Privacy Policy

LAST UPDATED: January 4, 2023

Welcome to our Consumer Privacy Policy!

This Consumer Privacy Policy applies to the websites, mobile apps and other online and offline services that are owned and/or operated by the operating subsidiaries of Global Partners LP (collectively, “Global” or “we”).  Thank you for taking the time to read it.

We appreciate that you trust us with your information. We intend this Consumer Privacy Policy to help you make informed decisions about how Global handles the personal information that you entrust to us and how you can control your personal information.

Throughout this Consumer Privacy Policy, we use the following terms with the following meanings:

  • consumer a natural person acting in an individual or household context and does not include a natural person acting in a commercial or employment context
  • controller means the person or entity that determines why and how personal information is processed
  • personal information means information that is linked or reasonably linkable to an identified or identifiable individual person
  • processing means any operation (or set of operations) performed on personal information), such as collecting, analyzing, and storing
  • processor means the person or entity processing personal information on behalf of a controller

When we refer to you in this Consumer Privacy Policy, we mean the consumer from whom Global collects personal information in connection with the Services.

Our processing of personal information is subject to the laws in the jurisdictions in which Global operates. Privacy rights may vary depending on each consumer’s place of habitual residence.

We have tried to keep legal and technical jargon to a minimum but, if you still have questions after you read our Consumer Privacy Policy, please let us know by contacting us:

  • by e-mail at [email protected], or
  • by telephone at 1-781-894-8800, or
  • by U.S. mail at 800 South Street, Suite 500, Waltham, MA 02453.
  1. WHERE THIS CONSUMER PRIVACY POLICY APPLIES

This Consumer Privacy Policy applies to:

  • websites for Global’s retail locations (“Global Websites”), including, without limitation, alltown.com, alltownfresh.com, gotomillers.com, jiffymartstores.com, visithoneyfarms.com, tbirdminimarts.com, mymrmikes.com and xtramart.com
  • Global’s consumer mobile applications (“Global Apps”), including, without limitation, the Alltown Fresh, Alltown Neighborhood Perks, My Jiffy Rewards and Miller’s Perks mobile applications
  • Global’s consumer loyalty programs (“Loyalty Programs”), including, without limitation, the Alltown Neighborhood Perks™ program, the Fresh with Benefits program, the Honey Money® loyalty program and the Jiffy Mart™ Rewards program)

We refer to the Global Websites, Global Apps, Loyalty Programs, and any other website or other digital or in-person service in which this Consumer Privacy Policy is posted or linked collectively as “Services.”   If a particular Service specifically refers to or posts a separate privacy policy, then that privacy policy — and not this Consumer Privacy Policy – applies.

  1. INFORMATION WE COLLECT

Global is the controller of the personal information that Global collects from or about consumers in connection with the Services.

Global collects the personal information that consumers choose to share with us, which typically includes the following categories of personal information:

Personal Information Collected Why the Personal Information is Collected
Contact Information and Similar Identifiers (Name, email address or other username, password, telephone number and similar contact information and purchase related contact information) We collect all of the information that you give us when you create an Account (as defined in Section 8 of our Terms of Service and including your Loyalty Account, if any), including at least a username and personal identification number or password and other identifying information necessary for the Account to work, such as your email address.  You also may decide to tell us your preferences or other information, depending in your Account type.
·       When you choose to participate in our offers and promotions, we collect the information that you use to register or participate. If you give us information about other people (such as when you send others a product as a gift), we collect the information you give us to process your request.
·       When you participate in surveys, you give us your responses to our questions.
·       To manage features of the Services that allow you to share your personal information
To respond to your request in a form filled out on any of the Global Website to download content or attend an event
Account Transactions We collect records of the products that you purchased or considered and the offers in which you participate.
Payment/Financial Information  For certain Loyalty Programs, you may provide your credit card and other payment information to a mobile payment processor when you link a credit card to your Loyalty Account.  When you make this link, the mobile payment processor makes available to Global your payment information in a single-use, unique encrypted token each time you make a payment using your Loyalty Account.  Global does not have access to or store or maintain the credit card or other payment information linked to your Loyalty Account.
Location Data
If you are accessing the Services through one of the Global Apps, we collect the precise geolocation (latitude and longitude) of your device (“Location Data”) as part of the functionality of the Services.  Your Location Data may be used to enable location-specific personalization and notifications in the Global Apps.  We can collect Location Data when you grant permission (“allow”) through your mobile device’s operating system settings and, for some Services, in your Loyalty Account settings.  Where required by law, we will seek your express consent before collecting Location Data.  Once you give us permission, we collect Location Data through your mobile device’s GPS, Bluetooth, or Wi-Fi connections and from your wireless carrier.  If you decline permission for us to collect your Location Data, we will not collect your Location Data but you may not have access to all features available through the Services. Some of the Services may use Google Maps to determine your location.  When Google Maps is part of the Services you choose to use, you also are subject to Google’s Privacy Policy at http://www.google.com/policies/privacy.  We also collect your IP address.  In some cases, your IP address may give us your location (city, state) but not your precise geolocation.
Audio Information  We may collect audio and similar information when you contact our customer service team.  We may monitor or record your online or telephone discussions with our customer service team for training purposes and to ensure service quality. We will announce when your telephone calls are recorded, as required by law.
Information associated with a social media account When you connect with Global through a social media platform, such as Meta or Twitter, Global may (depending on the applicable settings) automatically receive information from the social media platform.  We may collect and use this information for the purposes described in this Consumer Privacy Policy or at the time the information was collected.

