Privacy Policy Canada – National Retail Solutions

Effective as of August 1, 2023
 
 
General

National Retail Solutions, Inc. (“NRS”) is committed to protecting the privacy of your personal information.

This Privacy Policy (the “Policy”) sets forth our policies and procedures regarding the collection, use and sharing of your personal information.We also explain the steps we take to protect your information and how you can limit the collection, use and sharing of your information.

This Policy applies to the following unless otherwise noted:

When we use the term “Services” it collectively refers to the NRS Products, the NRS Websites, the NRS Reward Programs, the NRS Apps, and the NRS Web Stores.When we refer to NRS or “us,” or “we,” we’re talking about National Retail Solutions, Inc.

You should also read the terms of service for each Service that you use, which can be found at the applicable NRS Website, NRS App or NRS Web Store.

We may update this Policy from time to time and you should review it periodically for changes.Any updated Policy will be posted at the NRS Websites, the NRS Apps and in the NRS Web Stores.

What is Personal Information?

NRS may receive and collect both personal and non-identifying information from you when we operate and provide you with the Services, when you install, access or use the Services and when you communicate with us.Personal information means information either on its own or in conjunction with other data that enables a specific person to be identified, but does not include “de-identified,” “anonymous,” or “aggregate” information, which is not otherwise associated with a specific person.Non-identifying information means information that by itself cannot be used to identify a specific person (e.g., zip code).We may collect a variety of information from our customers.This section describes the information we may collect.

A. Information You Provide.Depending on the particular Service, you may provide the following personal information:

B. Information We Collect.Depending on the particular Service, we may automatically collect the following information:

C. Information Provided by Third Parties.When you install, access or use the Services we may obtain the following information from third party sources:

The 10 Principles of Privacy

The following principles, developed by the Canadian Standards Association, form the basis of NRS’s information collection practices and outline NRS’s commitment to protecting your privacy.

1. Accountability

Every NRS employee is responsible for maintaining the confidentiality of all information to which he/she has access.Our employees are informed about the importance of privacy and receive ongoing updates on privacy related policies.

In addition to establishing this Privacy Policy, we have appointed a Privacy Ombudsman who is responsible for overseeing the personal information handling practices at NRS and ensuring we are in compliance with our Privacy Policy and related policies.If you have questions, concerns or suggestions related to our Privacy Policy or our privacy practices you may contact us at:

National Retail Solutions, Inc.

520 Broad Street, 3rd floor

Newark, NJ 07102

Telephone:800-215-0931

Attn:Privacy Ombudsman

2. Identifying the Purposes for Collecting Information

We may use all the information we collect and receive to help us operate, provide, improve, understand, customize, support, and market our Services (and some third party services).In addition, we may use your information for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you.As used in this Policy, the terms “use,” “using” and “processing” information include using cookies or other similar technologies on a computer/phone/device, subjecting the information to statistical or other analysis and using or handling information in any way, including but not limited to, scanning, collecting, storing, evaluating, aggregating, modifying, deleting, using, combining, disclosing and sharing information among our affiliates both in and outside the United States and to select service providers and vendors.

A. Our Services.We analyze how our customers use our Services and use that information to evaluate and improve our Services, to research, develop, and test new services and features, and to conduct troubleshooting activities.For example:

B. Web Technologies.The NRS Websites, NRS Apps and NRS Web Stores may use certain web technologies such as “cookies” or “web beacons.”We use cookies, small text files stored locally on your computer or device to serve as markers, to operate, provide, improve and customize our Services and your experiences.For example, we use cookies to understand which of our FAQs are most popular and to show you relevant content related to our Services.Additionally, we may use cookies to remember your choices, such as your language preferences.Web beacons are used to tell us how and when pages in our sites are visited, by how many people, their point of origin and operating system and to monitor performance with our Services.These technologies do not collect personal information. We do not honor any web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third party websites or online services.We use and share this data and information to deliver customized content and advertising, to ensure that you see the correct product information, to manage the frequency with which you see an advertisement, to tailor advertisements to better match your interests, and to understand the effectiveness of our advertising.The content may be delivered on the NRS Websites, on non-NRS websites, on the NRS Apps, on NRS Web Stores, by our representatives, and via email, SMS, push notifications or other NRS services.In addition, if you respond to or interact with a particular advertisement, you may later receive a targeted advertisement as a result of an ad server or ad network concluding that you fit within a particular audience we are trying to reach.

C. Web Analysis.We use certain Google Analytics Advertising Features, including Remarketing and Demographics and Interest Reporting.Google Analytics is a web analysis service provided by Google that allows us to collect data about the traffic on the NRS Websites through Google cookies and other identifiers, which enables us, among other things, to create user segments based on demographic or interest data and to deliver relevant advertising.Google utilizes the data collected to track and examine the use of our websites and to prepare reports on the activities and share them with other Google services.Google may use the data collected to contextualize and personalize the ads of its own advertising network.You may be able to opt out of the Google Analytics Advertising Features through your browser ads settings or by visiting Google’s Ads Settings page.

