Privacy Policy

January 13th, 2024

This Privacy Policy describes the types of information ODP Business Solutions, LLC (“ODP” or “us”) collects on this website, our mobile sites, and applications (collectively, the “Sites”), and any other personal information obtained when you call, email, or otherwise communicate with us. By accessing the Sites on any computer, mobile phone, tablet, or other device (collectively, “Device”), making a purchase from ODP, or otherwise interacting with ODP, you agree to the terms of this Privacy Policy. If you do not agree to the policy, please do not use the Sites.

We may modify this Privacy Policy at any time and will post the current version on the Sites. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the information we collect.

For information concerning privacy rights of California residents and our notice at collection, please click here.

Information That We Collect

We collect and store information you provide when you engage with us and our Sites. The information we may collect includes:

• Information that you provide via our website, including information you provide when you register on our website e.g., name, email address, title, company, address, and telephone number, account login credentials.
• Payment information, including name, card issuer and card type, credit or debit card number, expiration date, CVV code, billing address, bank account number and other bank account details.
• Contact information, together with purchase details, delivery details, payment details, and any communications we have received about your order or purchase.
• Name and address of recipient for delivery, if different from yours.
• Communications we have with you, including through requests to contact customer service, sales, or technical support, feedback we receive from you, recordings of your interactions with customer service, and the contact information used to communicate with us. 
• Fraud checks or flags raised about your transactions, the payment card you want to use, payment card refusals, suspected fraud, suspicious activity, complaints, and claims.
• Information about your computer and about your visits to and use of the Sites, such as your Internet Protocol (IP) address, MAC address, demographics, your computers’ operating system, and browser type, device-identifying information, the specific web pages visited during your connection, the domain name from which you accessed the Sites, and geolocation, if you permit our app to access your precise geolocation.
• Information about your browsing behavior, such as the date and time you visit the Sites, the areas or pages of the Sites that you visit, the amount of time you spend viewing the Sites, the number of times you return to the Sites, links that are clicked, mobile device model, identifier or other unique identifier, sites or apps visited before coming to our Site, other site usage data, emails we send that you open, forward, or click through to our Site, and other clickstream data.
• Preference information, including your marketing preferences, your account settings including any default preferences, any preferences you have indicated and the types of services/offers that interest you.
• Non-personal or aggregated information for statistical analysis, research, and other purposes.

Like many commercial websites, we analyze how visitors use our Sites through what is known as “cookie” technology or similar tracking tools. For more information, visit our “Tracking Tools” page, here.

We may combine the information we collect through cookies, web beacons, or other technology tools with other information we have collected from you or information from other sources.

Use of Information

We may use the information we collect from and about you for any of the following purposes: (1) to register you as a customer; (2) to fulfill your requests for products or services, and process and deliver your order; (3) to manage our relationship with you, including to respond to your inquiries; (3) to send you a confirmation email when you make a purchase; (4) to review Site usage and operations; (5) to administer and address problems with the Sites, our business, or our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data); (6) to protect the security or integrity of the Sites and our business, and to detect and prevent fraud; (7) to monitor the Sites for compliance with our Terms of Use and the law; (8) to contact you with Site updates, newsletters and other informational and promotional materials from us and marketing offers about our products and services, as well as products and services offered by other companies; (9) to provide interest-based advertising, relevant website/mobile content, and ads to you based on the way you browse and shop on the Sites and other platforms, and to measure or understand the effectiveness of the advertising we serve to you; (10) for quality, training, and customer service purposes; (11) to use data analytics to improve our website, products/services, marketing, customer relationships and experiences, to customize your experience with us, and to look at site trends and customer interests; and (12) to make suggestions and recommendations to you about goods, products, promotions, offers, or services that may be of interest to you.

If you sign up for our mailing list, we will send you emails about offers or services. At any time, you can ‘unsubscribe’ yourself from our email list simply by clicking the ‘unsubscribe’ button.

If you do not wish to receive communications from us about special offers and promotions, you can opt-out of receiving these communications by following the instructions contained in the messages you receive. Even if you opt-out of receiving these messages, we reserve the right to send you certain communications relating to the services we provide, and we may send you service announcements and administrative messages. We do not offer you the opportunity to opt-out of receiving those communications. For more information about interest-based advertising, including how you can manage advertising, please see below “Interest-Based Advertising.”

