Effective Date: January 1, 2024
Depending on where you reside, you may have additional rights. Please refer to the Additional Information for Certain Jurisdictions section below.
1. Scope and Application
2. Definition of “Personal Information”
3. What Personal Information do we Collect?
4. How we Collect Personal Information
5. How we Use Personal Information
6. How we Share Personal Information
7. How we Manage Consent
8. How Can You Change Your Privacy Choices?
9. How we Store and Safeguard Personal Information
10. Children Privacy
11. Additional Information for Certain Jurisdictions
13. Who Can You Contact With Privacy Questions?
“Personal information” is any information that identifies, or could be reasonably associated with, an individual and their household (collectively, “individual” or “you”). This may include, for example, your name, contact information, email address, and information relating to your account with us (as the case may be). It may also include other types of more technical information, but only when this information can identify you as an individual. Information that is aggregated and/or anonymized and cannot be associated with an identifiable individual is not considered to be personal information. Please note that the definition of personal information may differ in various jurisdictions.
We limit the collection of personal information to what is reasonably required to fulfill the purposes for which it was collected. We collect personal information in a variety of ways detailed in the How we Collect Personal Information section.
Personal information we collect may include:
We collect personal information in a variety of ways, including: directly from you, from business partners, from technologies used at our locations, through online technologies (such as when you are interacting with us through our websites and apps), from third-party social networks and other third parties. Circle K encourages you to review the privacy policies of third parties as well. Third parties involved may use tracking methods such as but not limited to cookies to achieve their own business goals and purposes by relating and combining information about your usage of our websites and apps to any other personal information they may have collected on you.
More specifically, we collect personal information in the following ways:
We may collect personal information directly from you in our stores (including through our point-of-sales systems and other in-store interactive tools such as the LIFT screens), by mail, by email, over the telephone, through our websites and apps or in any other direct manner, for instance when you make a purchase, give us feedback on our stores and the products for sale in our stores, participate in a contest or survey, complete a franchise application, or make a request to our customer service.
Circle K offers many programs and services through which we may collect personal information directly from you, for instance: our brands’ main websites (e.g., https://www.circlek.com/, https://www.couche-tard.com/ and http://www.holidaystationstores.com/), gamification websites on which you may participate into a contest, our brands’ main apps (the Circle K, Couche Tard and Holiday apps), the Circle K Inner Circle loyalty program, the Circle K Easy Pay program, the Circle K EV chargers, our subscription services (such as the Car Wash and Sip&Save programs), our interactive LIFT screens at the point-of-sale, contests and sweepstakes or our newsletters.
Occasionally, we may receive personal information from business partners with whom we offer certain products at our stores or to provide certain programs. We may also receive your personal information from other sources with your consent or when authorized by law.
We may collect personal information through various types of technologies used in our stores. These can include video surveillance, sensors or other similar types of systems that we may use from time to time.
With your consent or as permitted under applicable law, we may collect certain types of information electronically when you interact with our websites and apps, emails, social media accounts, online advertising, or through the use of our or a third party’s technologies, which include cookies, web beacons or single pixel gifs or analytics engines. This information helps us understand what actions you take on our websites and apps and allows them to work correctly.
We may combine this information with other information collected in-store or online such as your transaction history. We do this to support our customer understanding using website and mobile analytics and to provide you with more tailored advertising and marketing campaigns. This includes serving interest-based advertising to you, subject to your right to withdraw consent. To learn more about the privacy choices available to you, please visit How Can You Change Your Privacy Choices? section below.
The technologies we use include:
You may delete or disable certain of these technologies at any time via your browser. However, if you do so, you may not be able to use some of the features on our websites. To learn more about the privacy choices available to you, please visit How Can You Change Your Privacy Choices? section below.
We may collect your personal information if you interact with us through our social media pages and accounts (e.g. Facebook, Twitter, Instagram). For instance, we collect the personal information these social media platforms allow us to collect from our followers. We may also collect any content you upload to our social media pages and accounts (including photos or videos).