D. NRS Apps.We engage certain service providers and vendors who use mobile software development kits to passively collect information from users of the NRS Apps.We use this data primarily to help us deliver personalized notifications and to identify you in a unique manner across other devices or browsers for the purposes of customizing advertisements or content.

3. Consent for the Sharing and Use of Your Information

You have choices about how NRS shares and uses information.In general, NRS seeks your consent to collect, use or disclose your personal information at the time of collection or in advance.We have taken steps to ensure that our language is clear and understandable so that you know why we are collecting your information and how we will use it.Please note that under certain legal and medical circumstances it may be impossible or impractical to obtain an individual’s consent.

Consent may be expressed in writing or it may be implied in the circumstances.In addition to writing, your consent may also be expressed verbally or electronically.

In deciding what form of consent is appropriate, we will consider the type of personal information we need, its use, any necessary disclosures, the type of customer contact that is involved and applicable legislation.Your choices regarding this consent will remain in effect unless you change them.

In general, you can choose not to provide us with some or all of your personal information at any time.However, should you make this choice we may not be able to provide you with the product, service or information that you requested or that could be offered to you.Upon request we will explain your options of refusing or withdrawing consent to the collection, use, and disclosure of your personal information.

A. Telemarketing.National “Do Not Call” laws allow you to place residential wireline, wireless and VoIP phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers.If you would like to add your numbers to this list, you may do so by visiting https://www.lnnte-dncl.gc.ca/.You should be aware that even if you add your number(s) to the Do Not Call list, most telemarketing laws allow companies to contact their own customers.If you would like to be removed from NRS’s telemarketing list, please contact us at 800-215-0931 or [email protected].Please allow 30 days for your telephone number to be removed from any sales programs that are currently underway.Please note that we may still call you regarding your Services and account even if you remove your number from our telemarketing list.

B. Email, Text Messages and Push Notifications.Marketing emails you receive from us will include an unsubscribe feature usually found at the bottom of the email that you may use to opt out of receiving future marketing emails.Marketing text and SMS messages from us also contain an opt-out feature that you can use to prevent future marketing text and SMS messages from us.You may refuse to consent to receive calls and texts from NRS and its affiliates that require your consent, including autodialed, pre-recorded or artificial voice telemarketing calls.You may also withdraw your previously given consent to receive such calls and texts.You can opt out of receiving push notifications from us via the NRS Apps by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for the applicable app.Please note that you cannot withdraw your consent to receive certain in app messages from us.Your ability to manage some of our Services could be limited if you withdraw your consent to receive text and SMS messages.In those cases NRS does not recommend using those Services without authorization to receive such messages.

C. Online Information.You have choices about whether certain information collected on the NRS Websites, NRS Apps and NRS Web Stores is used to customize advertising based on predictions generated from your visits over time and across different websites and apps.Similarly, many mobile devices offer controls you can set to limit the advertising use of information collected across mobile apps on your device.Please note that many opt outs use browser cookies or device controls and are specific to the device and browser you are using.If you buy a new computer, change web browsers or devices or delete the cookies on your computer, you may need to opt out again.In addition, ads you receive may still be tailored using other techniques such as publisher, device or browser-enabled targeting.You should check the privacy policies of the products, sites, apps and services you use to learn more about any such techniques and your options.You also can limit the collection of certain website information by deleting or disabling cookies.Most browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored.Disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

4. Limiting Collection

NRS does not collect personal information indiscriminately.Rather, we limit our collection of personal information to only what is necessary for the purpose we have identified.NRS does not knowingly market to or collect information from children under the age of 16 without obtaining verifiable parental consent.If you allow a child to use your device or our Services, you should be aware that their information could be collected as described in this Policy.We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.The NRS network may not be used by customers in any manner for the storage, transmission or dissemination of images containing child pornography or any other illegal or inappropriate activity involving children and we will report any instances of such activity of which we become aware to the appropriate law enforcement authorities.

5. Limiting Use, Disclosure and Retention

We may share all the information we collect and receive with our affiliates, both in and outside the Canada, and to select service providers and vendors, to help us operate, provide, improve, understand, customize, support, and market our Services (and some third party services), and for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you.We also share information with each NRS store with which you interact.When we share information with our service providers and vendors, we require them to use your information only in accordance with our instructions and terms or with express permission from you and not to sell your information.In addition, you share your information as you use and communicate through our Services.

A. Information Shared Within the NRS Family of Companies.We may share information within the NRS family of companies, including our affiliates both in and outside the United States (collectively, the “NRS Family of Companies”) primarily to operate, provide, support and market our Services.For example, we may share your information with various NRS affiliates in order to process your transaction.

