Privacy Policy for ALDI Official Membership

 

Last Update Date2024. 12. 16

Effective Date2024. 12. 16

 

Updates Summary:

We have updated the ALDI Official Member Privacy Policy, mainly as follows:

Added the scenario for customers to use vouchers in physical store

Added the scenario for customers to participate in ALDI Official WeChat group activities

Preface

We recognize the importance of personal information you entrusted to us. This means we are always committed to safeguarding your privacy in accordance with laws and regulations. Therefore, ALDI (China) Investment Co., Ltd has developed this Privacy Policy for ALDI Official Membership ("Privacy Policy") and hereby inform you that this Privacy Policy only applies to the products and/or services provided by ALDI (China) Investment Co., Ltd ("ALDI China") or its affiliates, including ALDI physical stores, "ALDI奥乐齐商城" WeChat Mini Program, "ALDI奥乐齐" WeChat official account and "ALDI奥乐齐" Official WeChat Group. This Privacy Policy does not apply to services provided to you by any third parties, which are governed by a separate privacy policy by the third party.

The handler of the personal information collected under this Privacy Policy is ALDI (China) Investment Co., Ltd with its registered office at Rooms 303-304, Building No. 9, No. 1045 Middle Huaihai Road, Xuhui District, Shanghai.

Please read this Privacy Policy carefully to be fully aware of our policies before using any aforementioned products and/or services provided by ALDI China. Please pay close attention to the Privacy Policy in bold/in bold and underlined and make sure you fully recognize and agree to them before using. In this Privacy Policy, we will explain to you how we collect, use, store, share, transfer and disclose your personal information when you use the products and/or services we provide, and we will inform you of the ways to access, correct, delete your Personal Information. If you have any questions, comments or suggestions regarding the contents of this policy, you may contact us through the contact details set out in this Privacy Policy.

Your consent to this Privacy Policy means you acknowledge that we collect and use your personal information in order to provide you with our products and/or services in accordance with this Privacy Policy, and we will seek your separate consent based on your actual use if it is required under this Privacy Policy.

 

This Privacy Policy is developed and implemented subject to the following principles: Power Matches with Responsibilities, Definite Purpose, Opt-in, Least Necessity, Openness and Transparency, Security Insurance, and Subject Participation. If we need to handle your personal information for purposes other than those set out in this Privacy Policy, we will inform you in a reasonable way and obtain your consent prior to such use.

 

This Privacy Policy will help you understand the following:

1. The Collection and Process of Personal Information

2. Entrustment, Sharing, Transfer and Disclosure of Personal Information

3. How We Protect and Store Your Personal Information

4. Access to and Correction, Deletion and Cancellation of Personal Information, Change in Scope of Authorization or Withdrawal of Consent

5. Cross-Border Transfer of Your Information

6. Protection of Personal Information of Children

7. How We Use Cookies and Similar Technologies

8. Future Updates

Appendix: Relevant Definitions

 

1 The Collection and Process of Personal Information

In order to provide you with our products and/or services, we will collect and handle your necessary personal information. If you refuse to provide corresponding personal information, you will not be able to be provided with the related products and/or services. 

1.1 Become a Member of ALDI

To join ALDI membership and enjoy membership services, you should provide your mobile phone number and a verification code for registration on ALDI Mini Program and becoming an ALDI member. In addition, we also provide you with membership services through our WeChat official account. After you authorize to log in to ALDI Mini Program Store with your WeChat accountwe will obtain your WeChat openid, WeChat unionid, username, user id (ALDI Member code), mobile phone number and log in status accordingly. If you do not wish to become a member, it is not necessary to provide the above information, and you can still browse and search the products and/or services at ALDI Mini Program Store.

At ALDI Mini Program Store, you may fill in and change the following information to help us improve your user experience, such as avatar, screen name, birthday, region, gender, etc. However, if you do not add this information, it will not affect your basic rights of membership.

When you participate in an ALDI membership activities, we may collect the consignee’s name, consignee mobile number, and shipping address for the purpose of sending you activities gifts.

