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Owner and Customer Personal Information Policy

Table of Contents

Owner and Customer Information is Confidential

Non-Discrimination

General

Tender-Type

Use of Owner Number and Owner Record

General

Access Discount Eligibility

Purchase Records

Voting Records

Subscriptions & Co-op Contact with Owners

Use of Legally Issued ID

Use of Online Owner Account

Sharing Customer/Owner Information

Contact, Sales, and Survey Information

Security Cameras

Customer Comments

Owner Meeting Participation

Owner and Customer Information is Confidential

Willy Street Co-op, in accordance with the Board of Directors’ Governance Policy B3, only allows proper usage of Owners’ and customers’ personal information. Privacy is important to ensuring a safe shopping experience for everyone. We never sell or rent any Owner or customer information to third-parties.

Additionally, Willy Street Co-op maintains high security standards for all information collected and stored. The Point-of-Sale system and network configuration requires our compliance to PCI standards, which includes the requirement of a computer acceptable use policy (AUP). The AUP is a legally binding document signed by all employees that includes information security and privacy policies. employees, Board of Directors, and committee members with access to sensitive information are also required to signed confidentiality agreements.

Non-Discrimination

General

Any form of discrimination based on age, race, sex, sexual orientation, gender identity, religion, national or ethnic origin, political beliefs, veteran status, disability, or any other category protected by state or federal law is contrary to the principles and policies of Willy Street Co-op. For these reasons, store hours, shelf prices, non-owner sales prices, and Owner benefits available and offered to Owners are the same for all customers regardless of Owner equity invested or tender-type chosen for payment.

Tender-Type

All customers are welcome to use the following tender types: Co-op or vendor issued coupons or vouchers, cash, check, MasterCard, Visa, Discover, FoodShare/QUEST, and at our North location: WIC.

In addition to acting in accordance with non-discrimination and State and Federal regulation, the Co-op prohibits requiring a minimum purchase, requesting personal or financial information, or requesting proof of eligibility for use of FoodShare/QUEST, WIC, or any other nutrition incentive program tender-types. When employees request assistance from supervisors to handle transactions involving these tender-types via page, they may not identify these tender-types as the reason for seeking assistance.

Use of Owner Number and Owner Record

General

In order to apply Owner benefits, sale prices, patronage, equity investments, information about subscriptions to our newsletter or promotional materials, and/or voting history to an Owner’s record, Co-op employees may ask customers to provide their Owner Card or Temporary Shopper Card, Owner number, or name for Owner record lookup. When an Owner number is provided to an Employee verbally, employees may confirm the Owner record by asking or stating the name of the Owner themselves and/or the additional person(s) named on their Ownership record.

Access Discount Eligibility

In order to verify eligibility for the Access Discount Program, employees may ask Owners to verify the balance on a nutrition incentive EBT card; submit a coupon provided by a qualified program; or show verification, confirmation, or statement of enrollment in the public or private programs that are qualifiers for the Access Discount Program. employees are prohibited from making copies of, keeping copies or originals of, or documenting information from any of the qualifiers presented unless the qualifier is a coupon from a program that qualifies an Owner to participate.

Purchase Records

Our Ownership database not only maintains a record of each Owner’s contact information, but also Owner purchases. We use aggregated purchase data and Owner information to improve and enhance our services and product offerings. Use of individual purchase data includes (and is not limited to) providing reminders when Owner Equity payments are due, tracking when Owner Equity is invested in-full, looking up receipts for an Owner upon their or an Employee’s request, and preparing contact lists in the event that we need to contact Owners about product they purchased.

Voting Records

Our Ownership database also maintains records of voting history, and voting history is purged annually. An Owner’s record only contains information about whether they participated in the most recent Owner vote, it does not maintain information regarding the way an Owner voted. Paper ballots submitted are sealed and stored as counted for seven years in accordance with the Co-op’s legal record-keeping standards.

Subscriptions & Co-op Contact with Owners

Each Owner record maintains information about how an Owner prefers to receive our newsletter and promotional materials (by mail or email); these preferences may be changed by the primary Owner on the Ownership account at any time. Items such as the newsletter, the annual report, patronage refunds, or product recall or other notices that are sent to a wide group of Owners may be sent via a third-party. When we use a third-party to contact Owners, they do receive Owner contact information, and the third-party signs a non-disclosure agreement.

Use of Legally Issued ID

The Co-op reserves the right to request a customer’s legally issued identification for reasons including and not limited to purchasing products that have age-restrictions (such as alcohol), and verifying ownership of tender-types presented (for example, check, credit, or debit card).

Sharing Customer/Owner Information

Contact, Sales, and Survey Information

The Co-op and its employees may not share or sell customer or Owner information that includes customer or Owner names, addresses, phone numbers, email addresses, financial information, or any other sensitive data about specific customers or Owners with other customers, Owners, nor any third-parties who are not contracted with the Co-op to conduct business and have not signed a non-disclosure agreement. The Co-op and its employees may share aggregated data, information, and survey responses that do not identify individuals with the public or other entities at the discretion of director-level Co-op management.

If the Co-op, a customer, Owner, or third-party who is not contracted with the Co-op to conduct business requests information that includes any of the information or data cited above as prohibited to distribute, the Co-op must ask affected customers and Owners to opt-in and provide documented consent prior to sharing any of the information or data, or survey responses requested.

Employees may pass on messages from customers, Owners or third-parties to other customers, Owners or third-parties upon request. Customers, Owners or third-parties that wish to share sensitive information or data among each other are welcome to do so upon their own consent.

Security Cameras

All Co-op sites have or may have security cameras, and the images captured are used solely to improve the safety and security on Co-op premises. Information and images captured may be shared internally with Co-op employees for the purposes of training, safety, or theft prevention; and/or with authorities in order to pursue violations of Madison or Middleton municipal code; and/or with insurance companies for the purposes of processing claims; and/or by court order.

Customer Comments

Customer Comments submitted may be made available for review in-store by the public or published in our newsletter. Content on customer comments made available for public will not be edited for grammar, spelling, or punctuation. Owner names and contact information are logged for employees, and removed from any comments or responses publicly posted.  

Owner Meeting Participation

Owner attendance is recorded for all Co-op meetings held in accordance with Co-op Bylaws Section IV: Owner Meetings and Section V: Board of Directors for the purposes of demonstrating a quorum of Owners were present. Minutes from meetings held in accordance with Bylaws IV and V are available to Owners to review upon request and may include attendance records.