Effective Date: August 4, 2020
The Clark Crown mobile consumer loyalty application for smartphones and tablets, and its associated websites, servers and databases (collectively, the “App”) is owned and operated by Clark Brands LLC and Clark Crown LLC (collectively “Clark Crown”). The App enables registered users (“you” or “your”) to participate in consumer loyalty programs (collectively, the “Program”) operated by Clark Crown and the independent gasoline and/or convenience store locations participating in the Program (collectively, “Merchants”).
Scope of this Policy
This policy applies to your use of the App and your participation in the Program, including the information that you furnish to the App, and information that is collected by both the App and by the Program’s software as a result of your access and use of the App and your participation in the Program. The App may contain links to websites and other sources of information over which we have no control. Clark Crown is not responsible for the privacy policies or practices of other websites and other sources of information of third parties that may be linked to by this App. We encourage you to review the privacy policies of those other website so you can understand how they collect, use and share your information.
Use of Personal Information
Type of Information We Collect
We may collect any or all of the following general types of information about you when you register, visit or use our App, or when you conduct transactions with Merchants pursuant to the Program: personal information, geographic/location information, and transaction information. Sometimes we collect combinations of these types of information.
Personal information is information that can be used to identify you, or any other individual to whom the information may relate, personally. We do not collect personal information unless you choose to provide it to us, such as by registering as a user of the App. Some examples of personal information that we collect in some areas of our App, including upon initial user registration, are: your full name; date of birth; e-mail address; and telephone number. Your telephone number is used as an alternative identifier, when you conduct transactions with Merchants pursuant to the Program.
When you enable the App to use location information, your location is used to enable the App to assist you in locating Merchants participating in the Program.
When you purchase gasoline or merchandise pursuant to the Program, or redeem loyalty rewards pursuant to the Program, we collect information concerning what you have purchased, the Merchant location where the purchase was made, and an identifier linking your Program account to the transaction.
Clark Crown may also collect, or log, certain other information that cannot identify you personally when you visit or use our App. This information includes your Internet Protocol ("IP") address, which is a number that is automatically assigned to your computer, smartphone or tablet by your cellular or Internet Service Provider, and through which you access certain features of the App. Clark Crown may log these IP addresses and aggregate them for system administration and to monitor the use of our App. We may use the aggregated information to measure the number of visits or uses of our App, the average time spent on or using our App, the number of App screens viewed or functions accessed, and various other App use statistics. Such monitoring helps us evaluate how our App is used and continuously improve the content we provide.
Clark Crown also may disclose personal information about you, without notice: (i) in response to requests from local, state or federal law enforcement officials; (ii) if requested by any judicial, administrative or similar proceeding or order, such as a subpoena; or (iii) if otherwise required by law.
How Information is Used
We use the information we gather on our App and Program software for the purposes of providing Program services, responding to any queries you may have, and operating and improving our App and the Program. Our services may include the display of personalized products, services, content, and advertising relating to your perceived interests. Some of our products and services may enable our trusted third parties to see your personal information and to contact you.
By registering the App with Clark Crown, by using the App or an alternative identifier to engage in transactions with Merchants pursuant to the Program, or expressly opting in when presented with choices, you have consented for us to use your information, subject to local law, in the following ways: to allow you to create an account; to create a profile for you based on information that you have provided to us; to make available financial transaction-related services pursuant to the Program via the App or an alternative personal identifier, to contact you about App and Program updates, informational and service-related communications, including important security updates; to provide you additional communications, information, and promotions such as newsletters and promotional emails; to inform you of other products or services available from Clark Crown or its trusted third parties; to enable you to provide feedback, to contact us and for us to respond to you; to conduct surveys, questionnaires, promotions and contests or sweepstakes, and to provide the results thereof such as contest or sweepstakes winners; and to generate internal reports about the use and performance of our App and the Program. By providing your personal information on the App and by participating in the Program, you acknowledge that you consent to your information being used as described here.
Disclosure of Information to Others
We may disclose to third parties your personal information, location/geographic information, and transaction information, as set forth below.
We may share your information with third parties who help us in the delivery of our own products and services to you, including via the Program. We may disclose information to companies and individuals we employ to perform functions on our behalf. Examples include hosting our web servers, analyzing data, providing marketing assistance, and providing customer service.
We may disclose such information to our trusted third parties if you consent to such disclosure by creating an account on the App, by Participating in the Program, or by expressly requesting a particular product or service. We may also share aggregated anonymous information about users of the App or Program with Clark Crown’s clients, partners and other third parties.
We disclose information if legally required to do so, if requested to do so by a governmental entity or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect our rights or property or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public. Because Clark Crown is a U.S. company and information collected by or using the App or the Program is stored in whole or in part in the United States, your information may become subject to U.S. law.
We may disclose and transfer such information to a third party who acquires all or a substantial portion of Clark Crown's business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Clark Crown becomes the subject of an insolvency proceeding, whether voluntary or involuntary, Clark Crown or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court. You will be notified of the sale of all or a substantial portion of our business to a third party by email or through a prominent notice posted on the App.
Other Important Information
You are responsible for ensuring that your log-in credentials (your username and password) are kept confidential.
Clark Crown and its designated service provides have implemented reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. Notwithstanding such measures, the Internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes.
Should you use the App for any financial transaction-related services, your gift card, debit card, and/or credit card information is protected through the use of encryption, such as the Secure Socket Layer ("SSL") protocol. SSL makes it difficult for your gift card or credit card information to be intercepted or stolen while being transmitted. Clark Crown may use a service company to process its gift card, credit and debit card transactions, and such transactions are subject to the service company’s own privacy and security policies and practices.
The App is not intended for, nor do we knowingly collect information from, children under the age of 13.
Changes to Privacy Statement
If we decide to change the substance of our Privacy Statement for Clark Crown, we will, where required, contact you either via the App, or via the email address that you maintain in your account profile.