Privacy Policy

Effective Date: June 23, 2020

Your privacy is important to Alimentation Couche-Tard Inc., Couche-Tard Inc., Circle K Stores Inc., Mac’s Convenience Stores Inc., Mac’s Convenience Stores LLC, Holiday Stationstores, LLC, TMC Franchise Corporation and their subsidiaries and affiliates in Canada and the United States (collectively, “Circle K”, “we”, “us” or “our”). In the United States and Canada, our stores are primarily operated under the Couche-Tard, Circle K, Holiday, Mac’s, Corner Store, Kangaroo Express and On the Run banners (for more information about our banners, please visit: https://corpo.couche-tard.com/en/our-company/our-brands/). This Privacy Policy applies to our activities in Canada and the United States and describes our practices with respect to the collection, use and disclosure of personal information, as well as any rights you may have with respect to your personal information (as defined in the Definition of “Personal Information” section).

If you are a California consumer, you may have additional rights under the California Consumer Protection Act (“CCPA”), as detailed in the California Consumers section.

Table of Content

Scope and Application
Definition of “Personal Information”
What Personal Information do we Collect?
How we Collect Personal Information
How we Use Personal Information
How we Share Personal Information
How we Manage Consent?
How Can You Change Your Privacy Choices?
How we Store and Safeguard Personal Information
Accessing and Correcting Your Personal Information
Children Privacy
California Consumers
Changes To Our Privacy Policy
Who Can You Contact With Privacy Questions?

1. Scope and Application

This Privacy Policy relates to the personal information collected by Circle K. This Privacy Policy applies whenever you interact with us, including when you visit our stores, visit one of our websites or use one of our mobile applications on which this Privacy Policy is posted, sign up to be a part of any of our programs (for example, we may offer loyalty programs in certain jurisdictions), enroll into one of our subscription services (for example, our Car Wash subscription service) promotions, contests or events, apply for or purchase our products or products from our stores, apply to become a franchisee or otherwise receive our services. If you are a job candidate, please review our Privacy Notice for Candidates.

2. Definition of “Personal Information”

“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 de-identified and cannot be associated with an identifiable individual is not considered to be personal information.

3. What Personal Information do we Collect?

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.

Learn more

Personal information we collect may include:

View Summary

4. How we Collect Personal Information

We collect personal information in a variety of ways, including: directly from you, from other sources, from technologies used at our locations, through online technologies (such as when you are interacting with us through our websites and apps) and from third-party social networks.

More specifically, we collect personal information in the following ways:

a. Directly From You

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.

For example:

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 Easy Rewards loyalty program app, our subscription services apps (such as the Car Wash app), our interactive LIFT screens at the point-of-sale, in-store and social media contests and sweepstakes or our newsletters.

b. From Business Partners

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.

For example:

c. Automatically From Technologies Used At Our Locations

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.

For example:

items they take. This allows us to better understand in-store customer experience and to allow our customers who have signed up for frictionless check-out services to make purchases without having to go through the cashier.

d. Through Online Technologies

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?

For example:

The technologies we use include:

checks, as well as unique online identifications such as IP address, and sends that data to Google for analysis.

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?

e. Third-Party Social Networks

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 the respective social media platforms allow us to collect from our followers. We may also collect any content you upload to our social network pages (including photos or videos).

In addition, third-party social networks that provide interactive plug-ins to enable social network features (e.g., to connect to Facebook) on our websites and apps may use cookies to gather information on your use of the websites and apps. How this collected data is used by a third party is dependent on the privacy policy of the social network which is available on the appropriate parties’ website. Circle K encourages you to review the privacy policies of third parties as well. Third parties involved may use these 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. We may also obtain and use analytical and statistical information from third-party social networks to help us measure performance and effectiveness of content we display on social networks, for example, by measuring impressions and clicks on the content Circle K promotes.

f. From other Third Parties

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.

View Summary

5. How we Use Personal Information

We may use all categories of personal information detailed in section 3 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 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:

a. Providing our Programs, Products and Services

We use your personal information in order to provide our programs, products available in our stores and services, for instance:

b. Managing Our Businesses

We use your personal information to manage our business, for instance:

c. Marketing and Advertising

We use your personal information to market our stores, brands (including Circle K, Couche-Tard, Holiday, Sloche, Provi-Soir, Circle K Froster, 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 How Can You Change Your Privacy Choices?

d. Conducting Market Research and Data Analytics

We may use your personal information in order to conduct market research and data analytics by tracking and analyzing current or previously collected information for the following purposes:

When possible, we will use your information in an aggregated and/or de-identified format.

View summary

6. How we Share Personal Information

We may share your personal information within Circle K and companies within our corporate group or with our third party business partners (companies with which we provide programs, products or services) and service providers (companies operating on our behalf) for the purposes described in this Privacy Policy and in accordance with applicable law. We may also share your personal information with third parties for statistical or scholarly research purposes, always in compliance with applicable law. We will not share your personal information with any non-affiliated third party without your prior consent, other than as provided in this Privacy Policy or as otherwise authorized by applicable law. We do not sell your personal information to any organization or person; the only exception to this would be if we sell or transfer any part of our business. If you are a California resident, please review the California consumers section for more information on our practices specific to the law applicable to you.

