webpage,
   application, or email. We use web beacons to monitor the traffic patterns of
   users from one page to another and to improve website performance, and in our
   emails to understand when our email communications are opened or discarded.

Flash Cookies
 * We may use or engage a third party that uses Local Stored Objects, sometimes
   referred to as "Flash Cookies," and other technologies to collect and store
   information about the use of our services. A Flash cookie is a small data
   file placed on your computer or device using Adobe Flash technology. Flash
   cookies are different from the cookies discussed above because cookie
   management tools provided by your browser will not remove Flash cookies. To
   limit the websites that can store information in Flash cookies on your
   device, you must visit the Adobe website:
   https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.
   html

Information We Collect From Other Sources

We may collect information that is publicly available. For example, we may
collect information you submit to a blog, chat room, or social network. We also
may collect information from other companies, organizations, or third-party
partners. For example, we may receive information about you from a partner when
we jointly offer services or from an advertiser about your experiences with
them. By gathering additional information about you, we can correct inaccurate
information and give you product recommendations and special offers more likely
to interest you.

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How We Use Your Information

Our primary purpose in collecting information is to provide you with a safe,
smooth, efficient, and customized experience. We may use your information in a
variety of ways, including for the following purposes:

Product and Service Fulfillment
 * We use your contact information to respond to your inquiries, fulfill your
   requests and improve your experience.

Our Marketing Purposes
 * We use your information to deliver coupons, mobile coupons, newsletters,
   emails, mobile messages, and social media notifications about our brands,
   products, events or other promotional purposes.
 * We use your information for reporting and analysis purposes. We examine
   metrics such as how you are shopping on our website, in our stores, and on
   our mobile applications, the performance of our marketing efforts, and your
   response to those marketing efforts.
 * We use your information to administer promotions, surveys, and focus groups.
 * We use your information to enable Online Tracking and Interest Based
   Advertising as further described in this Privacy Policy.
 * We use your information to improve your experiences when you interact with
   us.
 * We use your Precise Location Information to provide location based services
   for these marketing purposes. For example, using the Store Locator feature in
   our mobile application can allow you to quickly find the nearest Walgreens
   location.

Internal Operations
 * We use your information to improve the effectiveness of our services, conduct
   research and analysis, or to perform other business activities as needed.

Prevention of Fraud and other Harm
 * We use your information to detect, prevent or investigate potential security
   breaches, fraudulent transactions and monitor against theft.

Legal Compliance and As Necessary or Appropriate Under Applicable Law
 * We may use your information as necessary or appropriate under applicable law,
   to comply with legal process, to respond to such requests from public and
   government authorities (including law enforcement), to enforce our terms and
   conditions, including investigations of potential violations, to detect,
   prevent or otherwise address fraud, security or technical issues, to protect
   our rights, privacy, safety or property, and to allow us to pursue available
   remedies to limit the damages that we may sustain. In matters involving
   claims of personal or public safety or in litigation where the data is
   pertinent, we may use personal information without your consent or court
   process.

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How We Share Your Information:

While we do not directly sell, rent, or loan your personally identifiable
information, we may share your information with companies, organizations and
individuals outside of Walgreens as described below. Please note that certain
state laws have adopted a broad definition of a "sale" and may treat certain of
these disclosures as sales under their definitions. Please see the "Information
for California Consumers" for additional information.

Internally
 * We may share your information with our parent company or affiliates,
   including but not limited to, Walgreens Boots Alliance Inc., Boots Retail USA
   Inc., Walgreens Specialty Pharmacy Holdings, LLC, and Walgreens Specialty
   Pharmacy, LLC DBA Alliance Rx Walgreens Pharmacy.