In certain cases, we may collect personal information from other categories of third parties, but only with your consent or as permitted or required by applicable law. Third parties may include credit report agencies or background check providers.
We may use all categories of Personal Information detailed in the What Personal Information do we Collect? section above to provide you with our programs, products and services, to manage our business operations and make hiring decisions, to communicate offers and information we think might interest you, to generally enhance your customer experience with us, and as otherwise permitted or required by law.
Learn more about how we use your personal information for: PROVIDING OUR PROGRAMS, PRODUCTS AND SERVICES, MANAGING OUR BUSINESSES, MARKETING AND ADVERTISING, and CONDUCTING MARKET RESEARCH AND DATA ANALYTICS.
We use your personal information for the following purposes:
We use your Personal Information in order to provide our programs, products available in our stores and services, for instance:
We use your Personal Information to manage our business, for instance:
We use your Personal Information to market our stores, brands (including Circle K, Couche-Tard, Holiday, Sloche, Provi-Soir, Froster, K Freeze, Polar Pop, etc.), programs, products, services, special offers, promotions, contests or events, and those of third parties who may sell their products within our stores, that we believe may be of interest to you. We may do this in a variety of ways:
If you no longer wish to receive commercial electronic messages, please let us know by following the unsubscribe directions provided in every commercial electronic message. For more information on managing your marketing preferences, see the How Can You Change Your Privacy Choices? section below.
We may use your personal information in order to conduct market research and data analytics by tracking and analyzing your information for the following purposes:
When possible, we will use your information in an aggregated and/or de-identified format.
Learn more about how we may share personal information: WITHIN THE CIRCLE K GROUP, with third party BUSINESS PARTNERS[WF1] , with third party SERVICE PROVIDERS, with academic institutions and research partners for specific RESEARCH projects (such as the Connect Store at McGill Retail Innovation Lab), in the course of a SALE OR TRANSFER OF BUSINESS OR OTHER TRANSACTION[WF2] for OTHER PERMITTED REASONS, and WITH YOUR CONSENT.
We may share your personal information with third party business partners with whom we associate to provide certain products or services. We only share the personal information required for our business partners to offer the relevant products or provide the relevant programs or services.
We may participate in loyalty programs offered by our business partners, such as fuel companies or grocers, and we may need to share personal information about our participating customers to allow them to earn points and redeem rewards at our locations.
In the course of providing our programs, products, services, promotions, contests and events we may share all categories of personal information detailed in the section What Personal Information do we Collect? with third party service providers who perform services on our behalf. These service providers help us operate our business, technology systems and applications, internal procedures, infrastructure and advertising and marketing. They provide services to us, such as fulfilling purchases, processing credit card payments, performing credit checks, sending emails and postal mail, call centres, data hosting, contest administration, providing advertisements, and analytics services (e.g. tracking effectiveness of our marketing campaigns and analyzing usage of our websites and apps).
We may disclose personal information to a third party in connection with a sale or transfer of business or assets, an amalgamation, reorganization or financing of parts of our business (including the proceedings of insolvency or bankruptcy). In the event the transaction is completed, your personal information will remain protected by applicable privacy laws. In the event the transaction is not completed, we will require the other party not to use or disclose your personal information in any manner whatsoever and to completely delete such information, in compliance with applicable laws.
We may disclose information collected in certain selected and clearly identified stores where we conduct research projects with academic institutions and research partners for statistical or scholarly research purposes. When possible, we will share information for such purposes in aggregated and/or de-identified format.
We may disclose to researchers working at the McGill Retail Innovation Laboratory the information collected through video cameras and other sensors deployed in the Connect Store located on the campus of McGill University that provide a frictionless check-out experience or are used to test experimental retail systems and methods, who may use this information, on an aggregated and/or de-identified basis, for research purposes.