When you join ALDI Official WeChat group or become WeChat friends with Xiaoao, in order to facilitate communication, we may obtain your WeChat avatar, nickname, and WeChat unionid. When you participate in ALDI Official WeChat group activities (for example, you win a prize), the list of winners will include your WeChat avatar and a blurred version of your WeChat nickname.

1.2 Display, Notifications and Marketing of Products and/or Services

To show you the details about ALDI physical stores and the corresponding stock of goods and/or services within the delivery radius, we may ask for your consent to obtain your location at your first login on Mini Program. If you do not authorize us to collect your geolocation, you may type in your shipping address or manually select an ALDI physical store. You can also disable the access to the location of your mobile device, WeChat App or ALDI Mini Program after initial authorization and use a shipping address or manual selection to browse and search for an ALDI physical store.

In order to provide you with more convenient and personalized products and services, as well as to improve your shopping experienceWe may collect your gender, age, order information, behavioral preferences, browsing records, search and favorite records, WeChat unionid, user id(ALDI Member code), phone number, IP Address, device information and service log information, interactions in WeChat Official Account and ALDI WeChat Group, for comprehensive processing and analysis, with the aim to display you personalized pages, send you personalized advertisements or to send you pushes of products and services or other information that you might be interested in.

Please note that separate device information and service log information are unable to identify a specific natural person unless we combine this non-personal information with other information for the purpose of identifying a specific natural person, or we combine it with personal information, in this case, such non-personal information will be treated as personal information during the period of combined use. We will anonymize such information unless your consent is obtained or as otherwise stipulated in laws and regulations.

If you wish to turn off the personalized recommendation services, you can click the "Me" icon at the right bottom corner of ALDI Mini Program to enter into Personal Centre and click the “portrait” icon at the top left corner, click the “My Information", and then click “Personalized recommendation” to disable the services.

In order to provide you with marketing information related to our goods and services, we may collect your  gender, age, order information, behavioral preferences, browsing records, search and favorite records, WeChat unionid, user id(ALDI Member code), phone number, IP Address, device information and service log information, interactions in WeChat Official Account and ALDI WeChat Group,  so as to push our advertisements to you, or make marketing phone calls to provide you with promotional information, event notifications and other marketing information of relevant products.

If you wish to unsubscribe the services of push notification, commercial advertisements and telephone marketing, you can click the "Me" icon at the right bottom corner of ALDI Mini Program to enter into Personal Centre, and click the “portrait” icon at the top left corner, click the “My Information”, and then select “Privacy Settings”, click the “Push Notification and Marketing Service” button to disable the services.

Besides, you can also unsubscribe through our mini program online customer service or through our customer service hotline 400 -820-1973 to unsubscribe the above service.

If you do not wish to receive push messages from ALDI Official WeChat Account, you may click the “portrait” icon in the top right corner of the page and click “unfollow”.

If you do not wish to receive push messages from ALDI Official WeChat Group, you may click  “…” button in the top right corner of the Group page and click on “Delete and Leave”.

If you do not wish to receive push messages from ALDI Enterprise WeChat Account, you may click  “…” button in the top right corner of the page and click on “Delete the contact”.

1.3 Order Placement and Order Management

In order to help you place an order through ALDI Mini Program, you may provide at least the consignee's name, shipping address, consignee's contact phone number, and delivery time slot at ALDI Mini Program Store. Meanwhile, the order contains order information, including information about the goods and/or services you have purchased, order number, order creation time, order amount, order placement time, payment time, shipping time, logistics status, and other order information. You may order goods and/or services for others through ALDI Mini Program. In this case, you need to provide the name, delivery address, contact number of the recipient and the delivery time slot of that order. Please ensure that you have the right to provide the aforesaid information of the actual subscriber. In the case of orders placed for a child, you need to obtain consent from the guardian of the child prior to place the order.