When We Work With Third Parties
 * We may share your information with affiliated and unaffiliated companies that
   perform tasks on our behalf related to our business. Such tasks include
   analyzing website usage data, customer service, electronic and postal mail
   service, and social and other media services.
 * We may work with other companies who place cookies, tags, and web beacons on
   our websites. These companies help operate our websites and provide you with
   additional products and services.
 * We may also use third-party advertising networks to serve advertisements on
   our behalf. The cookies received with the banner advertisements served by
   these networks may be used to collect and build behavioral profiles by these
   companies to deliver targeted advertisements on our website and unaffiliated
   websites.
 * We may work with other companies who operate their own websites or mobile
   applications, to allow them to offer Walgreens customers the ability to
   connect to Walgreens services. These services give you more options for ways
   to use Walgreens services from websites or applications that are not owned or
   operated by Walgreens.
 * We contract with partner companies to allow Walgreens customers to access one
   of their loyalty program accounts from those partners' websites and/or mobile
   applications. This may include the ability to join a loyalty program, add an
   existing membership, and/or access your account balance.
 * If you participate in a loyalty program component which permits you to
   connect your loyalty program accounts with websites, application and devices,
   including non-Walgreens partners and their websites, application and devices.
   Notwithstanding the uses and disclosures set forth above, Walgreens may use
   or disclose personally identifiable information gathered under one of its
   loyalty programs for improving health, health research, or with your consent.
 * Social Media: Our online services may use social media plugins (e.g., the
   Facebook "Like" button, "Share to Twitter" button) to enable you to easily
   interact with certain social media websites (e.g., Facebook, Twitter,
   Instagram) and share information with others. When you visit our services,
   the operators of the available social media plugins can place a cookie on
   your device enabling such operators to recognize individuals who have
   previously visited our services. If you are logged in to these social media
   websites while visiting our services, the social media plugins allow the
   relevant social media websites to receive information that you have visited
   our services or other information. The social media plugins also allow the
   applicable social media websites to share information about your activities
   on our services with other users of the social media website. We do not
   control any of the content from the social media plugins. We may also
   interact with you on social media platforms. If you contact us on one of our
   social media platforms, request services, or otherwise communicate directly
   with us on social media, we may contact you to interact with you. For more
   information about social media advertising and social media plugins from
   other social media websites, please refer to those websites' privacy and data
   sharing statements.
 * We may share your information with business partners who may offer services
   or products to you. For example, in connection with the Walgreens credit
   card, we share some information with our partner so it can prescreen
   individuals to see if they qualify for offers. You can learn about your
   rights relating to prescreened offers including how to opt out by calling
   1-888-567-8688 or by going to https://www.optoutprescreen.com/.

When Sharing is Required by Law or Helps Us Protect Our Interests
 * We will disclose your information as necessary or appropriate under
   applicable law, to comply with legal process, to respond to such requests
   from public and government authorities, to enforce our terms and conditions,
   including investigations of potential violations, to detect, prevent or
   otherwise address fraud, security or technical issues, to protect our rights,
   privacy, safety or property, and to allow us to pursue available remedies to
   limit the damages that we may sustain. In matters involving claims of
   personal or public safety or in litigation where the data is pertinent, we
   may use or disclose personal information without your consent or court
   process.

When We Work On Business Transactions
 * As we continue to develop our business, we might sell or buy stores or
   assets, or engage in mergers, acquisitions or sale of company assets.
   Personal information may be disclosed in connection with the evaluation of or
   entry into such transactions or related business arrangements, or in the
   course of providing transition of services to another entity as permitted by
   law. In such transactions, customer information generally is one of the
   transferred business assets. Additionally, in the event that Walgreens or
   substantially all of its assets are acquired, customer information will
   likely be one of the transferred assets as is permissible under law.

Non-identifiable or Aggregate information with Third Parties
 * We may share non-identifiable or aggregate information with third parties for
   lawful purposes.

With Your Consent
 * At your direction or request, or when you otherwise consent, we may share
   your information.

--------------------------------------------------------------------------------

Your Choices

By interacting with any of the Walgreens family of companies as described
herein, you consent to the practices described in this Privacy Policy. However,
we want you to know that you do have certain choices with regard to how your
information is collected and used.

Email and Mobile Communications
 * You may choose to stop receiving email and mobile marketing communications by
   changing your preferences online. If you have an online account, log in to
   Your Account and click on Communication Preferences. If you do not have an
   online account, you may click Unsubscribe from the bottom of Walgreens
   emails, and reply STOP to our text messages to stop receiving emails and SMS
   text messages. To request unsubscribing by email, contact
   Customerservice@mail2.walgreens.com.

