The policy identifies sensitive personal information categories collected by Walgreens, including health data, financial information, precise geolocation, and account credentials, and states that California residents may request limitation of use to service-necessary purposes.
This analysis describes what Walgreens's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Under CPRA, sensitive personal information is subject to heightened use limitations and consumers have a statutory right to limit its use beyond service delivery. This provision establishes the right but the operational scope of what constitutes service-necessary use for health and pharmacy data in an integrated retail-pharmacy context requires evaluation.
Interpretive note: The operational scope of what Walgreens defines as service-necessary use for sensitive personal information in a combined retail-pharmacy context is not fully specified in the policy text.
The policy now emphasizes California residents' right to limit sensitive personal information use to necessary and proportionate purposes, and removes the mention of racial or ethnic origin data.
View full change record →This provision establishes that Walgreens collects sensitive personal information including health data, precise geolocation, and financial information. California residents are entitled to request that use of this data be limited to purposes necessary for providing requested services under CPRA.
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You can contact us in order to (1) update or correct your personally identifiable information, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the personally identifiable information maintained about you...
Access information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic information transferred to another party.
"We collect and use sensitive personal information, including health and financial data, precise geolocation, and account credentials. California residents may request that we limit the use of sensitive personal information to purposes reasonably necessary and proportionate to providing the services.Excerpt from Walgreens's Privacy Policy
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Under CPRA, sensitive personal information is subject to heightened use limitations and consumers have a statutory right to limit its use beyond service delivery. This provision establishes the right but the operational scope of what constitutes service-necessary use for health and pharmacy data in an integrated retail-pharmacy context requires evaluation.
This provision establishes that Walgreens collects sensitive personal information including health data, precise geolocation, and financial information. California residents are entitled to request that use of this data be limited to purposes necessary for providing requested services under CPRA.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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