When you place an order for goods and/or services via other channels (ALDI Scan & Go, physical stores), we will put your order information together and display them on ALDI Mini Program to make it more convenient for order management. We collect this information with the aim to facilitate your transaction, ensure the security of your transaction, check your order information, provide customer service and other purposes that we explicitly state.

1.4 Payment for Products and/or Services

In order to complete payment for your order, you shall select a payment method. We need to collect your order information, coupon information, transaction amount and other information required by law, such as anti-money laundering rules, to share with our business partners as a way to confirm your payment instructions and complete the payment.

When you require for an invoice, you need to provide us with the necessary invoice information (invoice title, taxpayer identification number, opening bank, address, telephone number, relevant order and amount) and invoice acceptance information (recipient, contact number, email address).

1.5 Delivery of Products and/or Services

According to your transaction or order information, a service provider will deliver your order. You acknowledge that the service provider will inevitably acquire and use your transaction or order information (purchased product code, purchased product name, purchase time, payment amount, the quantity of goods purchased, order status, consignee’s name, address, consignee’s contact number, delivery time slot) to ensure that the goods and/or services you purchased can be smoothly, safely and accurately delivered.

When your order is shipped, you can contact the deliveryman via a phone call. But in this case, we need to access your phone call. You have the right to deny the authorization, if you do, you will not be able to call a deliveryman, but it will not affect the use of other services we provide.

To keep us informed and confirm the delivery schedule and status in time, you acknowledge that we would collect shipping information (shipping status, order delivered time) from the delivery service provider, and thus provide you with after-sales and dispute resolution services.

1.6 Customer Service and Dispute Resolution

If you bring up any dispute on pre-sales, in-sales or post-sales consultation with online customer service or call center, we may ask for necessary personal information for verification to safeguard your account and the system. If you call customer service directly through the Mini Program, we need to access your phone call. You have the right to refuse that authorization. If you do, you will not be able to call customer service, but it will not affect the use of other services we provide.

In order to contact you, help you resolve your inquiry as soon as possible, or to record the resolution and its outcome, we may keep a record of the communications/call logs and related content between both parties, including member account information, transaction or order information, and any other information you need to substantiate the relevant facts thereto. If you make an inquiry, a complaint or offer advice regarding a specific order, we will consult your member account information and transaction or order information.

We may also use other information about you that is reasonably necessary to provide the service and to improve the quality of the service, including information you provide when you contact customer service, and information you send to us in response to questionnaires in which you participate.

1.7 Your Comment on Products and/or Services

In order to redeem your voucher at an ALDI physical store, we will ask for your permission to enable your device’s location access and request access to your device's camera. If you refuse to grant us permission to collect location information or access the camera/camera, you will not be able to use the corresponding products and/or services.

You may comment the products and/or services through the comment channel or other information distribution method we provide to you. When leaving your comments, you shall at least leave a star rating. In addition, you can enrich the content of your comments with images and other forms with the device camera or photo album permissions enabled. We will collect your comments on products and/or services, including images and texts, and present your username and comment content anonymously. We may use your comments as a reference to improve the quality of our products and/or services.

Please be aware that the information you post publicly may contain personal information or even sensitive personal information about you or others, for example, an image you uploaded may contain personal information. Please consider carefully when you use our services to share or even publicize information. We also reserve the right to block and delete relevant information in lawful circumstances.

1.8 Safety Guarantee

To improve the security of services provided by us, our affiliates and partners, safeguard the personal and property safety of yours, other users or the public, better prevent security risks such as phishing, fraud, cyber vulnerabilities, computer viruses, cyber-attacks, network intrusions, and accurately identify violations of laws and regulations, we may collect information about your device and service log informationWe may use or integrate your member information, transaction information and other basic information that our affiliates or partners have obtained with your consent or is allowed by laws for sharing to comprehensively evaluate possible risk of your account and transactions, and to authenticate personal identity, detect and prevent the security incidents, and take the necessary records, audits, analyses, and treatment measures to ensure the security of the services we provide.