Mobile Application
 * Push Notifications
   You can opt out from further allowing Walgreens to send you push
   notifications by adjusting the permissions in your mobile device or from the
   Walgreens mobile application.
 * Precise Location Data
   You can opt out from further allowing Walgreens to access precise location
   data by adjusting the permissions in your mobile device.
 * In-Store Location
   You can opt out from further allowing Walgreens to access your Bluetooth
   signal in our stores by adjusting the location permissions in your mobile
   device or from the Walgreens mobile application.

Online Tracking and Interest-Based Advertisements
 * Walgreens engages third-party advertisers to provide interest-based
   advertising on our website, as well as other third-party websites in order to
   display advertising that is relevant to you. These third parties may collect
   information about your use of our services over time and that information may
   be combined with information collected on different websites and online
   services. These third-party advertisers may be participants in the Network
   Advertising Initiative and/or the Self-Regulatory Program for Online
   Behavioral Advertising, which allow users to opt out of ad targeting from
   participating companies. To learn more about interest-based advertising, or
   to opt out of having your web browsing information used by certain
   third-party advertisers for behavioral advertising purposes, go to:
    www.aboutads.info/choices or https://www.networkadvertising.org/choices/.
   
   Please Note: When you "opt out" of receiving interest-based advertisements,
   this does not mean you will no longer see advertisements from Walgreens. It
   means that the online ads that you do see will not be tailored for you based
   on your particular interests. We may still collect information about you for
   any purpose permitted under the Policy, including for analytics and fraud
   prevention.

Our "Do Not Track" Policy
 * Walgreens respects enhanced user privacy controls. We support the development
   and implementation of a standard "do not track" browser feature, which
   signals to websites that you visit that you do not want to have your online
   activity tracked. Please note that at this time Walgreens.com does not
   interpret or respond to "do not track" signals. However, you may set your Web
   browser to not accept new cookies or web beacons, be notified when you
   receive a new cookie, or disable cookies altogether. Please note that by
   disabling these features, your experience on Walgreens.com will not be as
   smooth and you will not be able to take full advantage of our website's
   features. Please see the Help section of your browser for instructions on
   managing security preferences.

Minors
 * If you are under 18 years old and a registered user, you can request that we
   remove content or information that you have posted to our website or other
   online services. Note that fulfilment of the request may not ensure complete
   or comprehensive removal (e.g., if the content or information has been
   reposted by another user). To request removal of content or information,
   please contact us.

Accessing and Updating Your Personally Identifiable Information
 * You can review and update any of the information you have given us by
   emailing us or calling 877-924-4472. Our customer care staff will update your
   information. If you have a Walgreens.com account, you can log in and update
   your information.

Links to Third-Party Websites
 * Our services may contain links to, or otherwise make available, social media
   websites and other third-party services, websites and mobile applications
   that are operated and controlled by third parties. We do not take
   responsibility for the content or the privacy practices employed by other
   websites. Unless otherwise stated, any Information you provide to any such
   third-party website will be collected by that party and not by Walgreens, and
   will be subject to that party's privacy policy (if any), rather than this
   Privacy Policy. In such a situation, we will have no control over, and shall
   not be responsible for, that party's use of the Information you provide to
   them.

--------------------------------------------------------------------------------

How We Protect Your Information
Security Measures
 * Walgreens recognizes the importance of maintaining the security of your
   information. Whether you are shopping on our website, through our mobile
   services, or in our stores, we use reasonable security measures, including
   administrative, technical, and physical safeguards.

Email Security
 * "Phishing" is a common email scam where your email address is used to contact
   you and ask for personally identifiable or sensitive information. Always be
   cautious when opening links or attachments from unsolicited third parties.
   Also know that Walgreens will not send you emails asking for your credit card
   number, social security number or other personally identifiable information.
   If you are ever asked for this information, you can be confident it is not
   from Walgreens.