Applicable laws may permit or require the use, sharing, or disclosure of personal information without consent in specific circumstances (e.g., when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies). These circumstances include situations when permitted or required by law or when necessary to protect our group of companies, our employees, our customers, or others. If this happens, we will not share more personal information than is reasonably required to fulfill that particular purpose.
Other than the purposes listed above, we may, with your implied or express consent, share or disclose your personal information outside of our group of companies, in accordance with applicable laws.
If you choose not to provide us with certain personal information or if you withdraw your consent, where such withdrawal is available, we may not be able to offer you the programs, products, services, contests, promotions, events or information that you requested or that could be offered to you.
We want you to clearly understand your choices and make informed decisions about your privacy options. There are several options available for you to manage your privacy preferences, including, for example: managing your preferences within your account when applicable, contacting us directly, changing your browser settings on your device, and/or, where available, using third party unsubscribe functionality.
Learn more about how to change your privacy choices WITHIN YOUR ACCOUNT, WHEN YOU REGISTER OR BY CONTACTING US DIRECTLY [WF3] and USING THIRD PARTY UNSUBSCRIBE FUNCTIONALITY.
If you have an account with us, you can update your preferences where customer preference options are available through the relevant program, product or service.
You may opt in to receiving email or SMS marketing communications at the time that you register for our programs, products or services, enter our contests or promotions or any time thereafter through your online account(s). We may also have your implied consent to send you such marketing electronic communications under applicable laws.
You may opt out of receiving email or SMS marketing communications, by clicking “unsubscribe” within any marketing email you receive, following the opt-out instructions provided when you receive a marketing SMS, or, in certain instances, through your online account (if you have created one).
You may also withdraw your consent to other forms of marketing and advertising or to the use of your personal information for market research and analytics by communicating with the applicable Privacy Office as indicated in the section Who Can You Contact With Privacy Questions? Below.
Please note the following regarding withdrawal of consent or changes in your privacy preferences:
With your consent or as permitted under applicable law, we may use third parties (e.g., web companies or social media platforms) that use certain technologies to analyze your browsing behaviour as you visit our websites and apps. You can manage your privacy preferences with respect to certain third parties, such as Google and Facebook, by using the unsubscribe functionality within their platforms. Please note that disabling, blocking or deleting some of these technologies, such as cookies, may cause you to lose the functionality of certain features on our websites and apps.
For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Your web browser or device may also include features or settings that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes; for more information, consult the settings of your browser or device.
We also may embed links to other websites, including social media websites, on our websites and apps. For more information about social media plug-in protocols, such as “Like” buttons on Twitter, Facebook or Instagram and their impact on your privacy rights, please visit the appropriate social media help centre (e.g., Facebook’s Help Center at https://www.facebook.com/help/).
We take the security of your personal information very seriously and are committed to protecting your privacy by using a combination of administrative, physical, and technical safeguards. Your personal information may be stored in foreign jurisdictions, in which case it will be subject to foreign laws. We will store your personal information in accordance with our retention policies or as otherwise required or permitted by law.
We employ organizational, physical and technological measures to protect the confidentiality of personal information and to safeguard personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, in light of, among other things, the sensitivity of the information and the purposes for which it is to be used. These safeguards also apply when we dispose of or destroy your personal information. We use reasonable safeguards to ensure that our service providers protect your personal information wherever it is used or stored.
We implement a combination of policies and internal practices to protect your personal information, including:
Our objective is to prevent any unauthorize access, data loss, misuse, and unauthorized sharing of modification to personal information in our control. We also use these protection measures when we delete or destroy your personal information.
We may share personal information within the Circle K group of companies, including in Canada, the United States and the European Union. Some of our service providers may also access, process or store your personal information outside of the country or the province where we are located and where you reside. As a result, when your personal information is used or stored in a jurisdiction other than where you are residing, it may be subject to the law of this foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction.
We will store your personal information in accordance with our retention policies or as otherwise required or permitted by law, after which your personal information will be securely destroyed or anonymized (so the information no longer identifies you).
