Walmart collects sensitive categories of personal information including government ID numbers, health and pharmacy data, precise location, and financial account details, and states it limits the use of this data to purposes disclosed in the notice and permitted by law.
This analysis describes what Walmart'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
The CPRA established specific rights for consumers to limit the use and disclosure of sensitive personal information; the policy's disclosure of sensitive data categories triggers those rights for California residents and creates heightened compliance obligations for Walmart's health and pharmacy data practices.
Interpretive note: Whether Walmart's pharmacy operations qualify as a HIPAA covered entity depends on operational structure and is not explicitly resolved in the privacy notice; the applicability of HIPAA versus state health privacy law requires separate legal analysis.
The policy states Walmart collects government ID numbers, precise geolocation, health and medical information from pharmacy interactions, and financial account details as sensitive personal information; California residents have the right under CPRA to direct Walmart to limit the use and disclosure of this sensitive information to what is necessary to perform the requested service.
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"We collect certain categories of sensitive personal information, including financial account information, government-issued identification numbers, precise geolocation data, health and medical information provided in connection with pharmacy or health services, and information about your race or ethnic origin where voluntarily provided. We use sensitive personal information only for the purposes described in this Notice and do not use or disclose it for purposes other than those permitted under applicable law.Excerpt from Walmart's Privacy Policy
1) REGULATORY LANDSCAPE: CPRA Article 1798.121 grants California consumers the right to limit the use and disclosure of sensitive personal information.
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The CPRA established specific rights for consumers to limit the use and disclosure of sensitive personal information; the policy's disclosure of sensitive data categories triggers those rights for California residents and creates heightened compliance obligations for Walmart's health and pharmacy data practices.
The policy states Walmart collects government ID numbers, precise geolocation, health and medical information from pharmacy interactions, and financial account details as sensitive personal information; California residents have the right under CPRA to direct Walmart to limit the use and disclosure of this sensitive information to what is necessary to perform the requested service.
ConductAtlas has identified this type of provision across 290 platforms. See the full comparison.
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