Children's Personal Information
 * We recognize the importance of protecting children's online privacy. Our
   website and mobile services are intended for a general audience and are not
   directed to children. We do not knowingly collect personal information online
   from children under the age of 13.

--------------------------------------------------------------------------------

Information for California Consumers
If you are a California resident, we are required to provide additional
information to you about how we collect, use and disclose your information that
may be considered "Personal Information" under California Law ("CA Personal
Information"), and you may have additional rights with regard to how we use and
disclose your CA Personal Information. We have included this California-specific
information below.
 * Collection. Consistent with the "Information We Collect" section above, we
   collect certain categories and specific pieces of CA Personal Information
   about individuals who reside in California. In the 12 months prior to the
   date of this Privacy Policy, we collected the following types of categories
   of CA Personal Information, which we will continue to collect:
    * Identifiers: such as name, address, telephone number, email address, age,
      date of birth, username and password for our websites, online identifiers,
      IP address;
    * Characteristics of protected classifications under California or federal
      law: such as sex, gender, age (40 or older);
    * Commercial information: such as products or services purchased, obtained
      or considered, other purchasing or consuming histories or tendencies,
      payment information, health and medical information, health insurance
      information, loyalty program participation information;
    * Internet or other electronic network activity information: such as
      computer and connection information, statistics on page views, traffic to
      and from the websites, ad data and other standard weblog information;
    * Geolocation information: including location data and precise location data
      such as physical location information through the use of our services on
      your mobile phone or device by, for example using satellite, cell phone
      tower, WiFi signal, beacons, Bluetooth and near field communication
      protocols, when you are in or near a Walgreens store;
    * Audio, visual, or similar information: such as photographs you share,
      in-store security video, customer service audio recordings; and
    * Inferences drawn from the above categories of CA Personal Information:
      such as consumer preferences, characteristics, predispositions, and
      behavior.

 * Sources. We may collect certain categories of CA Personal Information from
   you and third parties as described in the "Information We Collect" section
   above. The categories of sources from which we collected CA Personal
   Information in the 12 months prior to the date of this Privacy Policy include
   the following:
    * In our stores (parent, subsidiary and affiliate brands)
    * On our websites and mobile applications (parent, subsidiary and affiliate
      brands)
    * When you communicate with our Customer Care Center
    * Through participation in loyalty programs
    * Third party websites and mobile applications (e.g., websites and
      applications that share information with us or our advertising partners
      regarding your online activities)
    * Data Suppliers (e.g., companies that provide demographics and other
      information regarding consumers)
    * Joint marketing or other commercial business partners
    * Online advertising networks
    * Delivery partners/carriers
    * Social media companies
    * Other service providers
    * Survey providers

   We will continue to collect CA Personal Information from these same sources.

 * Purposes. We collect CA Personal Information for the business and commercial
   purposes described in the "How We Use Your Information" section as described
   above. Specifically, we collect CA Personal Information to respond to your
   inquiries, fulfill your requests and improve your experience; for marketing,
   advertising and promotional purposes; for reporting and analytics; to improve
   the effectiveness of our services, conduct research and analysis, or for
   other internal operations purposes; to detect, prevent or investigate
   potential security breaches, fraudulent transactions and monitor against
   theft.
   Sharing your CA Personal Information for business purposes: As described
   above in the "How We Share Your Information" section, we share information
   for business purposes. In the 12 months prior to the date of this Privacy
   Policy, we shared and we may continue to share the following categories of CA
   Personal Information with third parties who are considered "service
   providers" as defined under California law since we disclose CA Personal
   Information to them for our business purposes.
   * Identifiers: such as name, address, telephone number, email address, age,
     date of birth, username and password for our websites, online identifiers,
     IP address;
   * Characteristics of protected classifications under California or Federal
     Law: such as sex, gender, age (40 or older);
   * Commercial information: such as products or services purchased, obtained or
     considered, other purchasing or consuming histories or tendencies, payment
     information, health and medical information, health insurance information,
     and loyalty program participation information;
   * Internet or other electronic network activity information: such as computer
     and connection information, statistics on page views, traffic to and from
     the websites, ad data and other standard weblog information;
   * Geolocation information: including location data and precise location data,
     such as physical location information through the use of our services on
     your mobile phone or device by, for example using satellite, cell phone
     tower, WiFi signal, beacons, Bluetooth and near field communication
     protocols. If you use our mobile application, your device may share
     location information when you enable location services. We may be able to
     recognize the location of a mobile device in stores through use of
     Bluetooth technology;
   * Audio, visual, or similar information: such as photographs you share,
     in-store security video, customer service audio recordings; and
   * Inferences drawn from the above categories of CA Personal Information: such
     as consumer preferences, characteristics, predispositions, and behavior.
   
