Effective Date: October 6, 2025

Overview and Purpose

This Applicant Privacy Policy (“Policy”) sets forth ALDI INC.’s (“ALDI”) data practices for the information it collects from you as a job applicant (“you” or “your”). ALDI will obtain, process, and maintain your Personal Information as described in this Policy and will comply with applicable data protection laws. Note that if you are later employed by ALDI, your employment information will be governed by a separate Personnel Privacy Policy, which you can obtain from MyALDI or your direct leader. Please review the website’s Terms of Use, which also apply to your employment application. For purposes of this Policy, “Personal Information” refers to any data that identifies, relates to, or could reasonably be linked to a consumer or their household.

Scope of the Policy

The Policy applies to the Personal Information that ALDI collects, uses, stores, and discloses in connection with processing your application for employment.

Please note that ALDI may utilize a careers portal that is operated by a third party, in which case your use of the career's portal will be subject to the third party’s privacy practices as disclosed on the portal.

Except as may be specifically required by law, this Policy does not apply to information available from a public source (such as a telephone directory) or to aggregated or de-identified information ALDI may collect about its applicant pool.

Personal Information ALDI Collects

When you apply for a job with ALDI, you will be asked to provide certain Personal Information that is necessary to evaluate your application. ALDI may ask for additional Personal Information if it extends a conditional offer of employment. If you do not provide the requested Personal Information, ALDI’s ability to consider you as a candidate may be limited. If you decide to provide Personal Information that is not requested, all Personal Information you provide is done so voluntarily and with your consent.

Personal Information that ALDI collects from you may include:

• • • Basic personal details (for example, your name)
    • Contact details (for example, your telephone number, email address or mailing address)
    • Employment details (for example, your employment background including current or previous employers, job titles, work experience)
    • Professional details (for example, preferred work location(s), willingness to relocate, authorization to work in the United States)
    • Education information (for example, your level of education, degrees, certificates, or transcripts)
    • Background information, where relevant to the position for which you are applying and permitted under applicable law (for example, employment references, driver’s license number and driving history, or criminal background information, which ALDI will only request if ALDI extends a conditional offer of employment, and only when applicable and permitted by law)Financial information, where relevant to the position for which you are applying and permitted under applicable law (for example tax information)

In addition:

• • • ALDI may ask you to voluntarily provide Personal Information regarding race/ethnicity, gender, and veteran status. However, you are not required to provide this Personal Information, and if you do provide such Personal Information, it will not be considered in the hiring or selection process nor will it be disclosed to recruiters. To the extent you decide to provide any additional Personal Information, you expressly consent and authorize ALDI to handle such Personal Information in accordance with this Policy and applicable law.
    • If you need accommodation(s) to complete the application and/or interview process, ALDI may request additional information to appropriately assess your request and implement any reasonable accommodation(s). Please contact accessibility@aldi.us for additional information. Please note that any Personal Information you provide in this regard will only be used in connection with assessing your request and implementing an accommodation and will not be considered in the hiring or selection process. Please review ALDI’s accessibility statement for more information https://careers.aldi.us/accessibility.
    • Please note that ALDI may also collect Personal Information when you make purchases from ALDI in an individual capacity and outside the context of your employment application. Personal Information collected from you during these transactions is not subject to this Policy, and ALDI will collect, use, store, disclose, and/or otherwise handle any such Personal Information as ALDI describes in its applicable consumer privacy policy, posted at Online Privacy Notice | ALDI US.

Usage Information Collected Automatically

ALDI, its service providers, and/or other third parties may automatically collect and/or store certain information when you visit or interact with ALDI’s employment application portal or otherwise online as a job applicant (“Usage Information”). Usage Information may be stored and/or accessed from your computer, tablet, mobile phone, or other device whenever you visit or interact with the employment application portal. Usage Information may include, but is not limited to:

• • • Your IP address, mobile device identifier and other unique identifiers.
    • Device information, including device model, operating system version, device date and time, mobile network information.
    • Geolocation of your device.
    • How you use and interact with the employment application portal, including pages you visit within the portal, content you view, and your preferences.
    • The URL or job advertisement that referred you to our employment application portal.