 

Information collected about use of the Global Apps

When you download and install one of the Global Apps on your mobile device or tablet, the information that we collect depends on the mobile device’s operating system and permissions. The Global Apps need to use certain features and data from your Mobile Device to function. For example, the Global Apps collect mobile operating system and version, usage data and crash reports.

To learn more about the specific information collected by one of the Global Apps, please check your Mobile Device’s settings or review the permissions information available on the mobile app platform (e.g., Google Play or App Store) from which you downloaded a Global App. Certain Global Apps also allow you to check or change your status for certain data collection in the settings. If you change your settings, certain features may not function properly.

To stop all information collection through a Global App, please uninstall the Global App.

Information Automatically Collected by the Services

We use various technology tools to automatically collect your browser and/or device type, browser language, the date and time of your visit and certain cookies that identify your device and browser with your Account, browsing history and other information regarding your interaction with the Services, as well as the third-party websites and mobile apps and digital advertisements that you see before or after you use the Services.

Please see Section 3 for more information about the data collection technology that we use to automatically collect information through the Services and how we use them.

  1. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

We use different kinds of technology tools to recognize you, your browser(s) and/or your device(s) when you use the Services and to collect personal information about you when you interact with the Services.  These tools include cookies, tracking pixels (sometimes called web beacons) and embedded scripts, which we refer to collectively as data collection technology.

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically stores the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.  Pixels are snippets of computer code embedded on websites that can collect information.

Data collection technology collects data related to usage and performance of the Global Websites, such as:

  • IP address and time zone
  • browser type and language
  • computer or mobile device type and operating system
  • device identifiers – IMEI/UDID (a numeric identifier for mobile devices) and MAC address (another kind of numeric identifier for mobile devices)
  • user settings
  • browsing history and activities conducted while using the Services
  • websites visited before and after the Services
  • Location Data (with consent)

Data collection technology enables Global to monitor and analyze usage, technical and navigational metrics; customize user experience; set or communicate with cookies; understand whether consumers visit the Services after seeing an online advertisement displayed on a third-party website; measure the success of email marketing campaigns; improve performance of the Services; and to help detect and prevent fraudulent use of the Services.

If you want to learn more about data collection technology, many online resources are available, such as www.allaboutcookies.org.

Cookies.  The Services use the following cookies:

  • Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we offer.
  • Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
  • Functionality cookies, which are used to recognize you when you return to the Services.
  • Targeting cookies, which are used to deliver personalized advertising that are relevant to you and your interests. We also may share this information with third parties to send you relevant advertising.
  • Interaction cookies, which allow you to recommend us on social media

You have the right to decide whether to accept or reject cookies used in the Services.  You can set your browser to refuse all cookies or to indicate when a cookie is set. (Most browsers accept cookies automatically but allow you to disable them but note that some features of the Services may not work properly without cookies.)  You also may be able to reject device identifiers by activating the appropriate setting on your mobile device.

Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) also have a “Do Not Track” (DNT) feature that tells a website that a consumer does not want to have his or her online activity tracked.  If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.

The Services use Google Analytics for analytics and targeted advertising (which Google sometimes refers to as ‘remarketing’).  Google uses cookies that recognize when consumers visit various websites.  The data collected through Google’s cookies primarily helps Google create reports for Global about when and how the Services are used, such as which parts of the Services are most popular and which consumers return to the Services.  Although Google Analytics sets a persistent cookie (i.e., the cookie persists until you delete it) in your web browser to identify you as a unique user of the Services, that persistent cookie is used and useable only by Google.

Google’s cookies also enable Global to personalize marketing and advertising.  More information about how Google processes personal information collected via the Services is available at https://policies.google.com/technologies/partner-sites. For more information about Google’s privacy practices, please visit Google’s Privacy Policy and for more information about how Google uses cookies in advertising, please visit Google’s Advertising page.