1.9 ALDI Scan & Go

You may use ALDI Scan & Go on ALDI Mini Program to purchase and pay for products and/or service at ALDI physical stores. This feature is based on your device's camera permissions. With this permission enabled, you are able to scan store QR codes and product barcodes to identify information of the store, products and/or services and add the product and/or service to your shopping cart, and later complete your purchase via WeChat Pay or other payment methods.

In order to provide you with a better shopping experience, we may collect and use your personal information for additional services (1.10). If you refuse to provide this information, it will not affect your access to other basic functionalities on ALDI Mini Program such as browsing, searching, purchasing and commenting, but you may not get the user experience of additional services.

1.10 Additional Services

Additional services include:

· Additional services based on location permissions: we will access your location information after you turn on location permissions, but we will not aggregate the locations at all time periods to form a trail of your whereabouts. Based on your location information, we automatically match you with nearby ALDI stores and available products and/or services for delivery.

· Additional services based on camera permissions: you can use this feature to take photos or videos with camera permissions turned on for posting comments, providing proofs for communications with customer service.

· Additional services based on voice recording permissions: you can directly use the microphone to consult and interact with our customer service. In these scenarios, we will collect and store your voice recording to provide you with consultation and pre-sales/after-sales services.

· Additional services with album-based photo/video access and upload permissions: you can use this feature to upload your pictures/videos with album permissions enabled to post comments of products and/or services, communicate with customer service to provide proofs and so on.

 

You understand and agree that the above additional services may require you to enable location information (geolocation), camera (camera), photo album (photo gallery) permissions on WeChat App of your device, as a way to collect and use the information based on these permissions. You can click on the "three dots" button in the upper right corner of ALDI Mini Program and then click on the "Settings" button on the pop-up window to view the status of location information and turn it on or off at any time at your discretion. You can also click "Me" - "Settings" - "Personal Information and Permissions" in the lower right corner of the WeChat main page to enable or disable the corresponding permissions on the system permission management page.  

 

1.11 Others

In case the information you provide contains personal information about other users, you need to ensure that you have obtained the proper authorization before providing such personal information to ALDI Mini Program Store.

If we obtain your information indirectly from a third party, we will ask the third party in writing to collect your personal information with your consent in accordance with the law before collection and inform you of the details of the shared information. Any sensitive information involved must be explicitly confirmed by you before being provided to us. In this case, we will require the third party to make a commitment to the legality and compliance for the source of personal information. In the event of a violation by the third party, we will expressly hold the third party legally responsible for the violation.

We may collect personal information from the information you entered, online communications between you and us, emails, and telephone conversations when you visit our Mini Program (including your registration and purchase at Mini Program Store). We may keep a record of that contact on file. When you use our Mini Program, we may obtain device information about your activities and mobile devices.

 

1.12 Circumstances in Which Consent is not Required for Authorization

You fully understand and agree that your authorized consent is not mandatory for us to collect and use your personal information and that we may not respond to your requests for access, correction, deletion, cancellation of personal information, change in scope of authorization, withdrawal of consent, or requests for information in the following circumstances:

· In connection with the performance of our obligations under laws and regulations;

· Directly related to national security, defense security;

· Directly related to public safety, public health, vital public interests;

· Directly related to criminal investigations, prosecutions, trials and sentence enforcement, etc.;

· To protect the life, property, or other significant legal rights and interests of the subject of personal information or other individuals, but it is difficult to obtain authorization from the person;

· The personal information disclosed to the public by the data subject themselves;

· Necessary for the conclusion and performance of a contract at the request of the data subject;

· Collection of personal information from lawful public disclosures, such as lawful news reports, open government information and other sources;

· Necessary for the maintenance of the safe and stable operation of the products or services provided, such as the detection and disposal of the malfunction of products or services;

· Other circumstances stipulated by laws and regulations.

 

1.13 Sensitive Personal Information

Sensitive personal information refers to the personal information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used, as well as the personal information of minors under the age of 14.