Information from Third Party Careers Portals and Other Third Parties

ALDI may receive Personal Information about you from third party careers portals, for example when you apply to one of ALDI’s job postings through that portal. The Personal Information ALDI receives is subject to this Policy. The Personal Information collected and stored by the third-party careers portal remains subject to its privacy policy.

Where permitted by applicable law, ALDI may also receive information about you from other third parties, such as third-party background screening companies, sources of publicly available information, and individuals or entities whose information you provide to ALDI as employment references.

How ALDI May Use Your Personal Information

ALDI may use the Personal Information (including your Usage Information) collected from or about you, for the following business purposes:

• • • Evaluating your employment application, including assessing your skills, qualifications, and professional interests.
    • Verifying your application information and conducting employment, background, and reference checks, where applicable (subject to your consent as required and where authorized by applicable law).
    • Communicating with you about the recruitment process and the status of your application.
    • Keeping records related to the ALDI hiring processes.
    • Creating and submitting reports as required by applicable laws or regulations.
    • Complying with applicable laws, regulations, legal processes, or enforceable government requests.
    • Analyzing and improving ALDI applications and the recruitment process.
    • To protect the rights and property of ALDI, other job applicants, employees, or the public, as required or permitted by law.
    • Preparing related governmental and internal statistics reports.

How ALDI May Share Your Personal Information

ALDI may disclose your Personal Information in the following circumstances:

• • • At your direction: ALDI may disclose Personal Information when an applicant directs it to do so.
    • ALDI Subsidiaries and Affiliates: ALDI is part of an international group of affiliates and subsidiaries, and certain services or business functions may be centralized by one or more affiliates for the whole or part of the ALDI group. As such, ALDI may share Personal Information with its affiliates and subsidiaries for business, analytical, and operational purposes.
    • Third-party service providers: ALDI may outsource some or all of the operations of its business to third-party service providers and may use third parties to act as ALDI’s agents to provide services. Services provided by third parties may include background checking, accounting, legal, recruiting, and other professional services. In such cases, it may be necessary for ALDI to disclose Personal Information to those service providers. In some cases, the third parties may collect data directly from applicants on ALDI’s behalf. ALDI restricts how such third parties may access, use and disclose Personal Information.
    • Legal requests and investigations and to comply with law: ALDI may be required to disclose certain Personal Information to comply with government reporting requirements, laws, or regulations. ALDI may disclose Personal Information when, in its opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of or any legal process issued by any governmental authority or any order of any court of competent jurisdiction. ALDI may also disclose Personal Information when necessary to exercise and defend legal claims and enforce its rights.
    • Business Transfers: As ALDI continues to develop its business, it might sell or buy companies, subsidiaries, or business units. In such transactions, applicant Personal Information, including data relating to prospective employment and recruiting, is typically one of the transferred business assets. Any data transferred will, to the extent required by law, remain subject to the promises made in any pre-existing privacy statement unless you consent to the new privacy policy, which may be required as a condition of employment or of continuing the recruitment process, subject to applicable law in your jurisdiction.

Security of Your Personal Information

ALDI has adopted commercially reasonable security procedures and practices designed to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction, including physical, technical and administrative controls. However, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. ALDI cannot ensure or warrant the security of any information it collects. You provide ALDI personal information at your own risk.

Retention of Your Personal Information

The length of time ALDI retains your Personal Information depends on the status of ALDI’s relationship with you and applicable legal requirements. ALDI will retain your Personal Information for as long as your prospective employment (and, if applicable, employment) with us lasts, and for a certain period after your employment or recruitment process with ALDI has ended. To determine that period, ALDI considers applicable legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether ALDI needs to retain Personal Information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes and/or enforce its agreements.

Changes to this Policy

ALDI reserves the right to amend this Policy from time to time within its discretion. If ALDI makes any material changes to the way it uses or discloses Personal Information, it will notify you were required by law. If required by applicable law, ALDI will afford you the opportunity to consent or to opt out of any new use or disclosure.

Notice to California Residents

California provides additional privacy rights to residents of the state. If you are a California resident, please see our Notice to California Applicants for more information about how to exercise your privacy rights.

Questions About this Policy

Any questions regarding this Policy should be directed to data.privacy@aldi.us for assistance.