As of the “Last Updated” date above, consumers may disable Google’s cookies or delete any individual cookie.  Google Analytics supports an optional browser add-on that – once installed and enabled – disables measurement by Google Analytics for any site you visit.  Users also can install Google’s opt-out browser add-on.  To opt out of targeted ads made available by Google, please use your Google Ads settings.

To opt-out of personalized advertising generally, visit  DAA Opt-Out Page (web browser only) or AppChoices (mobile apps).

Opting out does not mean you will not see advertising – it means you will not see personalized advertising from the companies that participate in the opt-out programs.  Also, if you clear your cookies, you many need to opt-out again.

  1. HOW GLOBAL USES INFORMATION

Global uses the information that we collect from or about consumers:

To deliver the Services

  • Provide customer support and respond to requests for information
  • Complete transactions
  • Manage and communicate with consumers about the Services
  • Monitor and test the Services, including to troubleshoot operational problems

To administer the Loyalty Programs and Promotions

  • Create and manage Accounts
  • Verify eligibility for Accounts, promotions, and similar services
  • Credit Loyalty Accounts with points and other benefits
  • Deliver prizes and premiums

For analytics and marketing

  • Combine and analyze information collected through the Services. (Combining information enables us to better understand consumers’ activities across the Services, to create a single set of information from all of ways that Global and our business partners interact with consumers, to deliver more personalized advertising and to understand how our advertisements perform.)
  • Customize the experience of the Services, such as delivering offers based on past purchases and display other content tailored to inferred interests
  • Perform website or mobile application analytics
  • Communicate with you by email, postal mail, telephone, or social media or through a Global App about products or services that we think will interest you, some of which is personalized based on the information associated with your Account
  • For research and innovation, such as through data analytics tools that enable Global and its business partners to better understand how you and other consumers interact with the Services

To learn about what you and other consumers like so we can improve the Services

  • Administer focus groups and surveys.
  • Conduct research and analysis to develop new features and content for the Services
  • Improve customer service

To prevent and detect fraud and abusive and unauthorized use of the Services

  • Detect bots and other disruptive code
  • Delete fraudulent Accounts

For legal compliance, risk management and similar administrative purposes

  1. HOW GLOBAL SHARES INFORMATION

Global shares information (including the categories of personal information described in Section 2 above) collected in connection with the Services as follows:

  • With the consent of the consumer
  • With Global’s Processors and Other Third Parties.  We share information with the third parties (including the processors with which we share personal information) that help us operate the Services, including for marketing, data analytics, web hosting providers, data centers, coupons, call center providers, payments, and cybersecurity.  Processors are contractually required to protect personal information consistent with this Consumer Privacy Policy and applicable law.
  • With Other Global Businesses and Business Partners.  We share information that we collect through the Services among the Global businesses.  We also may share information with business partners that use the information that we share to conduct targeted advertising or to deliver offers and other promotions.
  • For Corporate Transactions.  We share information with potential or actual acquirers or investors and their professional advisers in connection with any actual or proposed merger sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control on any Global business (in each case, whether in whole or in part). We will use our best efforts to ensure that the terms of this Consumer Privacy Policy apply to personal information after the transaction or that consumers receive advance notice of changes to personal information processing.
  • When Required by Law.  Applicable law may require information disclosure when necessary (in Global’s good-faith judgment) to comply with legal process, such as a court order, subpoena, search warrant, government investigation or similar legal requirement or for the prevention or detection of crime (subject in each case to applicable law). (Please also see How We Handle a Law Enforcement Request below.)
  • To Enforce Legal Rights.  We also share information when we believe that disclosure would mitigate our liability in an actual or threatened lawsuit or when we believe necessary to (i) protect our legal rights and legal rights of consumers, customers, employees, business partners or other interested parties; (ii) pursue available remedies or limit the damages; (iii) enforce our agreements with you; or (iv) respond to an emergency.
  1. CONSUMER PRIVACY RIGHTS AND HOW TO EXERCISE THEM

Privacy Rights

U.S. state privacy laws provide consumers certain rights with respect to their personal information. Global will honor these rights for all consumers who submit authenticated requests in compliance with these laws.

