Last updated: January 1, 2023.
GPM Investments, LLC (“GPM”, “we”, “us”, “our”) is committed to protecting your personal information and your right to privacy. This Virginia Consumer Privacy Notice Addendum (“Notice”) applies solely to residents of Virginia (“you”) and describes our current policies regarding the collection, use, distribution, and protection of your Personal Data (as defined below) you share with us, our subsidiaries, and affiliates, on any of our websites (the “Websites”), through any of our services (the “GPM Services” and together with the Websites, the “Services”), when you visit our stores or otherwise interact or communicate with us, and our mobile applications which include the following policy [link to Mobile Policy]. This Notice supplements our main Privacy Statement located at [link to main Privacy Statement].
If you have any questions or concerns about this Notice, please contact us at firstname.lastname@example.org.
- WHAT PERSONAL DATA DO WE PROCESS?
GPM may collect, use, store, disclose, analyze, delete, and/or modify (“process”) Personal Data as described in this Notice. “Personal Data” includes information that is linked to or reasonably associated with an individual, not including de-identified data or publicly available information.
GPM has processed the following categories of Personal Data:
- Personal identifiers such as names, phone numbers, email addresses, mailing addresses, usernames; passwords, and contact or authentication data;
- Personal Data that is consider “Sensitive Data,” such as precise geolocation data (if you consent to providing such data);
- Payment information such as billing data, billing addresses, debit and credit card numbers, and other similar information provided to us when you make an in-store or on-line purchase;
- Computer, device and technical information, which includes data through which your identity is not readily ascertainable but collected automatically through your use of the Websites or the Services, such as device and usage information including your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Websites and other technical information.
- WHY DO WE PROCESS OR SHARE YOUR PERSONAL DATA?
We process your Personal Data for legitimate business interests, such as providing you with the Websites and the Services, to fulfill our contracts with you, to fulfill and manage your orders, payments, returns, and exchanges, to facilitate account creation and log-on processes, to request feedback regarding our Websites and Services, to manage user accounts, to send administration information to you (e.g., to send you information regarding products, services, new features, changes to our terms, conditions, and policies), to administer prize draws and competitions, and for other business purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Websites, Services, products, marketing and your experience.
We may use your Personal Data to respond to user inquiries/offer support to users. We may use your data to respond to your inquiries and solve any potential issues you might have with the use of our Services.
We may process Personal Data for purposes of maintaining the security and operation of our Websites and Services and for our internal analytics and reporting purposes (e.g., for fraud monitoring and prevention to keep our Websites safe and secure). We may also process Personal Data for purposes of enforcing our terms, conditions and policies for business purposes and to comply with legal and regulatory requirements.
With your consent, we and/or our third-party marketing partners may use your Personal Data to send you marketing and promotional communications or for our marketing purposes. You can opt-out of our marketing emails at any time.
We also use your Personal Data to deliver targeted advertising to you with your consent. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. You may opt-out of targeted advertising by contacting us at fasREWARDS@gpminvestments.com.
- HOW DO WE SHARE YOUR PERSONAL DATA?
GPM does not sell Personal Data for monetary consideration.
GPM may share certain types of Personal Data in connection with providing the Services, as required by law or to protect our business interests. For example, we may share your Personal Data:
- With service providers acting on our behalf,
- With other participants in the payment ecosystem, including financial institutions, and merchants.
- With third parties for fraud monitoring and prevention purposes, or other purposes required by law.
- In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- [targeted advertising]
- VIRGINIA CONSUMER RIGHTS.
Please contact GPM at email@example.com if you wish to request to exercise any of the following rights under the Virginia Consumer Data Protection Act § 59.1-573:
- To confirm whether or not we process your Personal Data and to access such data;
- To correct inaccuracies in your Personal Data (taking into account the nature of the Personal Data and our purpose(s) for processing of such data);
- To delete your Personal Data;
- To obtain a copy of your Personal Data (taking into account the extent this is technically feasible); and
- To opt-out of the processing of your Personal Data for purposes of targeted advertising (GPM does not sell or process Personal Data for purposes of profiling).
You may also contact GPM at firstname.lastname@example.org if you wish to appeal GPM’s decision with regard to a request. GPM does not discriminate against consumers that may exercise any of the above consumer rights.
- HOW DO WE KEEP YOUR PERSONAL DATA SAFE?
GPM has implemented and shall maintain reasonable administrative, technical, and physical data security practices to protect the confidentiality, integrity, and accessibility of Personal Data. Such data security practices are appropriate to the volume and nature of the Personal Data.
- CHANGES TO THIS NOTICE.
The top of this Notice will include the date it was most recently updated. Using our Websites and Services where this Notice is posted constitutes your acceptance of our privacy practices described herein.
- CONTACT INFORMATION.
If you have questions about this notice, you may reach us by email, telephone or US Mail as follows:
Toll-Free Telephone: 1-844-400-1035
fas REWARDS® Customer Service
8565 Magellan Pkwy Suite 400
Richmond, VA 23227
Effective Date: June 1, 2016
GPM Investments, LLC and its subsidiaries (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.gpminvestments.com [list all websites] (individually and collectively, our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect:
- On our Website.
- In e-mail, text and other electronic messages between you and this Website.
- Through our mobile application fas App.(r)
- Through our fas CASHBACK® payment platform.
It does not apply to information collected by:
- us offline or through any other means;
- any third party, including through any application or content that may link to or be accessible from the Website.
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
- by which you may be personally identified, such as name, date of birth, mailing address, e-mail address or telephone number (“personal information”); and/or
- about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us. The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or any component thereof or when you apply for employment through our Website. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
Usage Details, IP Addresses, Cookies and Other Technologies. As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
The information we collect automatically is statistical data, and, except with respect to our fas CASHBACK® card and fas App®, does not identify any individual. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may, from time to time, include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To present our Website and its contents to you.
- To provide you with directions to our store
- To provide you with information, products or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To notify you about changes to our Website or any products or services we offer or provide though it.
- In connection with a job application.
- To allow you to participate in any promotions or contests we may offer.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
By providing your e-mail address to us, unless you have affirmatively opted-out, you expressly consent to receipt transaction e-mails and marketing materials from us and we may send you information that you have requested or information about other products or services developed or provided by us. We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data or e-mail firstname.lastname@example.org.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To contractors, service providers and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s or its affiliates or subsidiaries assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Company’s or its affiliates or subsidiaries about our Website users is among the assets transferred.
- To third parties to market their products or services to you if you have consented to or otherwise not opted out of these disclosures.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our affiliates or subsidiaries, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from the Company. If you do not wish to have your e-mail address used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an e-mail stating your request to email@example.com. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions. This opt out does not apply to information provided to the Company as a result of a contest or promotion that you have entered, product service experience or other transactions.
- Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to firstname.lastname@example.org.
Accessing and Correcting Your Information
You may send us an e-mail at email@example.com to request access to, correct or delete any personal information that you have provided to us. It is possible that we will not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write us at: GPM Investments, LLC, Attn: Privacy Officer, 8565 Magellan Parkway, Suite 400, Richmond, Virginia 23227.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.