Disclosure of Information

We may disclose information collected from and about you as follows: (1) to our related companies and service providers to perform a business, professional or technical support function for us; (2) to our marketing partners, advertisers or other third parties, which may be used to determine the ads and offers you see; (3) as necessary to detect and prevent fraud, and if we believe that there has been a violation of the Site Terms of Use or of our rights or the rights of any third party; (4) to respond to legal process (such as a search warrant, subpoena, or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (5) in the event that our company or substantially all of its assets are bought, sold or otherwise transferred, your personal information may be one of the transferred assets. We may also disclose your personal information with your express consent. We may share aggregate or de-identified information about Site users with third parties.

Please note that if you voluntarily submit any personal information for posting on the Sites, such as a review or a blog post, the information becomes publicly available and can be collected and used by others, so you should use care before posting information about yourself online.

Interest-Based Advertising

We may use third-party advertising companies that use tracking technologies to serve our advertisements across the Internet. For more information, view our “Tracking Tools” page, here.

Retention of Personal Information

Personal information that we collect, access, or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and ODP or as required or authorized by law.

Security

We maintain reasonable and appropriate measures designed to maintain information we collect in a secure manner. We have taken certain physical, electronic, and administrative steps to safeguard and secure the information we collect from visitors to the Sites. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect, and we cannot promise, and you should not expect, that your information will be secure in all circumstances.

Children

ODP sells products and services to other businesses.  Only registered users 18 and older and connected with a partner business are permitted to use the Sites.

Under Age 13

The Sites are not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly by sending an email here, and we will endeavor to investigate and delete such information from our systems.

Third-Party Websites

The Sites may contain links to third-party websites, such as social media sites like LinkedIn, Facebook, and Twitter, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.

Do Not Track

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of certain tracking by websites and online services. We are not currently set up to respond to these signals.

Changes to This Privacy Policy

We may change this privacy policy from time to time, including as required to keep current with rules and regulations, new technologies and security standards. When we do, we will post the change(s) on our Sites. If we change the policy in a material and retroactive manner, we will provide appropriate notice to you.

Your California Privacy Rights

California Shine the Light: California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information.  We do not currently share the personal information of California residents with third parties for their own direct marketing purposes.  However, if you have further questions about our privacy practices and compliance with California law, please contact us as explained below.

California Privacy Rights: If you are a resident of California, the following provisions apply to our processing of information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular business contact of ours subject to the California Consumer Privacy Act of 2018 and other applicable laws (collectively the “Privacy Laws”). For such business contacts, the provisions of this section prevail over any conflicting provisions of this Privacy Policy. We adopt this section of our Privacy Policy to comply with the Privacy Laws of and any terms defined in the Privacy Laws have the meaning set forth in the law of your state of residence when used in this section.

If you are a California resident applying for a job, please click here for information about our privacy practices for applicant information.

Information We Collect

Our Site collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). ODP has collected (or not collected, if indicated below) the following categories of personal information from its consumers within the last twelve (12) months:

Some of this information (including payment card information, account login information, and precise geolocation data) may be considered “sensitive” under certain Privacy Laws. Whether information is sensitive information will depend on the Privacy Laws in your jurisdiction.

ODP obtains the categories of personal information listed above from the following categories of sources:

• Direct interactions. You may give us your information on our Site, by filling in forms, or by corresponding with us by mail, phone, fax, email, webform, or in-person. This includes, but may not be limited to, personal information you provide when you:
  • Purchase our products;
  • Create an account on our Site;
  • Subscribe to our publications;
  • Request marketing be sent to you;
  • Interact with us, including through our Site, app, or customer service;
  • Interact with social media by visiting ODP pages, commenting on or liking posts;
  • Enter a sweepstakes, contest, or promotion, or fill out a survey; or
  • Provide information in-person at events or other venues, or providing information by phone, fax, or email.
• Automated technologies or interactions. As you interact with our Site and app, we may automatically collect data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies. Please click here for further details about cookies and how to opt out.
• Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below:
  • Technical data from the following parties:
    (a) Analytics providers such as Google;
    (b) Advertising networks such as Google Adwords, Bing Adcenter, Amazon ads, and Criteo sponsored ads;
    (c) Social media platforms
  • Data from providers of technical, payment, customer service, and delivery services; and
  • Data from data brokers.