When you use the above products and/or services provided by us, we may collect and handle your sensitive personal information as agreed in this Privacy Policy in accordance with laws, regulations and business needs, and we will specify the corresponding purpose and manner of handling such information in this Privacy Policy and mark it in bold letters. Your confirmation to this privacy policy means that you consent to our handling of your sensitive personal information. If you do not consent to our handling of such sensitive information or need to withdraw your consent, you may set the permissions as indicated in this Privacy Policy. We will no longer handle your personal information and we cannot continue to provide you with the products and services corresponding to the withdrawal of your consent.

If we need to collect and process other sensitive personal information of you which is not specified in this Privacy Policy, we will inform you of the processing purpose and method for collecting such sensitive personal information and seek your separate consent in accordance with the laws and regulations.

2 Entrustment, Sharing, Transfer and Disclosure of Personal Information

2.1 Entrustment

It refers to circumstances in which we delegate third parties. Certain specific modules or functions of our products and/or services are provided by external suppliers. As part of our business operations, we may entrust competent business partners to handle your personal information for the purposes specified in this Privacy Policy only, and the business partners can only access to the limited personal information they need to perform their duties.  We will enter into strict confidentiality agreements with these business partners and demand them to handle personal information pursuant to our requirements, this Privacy Policy and any other relevant confidentiality and security measures. If the business partner processes your personal information beyond the agreed purpose and method of handling, it will obtain your separate consent. When we terminate cooperation with our business partners, we will require them to delete related personal information and cannot store or use it anymore.

We may engage suppliers, service providers and other business partners to process your personal information. These business partners include suppliers of goods and/or services that provide us with goods, technical services, logistics services, payment services, advertising services, data processing. We will only provide your personal information to the extent necessary and reasonable, for example, to logistics companies to complete a delivery or to payment institutions to complete a payment.

2.2 Sharing

We will not share your personal information with any companies, organizations or individuals other than ALDI China, except in the following circumstances:

· We will share your personal information with other parties with your express consent or authorization.

· We may share your personal information in accordance with laws and regulations, or as required by the mandatory order from competent government authorities.

· Share with our affiliated companies: your personal information may be shared with ALDI Commerce (Shanghai) Co., Ltd, ALDI South Group and our other affiliates. We will only share your personal information to the necessary extent, in reasonable quantities and for the purposes stated in this Privacy Policy.

· Share with authorized partners: for the purposes stated in this Privacy Policy only, some of our services may be provided by authorized partners. We may share certain of your personal information with authorized partners in order to provide better customer service and user experience. Currently, our authorized partners include the following types:

 

o   Licensed Partner's SDK or other similar application. Currently, the SDK (Software Development Kit) or other similar applications from authorized partners embedded in ALDI Mini Program Store and Official WeChat Group include:

§ Tencent Map and Location service SDK: collects information about your device's location (GPS location, WLAN access point, Bluetooth, base station and other sensor information), collect your location information, access the network to obtain map services, and use storage privileges to save the map cache, which is used in location-related business scenarios, such as showing you inventory information around your location, facilitating your selection of shipping addresses, and displaying delivery information.

SDK Operator: [Tencent Technology (Shenzhen) Co., Ltd.]

Tencent Map and Location service SDK Privacy Policy: https://privacy.qq.com/document/preview/dbd484ce652c486cb6d7e43ef12cefb0

§ Wehat Open SDKCollect your screen name, avatar , mobile phone number, and realize the functions of sharing and adding to favorites through wechat, wechat login and wechat payment.

Wehat Open SDK Operator:[ Tencent Technology (Shenzhen) Co., Ltd.]

Wehat Open SDK Privacy Policy: https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8 

For companies, organizations, and individuals with whom we share personal information, we will enter into strict confidentiality agreements with them and demand them to handle of personal information pursuant to our requirements, this Privacy Policy and any other relevant confidentiality and security measures.