The specific privacy rights available for consumers are:

  • Right to Request Access:  You have the right to know and access the personal information that Global processes about you and to obtain a copy of that personal information.
  • Right to Request Deletion: You have the right to request the deletion of personal information provided by or obtained about you.
  • Right to Request Correction: You have the right to request that Global correct inaccuracies in the personal information that Global holds about you.
  • Right to Opt-Out of Targeted Advertising: You have the right to opt out of Global’s targeted advertising using your personal information.  (Targeted advertising is advertising based on data collected about your activities over time and across other websites and services and used to infer or predict your interests or preferences.)
  • Right to Opt-Out of Sale:  Depending on your state of residence, disclosure of your personal information to targeted advertising providers may constitute a sale of personal information.  Global will allow you to opt out of the sale of your personal information when applicable.

As of the “Last Updated” date at the beginning of this Consumer Privacy Notice, Global does not (i) sell personal information for monetary consideration or (ii) conduct profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (significant effect profiling).  Accordingly, Global does not offer you the right to opt out of a sale of personal information for monetary consideration or right to opt out of significant effect profiling.

How to Exercise Privacy Rights

You may submit a request to exercise a privacy right:

  • By clicking on the “Your Privacy Choices” link in the footer of the Global Websites or in the settings in the Global Apps and completing the form
  • By sending an email to [email protected] that includes your name, the email address associated with your Account (if applicable) or otherwise the email that you use/will use to communicate with Global, the privacy right(s) that you wish to exercise, the name of your authorized agent (if applicable) and documentation verifying your authorization and other information that you believe will help us verify and take action on your request.
  • By telephone at 1-781-894-8800

Global will respond to an authenticated privacy right request within 45 days (or, if shorter, the number of days required under applicable law).  Global may notify you of an additional 45-day extension when Global determines an extension is reasonably necessary based on the complexity of the privacy right request.   Global generally does not charge a fee for responding to a privacy right request but may do so if Global determines that a request is manifestly unfounded, excessive, or repetitive.

The privacy rights described above are not absolute – exceptions and exemptions apply.  If an exception or exemption applies to a privacy right request, Global will explain in a written response to the request.

Global reserves the right to request additional information to authenticate any privacy right request.  If Global is unable to authenticate a request after commercially reasonable efforts to do so, then Global may, in its good-faith judgment, not respond to a privacy right request.

You can appeal Global’s decision about a privacy right request by sending an email to [email protected].  In your email, please provide as much information as possible about the right you wish to exercise and the basis for your appeal of Global’s decision.

Your Account settings also allow you to access, correct or modify certain the personal information processing. You can deactivate and permanently delete your Account and all associated data by calling 1-781-894-8800 (or the customer service number printed on your Loyalty Program card, if applicable) or contacting customer service. You can stop all future information collection through a Global App by uninstalling it.  You also can adjust the permissions in your mobile device operating system or in some cases within the Global App to exercise certain preferences.

  1. HOW WE PROTECT INFORMATION

We use technical and organizational measures designed to protect your information against unauthorized access, use and loss.  Unfortunately, we cannot guarantee the security of information transmitted through the Internet.

You are responsible for maintaining the security of your Account credentials.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security related to your Account.

If you believe that your Account or information that you provided to us is no longer secure, please notify us immediately at 781-894-8800 or [email protected].

  1. HOW LONG WE RETAIN INFORMATION 

Global retains your personal information in identifiable form only as long as necessary for the lawful purpose for which Global collected it or, if longer or shorter, to comply with law, to resolve disputes and to enforce legal agreements.

  1. HOW WE HANDLE A LAW ENFORCEMENT REQUEST 

Global is committed to cooperating with law enforcement while respecting each consumer’s right to privacy.  We respond to valid legal process issued in compliance with U.S. law.

  1. ABOUT CHILDREN’S PRIVACY

We do not knowingly collect personal information from children under age 13 because they are not allowed to use the Services.

If you know that a person under age 13 has provided us with personal information without verifiable parental consent, please notify us immediately at [email protected] or by telephone at 1-781-894-8800 (or the customer service number printed on your Loyalty Program card, if applicable).

  1. WHEN THIS CONSUMER PRIVACY POLICY CHANGES 

From time to time, we will update this Consumer Privacy Policy to add information about new features or services or to address changes in law or business operations.  We will provide ten (10) days advance notice of material changes to this Consumer Privacy Policy that reduce privacy protections so that you have time to review the changes and decide whether you would like to continue to use the Services under the terms of the updated Consumer Privacy Policy.  If you choose not to continue to use the Services under the terms of the updated Consumer Privacy Policy (as of the “Last Updated” date above), then please review Section 6.

  1. HOW TO CONTACT GLOBAL

If you have any questions about this Consumer Privacy Policy, please contact us:

  • by e-mail at [email protected]
  • by telephone at 1-781-894-8800 (or at the customer service number printed on your Loyalty Program card, if applicable)
  • by U.S. mail at 800 South Street, Suite 500, Waltham, MA 02453