Use of Personal Information

We may use and/or disclose the personal information we collect for one or more of the following business purposes:

• To register you as a customer
• To fulfill your requests for products or services, and process and deliver your order including:
  (a) Managing payments, fees and charges
  (b) Collecting and recovering money owed to us
  (c) Telling you about or handling issues with your orders
• To manage our relationship with you which will include:
  (a) Notifying you about changes to our terms or privacy policy
  (b) Responding to your inquiries, requests, or questions and asking you to leave a review or take a survey
• To enable you to partake in a prize draw, sweepstakes, contest, or promotion, or complete a survey
• To administer and protect our business and this website and for security purposes (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
• To deliver relevant website/mobile content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
• For quality, training, and customer service purposes
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences, to customize your experience with us, and to look at site trends and customer interests
• To make suggestions and recommendations to you about goods, products, promotions, offers, or services that may be of interest to you

We generally use Sensitive Information for reasonably expected purposes, to provide you with services, in connection with your requests, and as authorized by law. For example, we use Geolocation information to show you the nearest store location and to show the store’s inventory.

ODP will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosing Personal Information

ODP may disclose your personal information to a third party for a business purpose.

We disclose your personal information with the following categories of third parties:

• Entities owned in whole or in part by ODP and/or its shareholders
• Authorized distributors and shippers of ODP’s products.
• Service providers acting as data processors
• Analytics providers, ad networks, and social media platforms
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

We may also disclose personal information as necessary if we believe that there has been a violation of the Site Terms of Use or of our rights or the rights of any third party; to respond to legal process (such as a search warrant, subpoena, or court order) and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and in the event that our company or substantially all of its assets are bought, sold or otherwise transferred, your personal information may be one of the transferred assets. We may also disclose your personal information with your express consent. We may share aggregate, de-identified information about Site users with third parties.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, ODP has disclosed the following categories of personal information for a business purpose:

• Category A: Identifiers.
• Category B: Personal information categories listed in certain applicable laws (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other personal information.

In the preceding twelve (12) months, ODP has not disclosed the following categories of personal information for a business purpose:

• Category E: Biometric information.
• Category J: Non-public education information.

Sale or Sharing of Personal Information

In the preceding twelve (12) months, ODP has sold or shared (as these terms are defined under Privacy Laws) the following categories of personal information. (ODP does not knowingly collect, sell, or share the personal information of individuals under the age of 16).

• Category A: Identifiers.
• Category B: Personal information categories listed in certain applicable laws (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))
• Category D: Commercial information.
• Category F: Internet or other similar network activity.
• Category I: Professional or employment-related information.
• Category K: Inferences drawn from other personal information.

Retention of Personal Information

We will store your Personal Information in a form which permits us to identify you, for as long as necessary for the purpose for which the Personal Information is processed.  We may also retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and rights, or if it is not technically reasonably feasible to remove it. We retain information you provide in connection with requests made under the Privacy Laws for a period of two years.

Your Rights and Choices

The Privacy Laws provide residents of California with specific rights regarding their personal information. This section describes your rights under the Privacy Laws, explains how to exercise those rights, and provides information about the response timing and format and your rights to appeal our decisions.

Access to Specific Information, Right to Know, and Data Portability Rights

You have the right to request that ODP disclose certain information to you about our information collection and disclosure practices. You also have the right to request a copy of the specific pieces of personal information we collected about you.  Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you, the categories of information we shared for a business purpose and the categories of information we sold during the prior 12 months.
• The specific pieces of personal information we collected about you since January 1, 2022, subject to certain exceptions.

Deletion Request Rights

You have the right to request that ODP delete your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For example, under certain Privacy Laws, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities and to help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s ability to complete such research, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
• Comply with a legal obligation.

Information Correction Rights

You have the right to request that we correct information that we hold which is inaccurate.  We will require that you provide information about yourself so that we can verify your identity before we can make any change in the information we hold about you and we will use commercially reasonable efforts to make the requested corrections.  In some cases, for instance if you have an account with us, you can update your information by logging into your account.

Please see below for information on how to exercise these rights and response timing and format.