B. Information Shared with our Service Providers and Vendors.We work with various service providers and vendors for a variety of business purposes such as to help us offer, operate, provide, improve, understand, customize, support and market our Services.We may share information with these service providers and vendors to the extent reasonably necessary for them to perform work on our and your behalf.For example, we may provide your credit card information and billing address to our payment processing company solely for the purpose of processing payment for a transaction you have requested.In addition, NRS shares certain information, including unique marketing identifiers, email addresses and mobile phone numbers (full or only partial), with some of our service providers and vendors, including tobacco companies, Google and Facebook, for marketing, advertising, rewards/loyalty programs and analysis purposes, including the delivery of advertising campaigns and preparing and sharing aggregate business and marketing reports, demographic profiling and to deliver targeted advertising about products and services.All the foregoing categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties.In addition, no mobile information will be shared with third parties/affiliates for marketing/promotional purposes.When we share information with our service providers and vendors, we request that these parties protect your information and limit their use of the data to the purposes for which it was provided, and not to sell your information.NRS does not sell, rent or lease its customer lists to third parties.NRS does on occasion sell certain pieces of personal information, such as personal identifiers, of some of our stores’ customers to data processors.Finally, if you purchase products or services offered jointly by NRS and one of our service providers or vendors, your customer information may be received by both NRS and the service provider or vendor that is providing the product or service.For these jointly offered products and services, you should also review the other company’s privacy policy, which may include practices that are different from the practices described here.

C. Special Circumstances.We may share information in certain special circumstances.For example:

D. Information Shared with Advertising Entities or Social Networks.You may see third party advertisements on our products and Services, the NRS Websites, the NRS Apps, and/or the NRS Web Stores.Some advertisements are chosen by companies that place advertisements on behalf of advertisers.These companies, often called ad servers, may place and access cookies on your device to collect information about your visit.The information they collect from our sites is in a form that does not identify you personally.This information may be combined with similar data obtained from other websites to help our advertisers better reach their targeted audiences.Targeting may be accomplished by tailoring advertising to interests that they infer from your browsing of our sites and your interaction with other websites where these ad servers also are present.If you choose to interact with specific advertisers who advertise on our products and Services, the NRS Websites, the NRS Apps, or the NRS Web Stores, the information you provide to them is subject to the conditions of their specific privacy policies.The NRS Websites, NRS Apps and NRS Web Stores also include plug-ins and widgets that may provide information to their associated social networks or entities about the NRS page you visit, even if you do not click on or otherwise interact with the plug-in or widget.

E. When You Share Information.You share your information as you use and communicate through our Services.Stores with whom you communicate may store or share your information (including your phone number or messages) with others on and off our Services.

F. Links to and from non-NRS Websites and Content.The NRS Websites, NRS Apps and NRS Web Stores may contain links to non-NRS sites.In addition, NRS content may be included on websites that are not associated with NRS.We have no control over these non-NRS sites and are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms.We recommend that you review the policies and practices of the sites you visit.

G. Social Networking.Some of our Services may allow you to participate in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews.Please be aware that these forums are accessible to others.We urge you to not submit any personal information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum.NRS is not responsible for the information you choose to submit in these forums.If you post content to information sharing forums, you are doing so by choice and you are providing consent to the disclosure of this information.

6. Accuracy

We strive to keep our customer records as accurate as possible.You may correct or update your customer information by calling an NRS customer service representative at 800-215-0931 or by accessing your account online and providing the updated information there.Please note that NRS is not responsible for information, content, apps or services provided by others.Before you access, use, link to or download a service or application on your computer or wireless device, you should review the associated terms of service and privacy policy.

7. Safeguards:Protecting your Information

NRS has technical, organizational and physical safeguards in place to help protect against unauthorized access to, use or disclosure of the information we collect and store.Employees are trained on the importance of protecting privacy and on the proper access to, use and disclosure of customer information.NRS secures information on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.We use Secure Socket Layer (SSL) encrypted protection to protect the personal information transmitted to the NRS Websites and NRS Web Stores.The NRS Websites, NRS Apps and NRS Web Stores are PCI compliant in connection with your credit card information.Although we work hard to protect your information that we collect and store, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose that information.NRS maintains security and incident response plans to handle incidents involving unauthorized access to information we collect or store.If you become aware of a security issue, please contact us.

8. Openness:Keeping you Informed

If you have questions, concerns or suggestions related to our Privacy Policy or our privacy practices you may contact us at:

National Retail Solutions, Inc.

520 Broad Street, 3rd floor

Newark, NJ 07102

Telephone:800-215-0931

Email:[email protected].

Attn:Privacy Ombudsman

We reserve the right to make changes to this Privacy Policy, so please check back periodically for changes.You will be able to see that changes have been made by checking to see the effective date posted at the beginning of the policy.

9. Providing Access

NRS will provide you with access to the information it retains about you upon receipt of a written request and satisfactory identification.We may charge you a nominal fee and if so, we will give you notice in advance of costs for processing your request.If we are unable to provide you with the information you have requested, the reason for the refusal will be explained in writing.

10. Providing Recourse

If you have any questions or concerns about the privacy of your personal information or our Privacy Policy, please contact us at the contact information listed above.Should you still have questions, you can also reach us by contacting the Privacy Ombudsman as indicated above.

©2023 National Retail Solutions, Inc. All rights reserved.