   As described above, examples of business purposes include product and service
   fulfillment, internal operations, prevention of fraud and other harm, and
   legal compliance.
   
   The categories of third party service providers to which we may share the
   above described categories include Payment Processing Companies, Data
   Analytics Providers, Fraud Prevention Providers, Cloud Storage Providers, IT
   Service Providers, Professional Service Providers, Delivery Partners, and
   Marketing Companies.
   
   In addition, we may share the aforementioned categories of CA Personal
   Information with third parties involved in the evaluation of or entry into
   the sale or purchase of stores or company assets, mergers, or acquisitions.
   The categories of third parties to which we may share the above described
   categories of CA Personal Information include potential Business Partners or
   Purchasers, Professional Service Providers (e.g., consultants, lawyers,
   accountants), and Data Analytics Providers. In the event of sale, merger, or
   acquisition, customer information (including CA Personal Information)
   generally is one of the transferred business assets, as is permissible under
   law.
   
   Sale of CA Personal Information. As described above in the "How We Share Your
   Information" section, we may share the following categories of CA Personal
   Information with third parties who are considered "third parties" as defined
   under California law since we disclose CA Personal Information to them which
   they may use for secondary purposes. Our disclosure of CA Personal
   Information to the third parties who use the information for secondary
   purposes may constitute a "sale" of CA Personal Information as defined under
   California law.
   
   In the 12 months prior to the date of this Privacy Policy, we shared for
   secondary purposes (which may constitute a "sale" of CA Personal Information
   under California law), and may continue to share, the following categories of
   CA Personal Information:
   
    * Identifiers: such as online identifiers, IP address;
    * Commercial information: such as products or services purchased, obtained
      or considered, other purchasing or consuming histories or tendencies;
    * Internet or other electronic network activity information: such as
      computer and connection information, statistics on page views, traffic to
      and from the websites, ad data and other standard weblog information;
    * Geolocation information: including location data and precise location
      data, such as physical location information through the use of our
      services on your mobile phone or device by, for example using satellite,
      cell phone tower, WiFi signal, beacons, Bluetooth and near field
      communication protocols. If you use our mobile application, your device
      may share location information when you enable location services. We may
      be able to recognize the location of a mobile device in stores through use
      of Bluetooth technology; and
    * Inferences drawn from CA Personal Information: such as consumer
      preferences, characteristics, predispositions, and behavior.
   
   The categories of third parties to which we may sell (as defined by
   California law) the above described categories of CA Personal Information
   include online Advertising Networks, Marketing Companies, Financial Services
   Partners and Social Media Companies.
   
   Opting Out of the Sale of CA Personal Information. You may stop our
   disclosure of your CA Personal Information to these entities for their use
   for secondary purposes by opting-out of the sale of your CA Personal
   Information. You can do so by submitting an opt-out request through this Do
   Not Sell My Personal Information link or by contacting us at 800-925-4733.
   
