FAS REWARDS® PRIVACY POLICY

(Effective December 6, 2017)

Message to Our Customers Regarding Privacy

GPM Investments, LLC, including its subsidiaries, related and affiliated companies (individually and collectively, “GPM Investments,” “we,” “us” or “our”) the owner and operator of the fas REWARDS program including the fasrewards.com website (the “Website”) and the fas REWARDS App (whether on iOS, Android, or any other platform on which such app may become available in the future, the  “Application”), believes in protecting the confidentiality of our customer information in accordance with our customers’ wishes and applicable laws. Our reason for collecting customer information is to help us deliver added value and improve the shopping experience of our customers. The fas REWARDS program is a primary means of collecting such information, which helps us to target benefits and services to our customers. This may include advising our customers about products, services and other opportunities.

GPM Investments values your business and the trust you place in us. To help you better understand how customer information is used and protected at GPM Investments, this Privacy Policy outlines (a) a definition of customer information, (b) methods and sources of collecting customer information, (c) categories of institutions or parties to whom we may disclose customer information, and (d) measures and efforts we take to safeguard customer information. GPM Investments reserves the right to revise this Privacy Policy at any time without prior notice. For this reason, please check regularly for the most recent version of our privacy policy.

Definition of Customer Information

Customer Information is information about you that is obtained by GPM Investments in connection with providing a product or service for personal, family or household purposes. We will collect and use sales information or purchase data to determine purchasing trends and locations, calculate available benefits, and, through the fas REWARDS program, deliver rewards and communications.  Our goal is that this will help optimize your customer experience and enhance time spent at participating fas REWARDS locations.  Because this information is linked to an individual, it is protected by this policy.

Customer Information also includes information that identifies you (“Customer Identifiable Information”) such as your name, address, email address, and telephone number.

Methods and Sources of Collecting Customer Information

 • To help better understand and serve the needs of our customers, we collect Customer Information from various sources, including the following:

 • Information we receive when you use your fas REWARDS card or the Application at participating locations;

 • Information you give us on application forms, voluntary customer surveys, sweepstakes and coupon rebate entries, or when you visit the Website or use the Application;

 • Information you provide to us over the phone or through the mail or email;

 • Information that your iOS device provides such as location data;

 • Information we collect through your browser when you visit our website and your browser interacts with us; and

 • Information provided to us by other sources/companies.

How is Customer Identifiable Information Used?

GPM Investments will not disclose to any company, person, or agency Customer Identifiable Information, except as described below. 

In order to provide you with loyalty products and services we believe may meet your personalized needs and interests, GPM Investments may disclose Customer Identifiable Information about you, along with data about your purchases and your experiences with fas REWARDS, to our service providers who maintain and run the fas REWARDS program and merchandise vendors whose products are sold at participating fas REWARDS locations and need such Customer Identifiable Information to push coupons or other promotions to specific customers. We may also provide Customer Identifiable Information to service providers that work for us, such as sending a direct mail offer from us to you – however, we require these companies to sign a confidentiality agreement that prohibits them from using your personal information for any unauthorized purposes.  We may also provide Customer Identifiable Information 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 GPM Investments’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by GPM Investments is among the assets transferred.

In addition, GPM Investments may disclose to any company, person, or agency Customer Identifiable Information as required by law or legal process, as required to protect the rights or safety of GPM Investments, fas REWARDS locations or our customers, or in response to a specific law enforcement request. Security regulations of several countries may require us to provide foreign and domestic government agencies with access to data you disclose to us.

GPM Investments may share anonymous, aggregated customer data (free of any personal Customer Identifiable Information) about all our users with third parties. 

How Can I Prevent My Customer Identifiable Information from Being Disclosed?

You have the right at any time to direct us not to disclose Customer Identifiable Information about you, or to change your preference in this regard, or to change Customer Identifiable Information that you have provided to us, through our website, or by calling fas REWARDS toll-free at 1-844-400-1035. A fas REWARDS Personal Identification Number (PIN) is required for account information. If you direct us not to disclose such information about you, you will not be eligible for any card-based promotions that require individual data, such as continuity programs, which require Customer Identifiable Information, sweepstakes, etc., but you will still be entitled to receive other benefits from the use of your fas REWARDS Card.

Additionally you may prevent the Application from collecting and using real-time information about your device's location by disabling the GPS and opting out of location based promotions.  If you block the use of location information some parts of the Application may then be inaccessible or not function properly.

Security

Protecting Customer Identifiable Information is an important priority for GPM Investments. Marketing services providers or affiliates that receive Customer Identifiable Information are required to preserve the confidentiality of that information under the terms of our legal contracts with them. GPM Investments also maintains physical, electronic and procedural safeguards in accordance with industry standards that are designed to keep unauthorized persons from accessing Customer Identifiable Information stored on our systems.

California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Application and Website who 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 [email protected] or write us at: GPM Investments, LLC, Attn: Privacy Officer, 8565 Magellan Parkway, Suite 400, Richmond, Virginia 23227.

Will the Privacy Policy Change?

fas REWARDS may modify this Privacy Policy from time to time. Our current Privacy Policy can be viewed on our website at www.fasrewards.com.  If you have any questions regarding this Privacy Policy or wish to change your personal Customer Information preferences, please contact us toll-free at 1-844-400-1035 or through our website. A fas REWARDS Personal Identification Number (PIN) is required for account information.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: [email protected] or GPM Investments, LLC, Attn: Privacy Officer, 8565 Magellan Parkway, Suite 400, Richmond, Virginia 23227.