Learn more about how we may share personal information: within the Circle K group, with third party business partners, 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, for other permitted reasons, and with your consent.

a. Within the Circle K Group

Circle K affiliates and subsidiaries in Canada, the United States and internationally may share personal information with each other and use it for the purposes described in this Privacy Policy. This allows Circle K and each entity within the group to comply with applicable laws, regulations and requirements and ensures that your information is consistent, accurate and up-to-date. In addition, it increases the quality and relevance of the services you receive and improves your interactions with Circle K through easier access to your information within the group.

b. Business Partners

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.

For example:

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.

c. Service Providers

In the course of providing our programs, products, services, promotions, contests and events we may share all categories of personal information detailed in 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 require these service providers to limit their access to and/or use of personal information to what is required to provide their services and require that those third parties adhere to confidentiality as well as security procedures and protections.

For example:

d. Sale or Transfer of Business or Other Transaction

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.

e. Research

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.

For example:

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.

f. Other Permitted Reasons

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.

g. With Your Consent

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.

View Summary

7. How we Manage Consent

By subscribing to our programs, products and services and/or submitting information to us in connection with using our programs, products and services, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. In some cases, your consent may be “implied” i.e. your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Policy or in the terms and conditions of a specific program, product, service, contest, promotion or event you signed up for, participated in or purchased. You may be entitled under applicable law to withdraw your consent (except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations with us). For information on how to manage your privacy preferences, please see How Can You Change Your Privacy Choices?

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.

8. How Can You Change Your Privacy Choices?

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 through your account, when you register or by contacting us directly, and using third party unsubscribe functionality

a. Within your Account

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.

b. When You Register or by Contacting Us Directly

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:

Please note the following regarding withdrawal of consent or changes in your privacy preferences:

c. Using Third Party Unsubscribe Functionality

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, 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 example, Google Analytics uses cookies to analyze your browsing behaviour on our websites. This information is not provided to us in a personally identifiable format and is collected through your ad settings on your device or browser. If you would like to opt out of Google’s ad settings, please go to www.google.com/ settings/ads or use the Google opt out browser add-on located at https://tools.google.com/dlpage/gaoptout.

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/).

View Summary

9. How we Store and Safeguard Personal Information

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.

Learn more about how we protect personal information, where we keep personal information and cross-border transfers and how long we keep personal information

a. How we Protect Personal Information

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.

b. Where we Keep Personal Information and Cross-border Transfers

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 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.

c. How Long we Keep Personal Information

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).

View Summary

10. Accessing and Correcting Your Personal Information

You may have the right to access and rectify the personal information we hold about you under the law applicable in the jurisdiction where you reside. In this case, upon request, we will provide you with access to your personal information within a reasonable timeframe, in compliance with applicable laws. It is your responsibility to provide accurate, correct and complete information.

You can request access or rectification by contacting the applicable Privacy Office as described in the “Who Can You Contact With Privacy Questions?” section. If you are residing in California, please refer to the California Consumers section for more information on how to exercise your rights.

11. Children Privacy

We do not knowingly request or collect personal information from children under 13 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.

12. California Consumers

This section describes the rights you have under the CCPA if you are a consumer residing in California.

The categories of personal information we collect about California consumers (and that we may have collected in the last twelve months) and the purposes for which we collect this personal information are listed, respectively, in sections What Personal Information do we Collect?, How we Collect Personal Information and How we Use Personal Information of this Privacy Policy. We do not sell your personal information. We may disclose all personal information we collect for business purposes to service providers (and may have done so in the last twelve months), as further detailed in the How we Share Personal Information section of this Privacy Policy.

a. Request to Know about the Personal Information we have Collected and Disclosed

Once every 12 months, you may submit a verifiable request that we disclose the following information to you:

b. Right to Request that we Delete your Personal Information

You may submit a verifiable request that we delete any personal information that we have collected about you, subject to the exceptions provided by the CCPA.

c. Methods for Exercising your Rights and Verification of your Identity

You may exercise these rights using one of the methods detailed in the “Who Can You Contact With Privacy Questions?” section.

In accordance with applicable law, we must take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we may verify your identity through existing authentication practices for the account, such as you username and password. We may also verify your identity by matching two or three data points of identifying information you provide to data points we already maintain about you and have determined to be reliable for the purposes of verification, depending on the nature of your request.

You can authorize an agent to exercise any of these rights on your behalf, but we will take additional measures to verify the legal authority of your agent.

d. Non-Discrimination Right

We will not, because you have exercised any of the rights detailed in this section 12, deny you any goods or services, charge different prices or rates for goods or services, or provide you with a different level or quality of goods or services.

13. Changes To Our Privacy Policy

We may make changes to this Privacy Policy from time to time. Any changes we make will become effective when we post a modified version of the policy on our websites and apps. If the changes we make are significant, we will provide a more prominent notice when required by applicable laws. By continuing to participate in our programs, and/or use our services or purchase our products after the modified version of the Privacy Policy has been posted or you have been informed of such update, you are accepting the changes to the Privacy Policy. If you do not agree to the changes in our Privacy Policy, it is your responsibility to stop participating in our programs, and/or using our services or purchasing our products. It is your obligation to ensure that you read, understand and agree to the latest version of the Privacy Policy. The “Effective Date” at the top of the Privacy Policy indicates when it was last updated.

14. Who Can You Contact With Privacy Questions?

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 Office

                  Circle K Stores Inc.

                  1130 West Warner Road, Building B

                  Tempe, Arizona 85284

                  If you are in Canada

                  Legal Department c/o Privacy Office

                  Couche-Tard Inc.

                  4204 Industriel Boulevard

                  Laval, QC H7L 0E3

Toll-free number: 1-833-662-0510

Email address: privacy@circlek.com