We do not knowingly request or collect personal information from children under 14 years of age without prior verifiable consent of his or her parent or legal guardian and complying with any other legal requirements. If we become aware that we have unknowingly collected personal information about a child without verifiable parental or legal guardian consent, we will delete this information from our records or take reasonable steps to de-identify the information.
Section 11.1.1 covers Circle K’s Collection, Use, and Sharing of Personal Information as defined under CCPA and VCDPA. Section 11.2.1 describes your Rights under CCPA and VCDPA. and explains how to exercise those rights.
Generally, we collect, retain, use, and disclose your Personal Information to provide you services and as otherwise related to the operation of our business, the whole as further described above. The “Business Purposes” for which we collect, retain, use, and disclose your Personal Information are the following:
The CCPA’s listed business purposes are:
Our third-party service providers may also use your Personal Information for some or all of the business purposes. Our third-party service providers may themselves engage services providers or subcontractors to enable them to perform services for us, which sub-processing is, for purposes of certainty, an additional business purpose for which we are providing you notice.
The first column of the table below describes the categories of Personal Information we collect about you. The third column of the table describes, as to each category of Personal Information, the third parties with whom we shared your Personal Information for business purposes.
As discussed in detail further below, we do not believe that we have “sold” your Personal Information as that term is defined in the CCPA. As described above, third-party cookie operators (“Cookie Operators”) collect Personal Information that falls under the Identifiers (e.g., cookie ID, IP address, and other online IDs) and Internet Usage Information categories. To the extent we have sold Personal Information, which we do not believe we have, the categories of Personal Information would be Identifiers and Internet Usage information, and the recipients of each category of Personal Information would be Cookie Operators. Please see the section Rights under CCPA and VCDPA. below for information on how to exercise choice with respect to Personal Information collected by Cookie Operators.
Category of Personal Information
Examples within category
Categories of Recipients
1. Identifiers and Contact Information
Real name, alias, postal address, unique personal identifiers, online identifier (such as mobile advertising ID, cookie ID), Internet Protocol address, e-mail address, and account name.
2. Personal Records
Name, signature, description, address, telephone number, and financial information (e.g., payment card information). Some Personal Information included in this category may overlap with other categories.
3. Personal Characteristics or Traits
In some circumstances, we may collect Personal Information that is considered protected under U.S. law, such as age, gender, nationality, race or information related to medical conditions, but only when that information is relevant for our Business Purposes.
4. Customer Account Details / Commercial Information (such as your purchase history)
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
5. Internet Usage Information (such as search or browsing history)
When you browse our sites or otherwise interact with us online, we may collect browsing history, search history, and other information regarding your interaction with our sites, applications, or advertisements.
6. Location Data (such as where you enable location-based features on your device)
If you interact with us online we may gain access to the approximate, and sometimes precise, location of the device or equipment you are using.
7. Audiovisual and Similar Information (such as security camera footage, customer service call recordings)
We may collect audio, electronic, or similar information when you visit our stores or contact us.
8. Inferences from Personal Information Collected
Inferences drawn from Personal Information to create a profile about a Consumer reflecting, without limitation, preferences, characteristics, predispositions and/or behavior.
See section How we Collect Personal Information above.
We provide Consumers the privacy rights under the CCPA and VCDPA as described in this section.
You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and VCDPA and related regulations. Any request you submit to us is subject to an identity verification process (“Verifiable Consumer Request”) as described in the Verifying Your Request section below. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected Personal Information. To make a request to know or delete, please submit your request to us by either:
You may also obtain information on how to make, and may submit, a request by asking a manager at any of our California and Virginia locations, who will refer to these same two methods. Note that some Circle K locations are independently owned and operated by franchisees, in which case a request to us will not include Personal Information collected independently by them that was not shared with us.