 

2.3 Transfer

We will not transfer your personal information to any companies, organizations or individuals except in the following circumstances:

· With your express prior consent or authorization;

· In accordance with the provisions of laws and regulations or mandatory governmental or judicial requirements;

· In accordance with agreements (including user agreements signed online) or other legal documents signed with you;

· In the event of a merger, acquisition or liquidation involving the transfer of personal information, we will demand the new company or organization holding your personal information to remain bound by this personal information protection policy, otherwise, we will ask that company or organization to seek your consent again.

We may also use non-personal, non-identifying information for our own research. Under no circumstances will we or any of our affiliates resell your personal information to marketing agencies or any third parties without your express consent. In the event of a merger, acquisition or liquidation involving the transfer of personal information, we will require the new company, entity or organization to continue to be bound by this Privacy Policy, otherwise, we will require that company, entity, or organization to re-solicit your consent.

 

2.4 Disclosure

We will not publicly disclose any of your personal information, except in the following circumstances:

·  With your express prior consent or authorization;

· In accordance with the provisions of laws and regulations or mandatory governmental or judicial requirements.

3 How We Protect and Store Your Personal Information

3.1 Information Protection

We have implemented security measures to protect the personal information you provided to us against unauthorized access, public disclosure, use, modification, damage or loss of your personal information in accordance with the laws and industry standards. We will take all reasonably practicable steps to ensure no unrelated personal information is collected and to protect the collected personal information.

 

We have successfully passed the rating evaluation of Level 3 cybersecurity and obtained a certificate of cybersecurity protection level for the record issued by the public security authorities. At the same time, we regularly hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

 

Given that the Internet is not an absolutely secure environment, we are legally responsible for any unauthorized access, public disclosure, alteration, or destruction of information that result from the failure of our physical, technical management or protective facilities that compromises your legal rights.

 

The Internet is not an absolutely safe environment. When using services at ALDI Mini Program Store, we strongly suggest you not use any communication methods other than those methods recommended by ALDI Mini Program to send personal information. When it is unavoidable that you disclose your personal information to a counterparty or potential counterparty, please protect your personal information appropriately. If you become aware that your personal information, in particular your account number or password, has been leaked, please contact us immediately so that we can act accordingly.

 

In the event of a personal information security incident, we will inform you in a timely manner subject to the requirements of laws and regulations of the basic situation of the security incident and possible impacts, the treatment measures we have taken or will take, the suggestions that you may adopt to prevent and mitigate risks, remedies for this incident, etc. In addition, we will notify you promptly by e-mail, letter, telephone, or push notifications of the circumstances of your case. If it is difficult to inform the data subjects individually, we will publish the information in a reasonable and effective manner. At the same time, we will report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

 

3.2 Information Storage

Your personal information is stored within the territory of the People's Republic of China. We will only retain your personal information for as long as necessary to achieve the purposes described in this Policy, unless an extension period is required, or it is allowed by the laws. When the retention period expires, we will delete or anonymize your personal information as required by law.

4 Access to and Correction, Deletion and Cancellation of Personal Information, Change in Scope of Authorization or Withdrawal of Consent

4.1 Access and Correction

You can access and correct your personal information via the following methods:

· You can log in to ALDI Mini Program, click on the "Me" icon in the lower right corner to enter Personal Centre. You can click on the corresponding icon or text to access your basic information, order delivery information, orders, coupons, points, comments and so on. You can correct or delete your basic information and order delivery information through Personal Centre;

· You can access or clear your search history by clicking on the search bar on the Mini Program;

· If you are unable to access such personal information via the above-mentioned path, you may contact customer service at ALDI Mini Program Store.

If you would like to inquire other personal information arising from your use of our products or services, you can contact customer service at ALDI Mini Program or by calling 4008201973. We may verify your identity, process and respond to your request within a reasonable time.

When you spot an error about your personal information we hold, you have the right to request that we correct or supplement it. You may do so by contacting customer service on ALDI Mini Program or by calling 4008201973. We may verify your identity, process and respond to your request within 15 working days.