Your Opt-Out Rights

Do Not Sell My Personal Information

You have the right to opt out of the sale of your personal information. Once we receive your request, we will opt you out from the sale of such information. 

Do Not Share My Personal Information

You have the right to opt out of having your personal information shared for cross context behavioral advertising purposes and having your information used for targeted advertising. 

Sharing your personal information means making it available to a third party so that they can use it for cross-context behavioral advertising purposes.

Cross-context behavioral means that we display an advertisement to you that is selected based on personal information about you that we obtained or inferred over time from your activities across other companies’ websites, applications, or online services that we use to predict your preferences or interests.  This does not include using your interactions with us or information that you provide to us for us to select advertisements to show you.

Exercising your rights

Exercising Do Not Sell and Do Not Share My Personal Information Rights
You can opt out of the sale or sharing of information for cross-context behavioral advertising purposes in several ways.

• Visit our online Do Not Sell or Share My Information page here and submit your name, ZIP Code, email address and phone number with your request.  We will use the information you submit for purposes of processing your request.  We act upon your request within 15 days.
• Call our toll-free phone number 1.888.263.3423.  We will ask for your name, ZIP Code, email address and phone number with your request.  We will use the information you submit for purposes of processing your request.  We act upon your request within 15 days.
• In any of Office Depot or OfficeMax stores located in California.
• Activate certain user-enabled global privacy controls, such as a browser plug-in or privacy setting, device setting, or other mechanism, that communicates or signals your choice to opt-out of the sale and sharing of personal information. When we receive such a signal we will stop setting cookies on your browser that involve a “sale” or “sharing” of your personal information, to the extent and as required by Privacy Laws.  This will opt you out of the sale or sharing of information relating to that specific device through cookies to our advertising or analytics partners. Your selections are specific to the browser and device you are using and the website you are visiting.  This option does not stop all sales or sharing of your information because we cannot match your device’s identification or internet protocol address with your personally identifiable information like your name, phone number, email address or ZIP Code. You’ll also need to visit our online Do Not Sell or Share My Information page here to opt out of other ways in which we may sell or share your information. If you delete cookies on your browser, any prior do not sell or do not share signal is also deleted and you should make sure that your user-enabled setting is always activated. You will need to exercise this option on each of our websites that you visit.

This website uses certain third-party tracking tools that collects information about you passively.  In addition to opting out of the sale of data collected by ODP, you may also opt out of the collection of your information by such tools by clicking here.

Exercising Access, Deletion, and Correction  Rights
To exercise the access, deletion, and information correction rights described above, please submit a verifiable consumer request to us by either:

• Visiting our Website Portal available here 
• By calling 1.888.263.3423
• At any Office Depot or OfficeMax store in California
• By sending us an email here

Only you, or an agent that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We will provide a confirmation email to you within 10 days of receipt of a request for access, deletion, or correction.  The confirmation email will explain how we will verify a request which will vary depending on the type of request made.  We endeavor to respond to a verifiable consumer request for access or to delete within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our response to the email address you provided when you made your request.  For a request not to sell or share your information, we will respond as soon as feasibly possible, but no later than 15 days from the date we receive the request.

Any disclosures we provide may only cover the 12-month period preceding a verifiable consumer request. However, you may request that we disclose the required information beyond the 12-month period, and we will honor that expanded request unless doing so proves impossible or would involve a disproportionate effort. Your right to request required information beyond the 12-month period, and our obligation to provide that information, shall only apply to personal information collected on or after January 1, 2022.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance (e.g. Microsoft Excel file and/or Adobe PDF file).

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You may make a request for access twice in any 12 month period.  You may make all other requests at any time.

Non-Discrimination; Notice of Financial Incentive
We will not discriminate against you for exercising any of your Privacy Law rights. Unless permitted by law, we will not:

·       Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Financial Incentives: From time to time, we may offer financial incentives in connection with the collection or use of personal information. The material terms of the financial incentive will generally be presented to you at the time you sign up. You may withdraw from any financial incentive at any time by emailing us at privacysupport@odpbusiness.com.

Contact Us

If you have questions or concerns about this Privacy Policy or how we collect and use the information of our customers, you can contact us by emailing us at privacysupport@odpbusiness.com, or by postal address at:

Attn: Legal Department Privacy Team

ODP Business Solutions

6600 N. Military Trail

Boca Raton, FL 33496