   * Notice of Financial Incentive. We may provide price discounts, coupons,
     services and other perks for members of our loyalty programs such as
     myWalgreens. Through these offerings, consumers may provide us with any or
     all of the categories of CA Personal Information set out above in the
     "Collection" section depending on how they choose to interact with us when
     and after they opt-in to our programs. There is no obligation to opt-in and
     consumers may opt-out at any time. The details of each program are
     contained in the program offering. We offer these programs, among other
     things, to enhance our relationship with you so you can enjoy more of our
     products/services at a lower price. We invest heavily in our marketing and
     brands, in part, so we can provide programs to our customers. Consumer data
     is more valuable to our business when it is combined with a sufficient
     amount of other consumer data and after it is enhanced by our efforts
     described in this Privacy Policy. The value to our business of any
     individual consumer's data is dependent on a number of factors, including,
     for example, whether and to what extent you take advantage of any
     offerings, whether and to what extent you opt out of any offerings, and
     whether we are able to enhance the data through our efforts described in
     this Privacy Policy. We do not calculate the value of consumer data in our
     accounting statements. We make this good faith estimate for California
     residents. To the extent we create overall value from our programs to our
     business that could be directly or reasonably related to the value of
     customer data, the method for calculating the value would include: (1)
     costs related to maintaining the program including but not limited to IT
     infrastructure, delivery of offers, and skilled marketing teams with the
     appropriate knowledge to enhance customer data; (2) whether the sales
     generated by the program exceeds the cost to us of offering the program
     including value of discounts to customer; and (3) value of the insights we
     are able to create based upon aggregate data.
   * Deidentified Patient Information. We may also disclose information that
     does not identify an individual and cannot reasonably be used to identify
     an individual which is derived from CA Personal Information, as well as
     deidentified protected health information that has been modified to remove
     individually identifiable information in accordance with HIPAA's expert
     determination (also known as "statistician's method") or safe harbor
     deidentification standards.
   
   California Consumer Rights. As a California resident, you have the right to
   ask us for any or all of following types of information regarding the CA
   Personal Information we have collected about you in the 12 months prior to
   our receipt of your request:
   
   * Specific pieces of CA Personal Information we have collected about you;
   * Categories of CA Personal Information we have collected about you;
   * Categories of sources from which such CA Personal Information was
     collected;
   * Categories of CA Personal Information we sold or disclosed for a business
     purpose about you; and
   * The business or commercial purpose for collecting or selling your CA
     Personal Information.
   
   You also have the right to request deletion of your CA Personal Information
   and opt out of the sale of your CA Personal Information.
   
   * Exercising California Consumer Rights. You or your authorized agent may
     submit a request to exercise your California Consumer Rights by using one
     of the following specifically designated methods:
      * Self-service on our digital properties by logging on to your account and
        using the Customer Preference Center
         * Click the following links and confirm your choices:
           Do Not Sell My Personal Information
           Exercise California Consumer Privacy Rights
         * Contacting our Customer Care Center at 800-WALGREENS (800-925-4733)
   
   * Responding to Requests. For requests for access or deletion, we will first
     acknowledge receipt of your request within 10 business days of receipt of
     your request. We provide a substantive response to your request as soon as
     we can, generally within 45 days from when we receive your request,
     although we may be allowed to take longer to process your request under
     certain circumstances. If we expect your request is going to take us longer
     than normal to fulfill, we will let you know.
     
     For requests to stop the sale of your CA Personal Information, we will
     comply within 15 business days after receipt of your request.
     
     We usually act on requests and provide information free of charge, but we
     may charge a reasonable fee to cover our administrative costs of providing
     the information in certain situations. In some cases, the law may allow us
     to refuse to act on certain requests. When this is the case, we will
     endeavor to provide you with an explanation as to why.
   * Requests By Authorized Agents. You may designate an agent to submit
     requests on your behalf. The agent must be a natural person or a business
     entity that is registered with the California Secretary of State.
     
     If you would like to designate an agent to act on your behalf, you and the
     agent will be required to provide us with proof of the agent’s identity and
     proof that you gave the agent signed permission to submit a request on your
     behalf. Additionally, you will be required to verify your identity by
     providing us with certain CA Personal Information as described above or
     provide us with written confirmation that you have authorized the agent to
     act on your behalf.
     
     Please note that this subsection does not apply when an agent is authorized
     to act on your behalf pursuant to a valid power of attorney. Any such
     requests will be processed in accordance with California law pertaining to
     powers of attorney.
   * Requests for Household Information. There may be some types of CA Personal
     Information that can be associated with a household (a group of people
     living together in a single dwelling). Requests for access or deletion of
     household CA Personal Information must be made by each member of the
     household. We will verify the identity of each member of the household
     using the verification criteria explained above and will also verify that
     each household member is currently a member of the household.
   * Verification of Requests. After you submit a request to exercise a
     California Consumer Right as described above (other than a request to stop
     the sale of your CA Personal Information), you will enter into a two-part
     verification process.
     