4.2 Deletion

The information you can delete or purge directly from our Mini Program pages includes your shipping address, basic personal information and wish list.

In the following instances, you may raise a request to us to delete personal information:

· If our handling of personal information violates laws and regulations;

· If we collect or use your personal information without your consent;

· If we process personal information in a way that violates our agreement with you;

· If you no longer use our products or services, or if you cancel your account;

· If we no longer provide you with products or services;

· Other circumstances as stipulated by laws and regulations.

 

We may verify your identity. If we decide to delete your information at your request, we will at the same time notify the entities that received your personal information from us and request them to delete your information promptly, unless otherwise stipulated in laws or regulations, or unless these entities are independently authorized by you.

When information is deleted from our services, we may not immediately remove the same information from the backup system, but we will delete it when the backup is updated. Please note where the laws and regulations require a longer storage period, or the deletion of personal information is difficult to be realized technically, we will not handle your personal information except for storage and necessary security protection measures.

 

4.3 Cancellation

You can cancel your account at any time by one of the following methods:

· When the ALDI Mini Program is operating, you can click the "Me" icon at the right bottom corner to enter into Personal Centre, and click the “portrait” icon at the top left corner, and then click the "Account Cancellation "to submit the application to cancel your account; or

· When the ALDI Mini Program is operating, you can click the "Me" icon at the right bottom corner to enter into Personal Centre, and click the "Customer Services "to contact customer service or call 4008201973 to apply for account cancellation.

Please refer to ALDI Mini Program Account Cancellation Notice for conditions for account cancellation.  Upon receiving your request for account cancellation, we may verify your identity and respond to your request within 15 working days.   After the cancellation of your account, we will discontinue to provide you with products or services. We will delete or anonymize your personal information at your request, unless otherwise provided by law or regulation, in which case we will no longer use the information in our daily business activities.

 

4.4 Withdrawal of Consent or Change in the Scope of Consent

You may change the extent to which we collect personal information or withdraw your consent by deleting information, turning off your device or software features.

Each business function requires certain basic personal information to be completed (see this Policy 1.1 to 1.10). Your withdrawal of consent will prevent us from continuing to provide you with the corresponding services.

For the collection and process of any non-essential or additional information, you may contact us to give or withdraw your consent, or to change any of the consent for a single service. When you change the scope of these permissions, we will no longer process the personal information for which you have withdrawn your consent. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your consent.

If you withdraw consent to this Privacy Policy in whole, we will cancel your account, please follow the steps in Section 4.3 of this Privacy Policy to cancel your account.

4.5 Constrain information systems to make automatic decisions

In some business functions, we may make decisions based solely on non-human automatic decision-making mechanisms such as information systems, algorithms, etc. If these decisions significantly affect your legal rights and interests, you have the right to request an explanation from us.

 

4.6 Respond to Your Request

If you do not wish to receive the emails from us, you can contact customer service on ALDI Mini Program or by calling 4008201973.

In the above-mentioned requests for access to your personal information, correction, deletion and cancellation of your personal information, withdrawal of consent or changes in the scope of consent, we will respond within a reasonable period of time. In terms of the requests to correct or delete your personal information or to cancel your user account, we will proceed with your request and respond within 15 working days.

For security purposes, you may be asked to provide a written request or complaint, or otherwise prove your identity. We may verify your identity before we process your request.

We will cooperate with your reasonable requests. Requests that are unreasonably repetitive, require excessive technical means, pose risks to the legal rights and interests of others, or are highly impractical, may be denied.

In the following circumstances, we will not be able to respond to your request as required by laws and regulations:

· In connection with our obligations under laws and regulations;

· Directly related to national security, defense security;

· Directly related to public safety, public health, vital public interests;

· Directly related to criminal investigations, prosecutions, trials and enforcement of sentences, etc.;

· We have sufficient evidence of subjective malice or abuse of rights by the data subject;

· In order to protect life, property and other important legal rights and interests of yours and others but it is difficult to obtain authorized consent from the party;

· Responding to your request will result in serious harm to your legal rights or those of other individuals or organizations;

· Regarding our trade secrets.

