Automated License Plate Recognition Usage and Privacy Policy

Effective Date: June 1, 2025

At the Kroger Family of Companies (“Kroger,” “we,” “us,” “our”) your safety and trust are important to us. For that reason, we are committed to handling your information in a way that is transparent, fair, and worthy of your trust. This Automated License Plate Recognition (“ALPR”) Usage and Privacy Policy describes how we use, maintain, and disclose information collected by ALPR technology at select retail locations in California.

An ALPR system is a searchable computerized database resulting from the operation of one or more fixed cameras combined with computer algorithms to read and convert images of license plates and the characters they contain into computer-readable data. The information collected by an ALPR system (“ALPR Information”) includes still images of vehicles including the make and model, color, license plates, characters and numbers associated with the license plates, and the date and time when the images were collected.

We collect and use ALPR Information for the following purposes:

• To enhance safety and security, including protecting the health and safety of customers, associates, other businesses, and the public
• To prevent, investigate, and prosecute shoplifting, fraud, and other criminal activities that occur at our retail locations, other businesses, as well as in the community
• For internal business purposes such as risk management, investigations, reporting, and other legal and compliance reasons
• To operate and troubleshoot the ALPR system
• To support law enforcement investigations and operations

We also may use ALPR Information to enforce our rights or as otherwise needed for legal purposes.

We limit internal access to the ALPR Information to authorized individuals who have a legitimate business purpose for accessing the ALPR information (“authorized personnel”). These authorized personnel include:

• Select security, asset protection, and retail operations personnel who use ALPR Information in connection with detecting, investigating, and preventing activities that may violate our policies, be illegal, or otherwise impact the safety and security of our customers and/or third parties.

Authorized personnel are trained on the sensitivity of ALPR Information and the legal requirements concerning access, use, and disclosure of ALPR Information, how to use the ALPR system, as well as who to contact if they believe that the ALPR Information may have been accessed without authorization.

We implement and maintain reasonable security procedures and practices appropriate to monitor and secure the ALPR Information, including appropriate technical, administrative, and physical measures designed to protect information from unauthorized or illegal access, destruction, use, modification, or disclosure. We periodically audit our procedures and practices to confirm that ALPR Information is being collected and used in compliance with our procedures and applicable laws. We keep audit logs of persons who access the ALPR system to protect against unauthorized access and use of ALPR Information.

We will not sell, share, or transfer ALPR Information outside of The Kroger Family of Companies, except in limited circumstances, including:

• To provide service providers with ALPR Information in connection with their performance of services on our behalf; however, these companies are prohibited from using ALPR Information for purposes other than those requested by us or required by law
• We may share information with third parties, such as law enforcement and other businesses, when reasonably necessary to ensure the safety and security of our customers, associates, or the general public; to protect the rights and property of our customers, associates, the public, and other businesses; to comply with legal requirements; or if disclosure is required by law

We regularly review the ALPR Information to ensure its accuracy and correct errors. These measures include both regular technical testing and ongoing human intervention. Retention of ALPR Information. Except as otherwise permitted or required by applicable law or regulation, we will keep your ALPR Information for as long as reasonably necessary to fulfill the purposes for which it was collected or for purposes that are compatible with the purposes that we have previously disclosed.

The official custodian and owner of the ALPR Information and ALPR system is The Kroger Co. If you have questions about this ALPR Policy, please send an email to krogerprivacyoffice@kroger.com and include “ALPR Usage and Privacy Policy” in the subject line of that email.