Some Personal Information we maintain about consumers is not sufficiently associated with enough Personal Information about the consumer for us to be able to verify that it is a particular consumer’s Personal Information when a Consumer request that requires verification pursuant to the CCPA’s or VCDPA’s verification standards is made (e.g., clickstream data tied only to a pseudonymous browser ID). We do not include that Personal Information in response to those requests. If we cannot comply with a request, we will explain the reasons in our response. You are not required to create a password-protected account with us to make a Verifiable Consumer Request. We will use Personal Information provided in a Verifiable Consumer Request only to verify your identity or authority to make the request and to track and document request responses, unless you also gave it to us for another purpose.
We will make commercially reasonable efforts to identify Consumer Personal Information that we collect, process, store, disclose and otherwise use and to respond to your California or Virginia Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee, or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.
In order for us to look into your request, we first need to verify your identity, meaning that we need to make sure that you are the consumer we may have collected Personal Information about or a person who has been duly authorized to make the request on behalf of the consumer.
To verify your identity, we ask that you to provide us with, at a minimum, your full name and phone number or email, and the nature in which you have transacted or interacted with us (e.g., in store or online, or both). Depending on the nature of the request and whether we have the phone number or email address you have provided in our systems, we will request further information from you in order to verify that you are the consumer about whom we have collected information.
For a specific pieces request and a request to delete important data, we are required to verify a consumer’s identity to high degree of certainty, which may include matching at least three data points provided by the Consumer with data points maintained by us (and which we have determined to be reliable for the purpose of verifying the consumer), together with a signed declaration under penalty of perjury that the requestor is the consumer whose Personal Information is the subject of the request. If we cannot verify you to that standard, we will treat the request as a categories request or a standard deletion request, for which we require a reasonable degree of certainty based on matched data. If we are unable to verify you to that standard, we will refer you to this U.S. State Notice.
You may designate an authorized agent to submit your consumer request on your behalf by submitting a request in the manners described above. If you are an authorized agent who would like to make a request, we are required to ensure that a right to know or deletion request made by an agent is a Verifiable Consumer Request and allows us to request further information to ensure that the Consumer has authorized the agent to make the request on their behalf. Generally, we will request that an agent provide proof that the Consumer gave the agent signed permission to submit the request and we also may require the Consumer to either verify their own identity or directly confirm with us that they provided the agent permission to submit the request.
(i) Right of Access.
(ii) Right Rectification.
(iii) Right of Deletion.
(iv) Right to Opt-Out of Sales.
(v) Right to Non-Discrimination for Exercise of Privacy Rights.
(vi) Right of Restriction.
(vii) Right of Portability.
(viii) California “Shine the Light” Notice.
We comply with California Civil Code Section 1798.83 (the “Shine the Light” law) by not sharing your Personal Information with third parties for their direct marketing purposes (as those terms are defined by that law) without your consent. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us in the following ways:
Please note that the CCPA and Shine the Light are different laws offering different rights and requests must be made separately.
We do not believe we “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. Though we do not believe we sell covered information, Nevada’s law requires us to provide a method for Nevada consumers to make requests to opt out of sale, which you can do by visiting our request portal: Individual Rights Request Form.
If you wish to request access to or correction of your personal information in our custody or control, you may contact the applicable Privacy Office as described in the Who Can You Contact With Privacy Questions? section. Your right to access or correct your personal information is subject to applicable legal restrictions. Upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. We may take reasonable steps to verify your identity before granting access or making corrections.
If you have any questions about how we handle your personal information, please contact us as indicated below. If you have a program, product, service, or are participating in a promotion, contest or event that is offered by us with a third party, the third party may hold your personal information. If you have any questions or concerns, we will direct you to the appropriate party so that you may make enquiries as to that party’s privacy policies and practices.
By mail: If you are in the U.S.
Legal Department c/o Privacy Officer
Circle K Stores Inc.
1130 West Warner Road, Building B
Tempe, Arizona 85284
If you are in Canada
Legal Department c/o Privacy Officer
Alimentation Couche-Tard Inc.
4204 Industriel Boulevard
Laval, QC H7L 0E3
Toll-free number: 1-833-662-0510
Request Form: Individual Rights Request Form