5 Cross-Border Transfer of Your Information

Generally, personal information collected and generated in the course of our operations in the People's Republic of China is stored within Chinese territory, unless

· The applicable law has express stipulations;

· With your explicit authorization;

· Your personal initiatives such as conducting cross-border transactions via the Internet, etc.

In other cases, in order to provide you with a better shopping experience and to conduct our business, we may provide your personal information (including but not limited to information you provide through personal initiatives such as cross-border transactions over the Internet) to our investors and other affiliates of ALDI South Group outside China.

If it is necessary to transfer personal information across the border, we will inform you of the purpose, the identity of the oversea recipient, the relevant security measures and other contents as stipulated by relevant laws , and seek your separate consent in advance. We will strictly comply with the requirements of relevant laws and regulations, and we will take all reasonable and feasible measures including anonymizing or de-identifying personal information as far as possible to protect your personal information.

6 Protection of Personal Information of Children

We attach particular importance to the protection of the personal data of minors. Children under the age of 14 shall not create their own user accounts without the consent of their guardians. We suggest that children use our Mini Program only with the consent of their guardians. In cases where personal information is collected from a child with the consent of a guardian, we will only use or disclose this information as permitted by law or as necessary to protect the child. If we find out that we have collected personal information from a child without the prior consent of the guardian, we will attempt to delete the information as soon as possible. You may also make a request to us for correction or deletion. If you have any questions, suggestions or complaints about matters related to children's personal information, you may contact us through the methods provided in this Privacy Policy.

7 How We Use Cookies and Similar Technologies

7.1 Cookie

In the future, ALDI China or its affiliates may set up websites to provide you with products and services. With the aim to make the websites work properly, provide easy access and recommend content you might be interested in, we will save local cache in the name of Cookie or Flash Cookie or identifiers, site names, numbers and characters (collectively, "cookies") provided by the browser or associated applications on your computer or mobile devices. Cookies allow websites to store data of the items in your shopping cart.

7.2 Cookie-Alike Technologies

In addition to cookies, we may also use cookie-alike technologies on our websites or on ALDI Mini Program.

For example, we may cache some of your login and location information in order to improve your user experience when using our Mini Program.

8 Future Updates

As our business continues to thrive, we will review and modify our policies regularly. We reserve the right to change our Privacy Policy from time to time. When the purpose, manner and scope of our collection and use of personal information changes, we will post an updated version of the Privacy Policy on ALDI Mini Program and remind you to read it via push notification, email, pop-up or other means. We will collect, use, share, and store your personal information in accordance with the updated Privacy Policy only after you click to give your consent. The updated Privacy Policy will apply to all our customers regardless of when we collect your personal information.

If you have any questions about our Privacy Policies, or if you have any inquiries or complaints, please contact us on 4008201973 or via online customer service. We will consider and respond to all inquiries and complaints in writing within 15 working days.

Appendix: Definitions

ALDI physical stores: physical stores invested and operated by ALDI (China) Investment Co., Ltd and its affiliated companies in the People’s Republic of China.

ALDI奥乐齐商城: “ALDI奥乐齐商城” Mini Program on WeChat App.

ALDI奥乐齐: WeChat official account “ALDI奥乐齐” on WeChat App.

ALDI奥乐齐Official WeChat Group: the "ALDI奥乐齐" member benefits group running on the WeCom App.

ALDI Official Members: A member registered with ALDI’s own official channels, including ALDI Physical stores, "ALDI奥乐齐商城" WeChat Mini Program.

Personal information: refers to all kinds of information recorded electronically or in other ways that can independently or in combination with other information identify a specific natural person or reflect the activities of a specific natural person.

Affiliated Companies: refers to companies that have direct or indirect control relationship or equity relationship with ALDI China including but not limited to ALDI Commerce (Shanghai) Co., Ltd, ALDI South Group, etc.

Children: minors that are under 14 years old.