     For part one, you must verify your identity by correctly answering
     demographic questions powered through Lexis Nexis®, and/or confirming
     control over the phone number and/or email or postal address you provide in
     the request form.
     
     If you successfully complete the Lexis Nexis® identity verification and/or
     the phone and/or email or postal address verification, you will proceed to
     part two of the process in which we will attempt to match the data provided
     in the request form to the data we maintain. Depending on the type of
     request submitted, if you are matched to a high degree of certainty your
     request will be processed as follows:
     
     (a) Access request: Your access report will include the specific pieces of
     CA Personal Information not otherwise subject to an exception pursuant to
     law that we match to you.
     
     (b) Deletion request: All data matched to you and not otherwise subject to
     an exception pursuant to law will be deleted.
     
     If you fail Lexis Nexis® identity verification, but successfully complete
     phone and/or email or postal address verification you proceed to part two
     of the process in which we will attempt to match the data provided in the
     request form to the data we maintain. Depending on the type of request
     submitted, if you are matched to a reasonable degree of certainty you
     request will be processed as follows:
     
     (a) Access request: Your access report will include the categories of CA
     Personal Information we match to you unless otherwise subject to an
     exception pursuant to law
     
     (b) Deletion request: Certain limited data we associate to you will be
     deleted.
     
     If you fail Lexis Nexis® identity verification as well as phone and/or
     email and postal address verification, your request will be cancelled and
     you will be notified.
   
   Nondiscrimination. Should you wish to request the exercise of your rights as
   detailed above with regard to your CA Personal Information, we will not
   discriminate against you. To the extent you provide CA Personal Information
   in connection with programs such as myWalgreens, additional information about
   the terms applicable to those programs, including our use of CA Personal
   Information in exchange for the applicable financial incentives, can be found
   in the terms and conditions for those programs and in the Notice of Financial
   Incentive section above.
   
   No Sale of Minors' Personal Information. Additionally, California law
   requires California residents under the age of 16 to opt-in to the sale of CA
   Personal Information. We have protections in place to prevent the sale of,
   and do not intend to and have no actual knowledge that we sell the CA
   Personal Information of California residents under the age of 16. As a
   result, certain programs and services may be unavailable to California
   residents under the age of 16.
   
   Metrics. California law requires recording of metrics regarding Access
   requests, Deletion Requests, and Opt-out requests submitted by California
   residents pursuant to the California Consumer Privacy Act. The metrics below
   reflect the time period from January 1, 2021 to December 31, 2021.
   
   * Access Requests
      * Request Received: 406
      * Completed: 109
      * Expired/Rejected: 297
      * Median Days to Fulfill: 31
   
   * Deletion Requests
      * Requests Received: 664
      * Completed: 276
      * Expired/Rejected: 388
      * Median Days to Fulfill: 24
   
   * Opt-out Requests
      * Requests Received: 56,930
      * Completed: 55,728
      * Expired/Rejected: 1,202
      * Median Days to Fulfill: 0
   
   --------------------------------------------------------------------------------
   
   How To Contact Us:
   
   If you have questions about our Privacy Policy, or to exercise your rights as
   detailed above, except for California Consumer Rights which you may exercise
   by using the designated methods identified in the "Information for California
   Consumers, California Consumer Rights” section above, contact us by:
   
   Phone: (877) 924-4472
   E-mail:   privacy.office@walgreens.com
   Regular mail:
   
   Walgreen Co. Privacy Office
   Attn: Privacy Officer
   200 Wilmot Rd, MS 9000
   Deerfield, IL 60015
   
   To request this Privacy Policy in an alternative accessible format, call our
   Customer Care Center at 800-WALGREENS (800-925-4733).
   
   Effective Date: 10/21/2016; Last Updated: 6/27/2022



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