Last updated 05/01/2022
G&M Oil takes your privacy seriously. This policy explains how G&M Oil, Inc. collects, uses and protects information when submitted and collected as part of its websites, apps and loyalty services as part of mobile and software applications (collectively referred to as the G&M Platform) that deliver offers and perform age verification. This policy specifically relates to customer data provided directly from the G&M customer.
We collect several types of information (“Information”) including:
• Information that determines the identity of an individual, such as: name, postal address, email address, telephone number, date of birth (for age verification), driver’s license number, other information you provide for us to verify your age, or any other identifier by which you may be contacted online of offline, and cryptographic identifiers unique for your mobile device and used for age verification (“personal information”);
• Information that is about you but individually does not identify you, such as: location data, date and time of your visit to the G&M Oil
Platform, error information, other communication data, and the resources that you access and use on the G&M Oil Platform; and
• About your internet connection, the equipment you use to access our G&M Oil Platform and usage details.
• Information You Provide: We collect Information you provide when you fill out forms to redeem an offer on the G&M Oil Platform. We may also ask you for Information when you complete a survey or report a problem with the G&M Oil Platform. You may be required to provide age information, or other information before responding to an offer on the G&M Oil Platform or when filling out a survey. For example, if you respond to a text-in offer, you must provide your phone number.
• Information We Automatically Collect: When you use the G&M Oil Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
• The dates and times you browse or view offers;
• Age and identity verification information stored when we verified your identity and age;
• Error and other G&M Oil Platform log information we use to fix and correct errors and to protect the G&M Oil Platform;
• Clickstream data;
• How you engage with promotions, including detailed events about your engagement activity;
• Location information;
• If you accessed the offer from a digital channel where your identity is already present (such as social media platforms or through text messages), we may collect the personal information made available through those platforms. For example, we may collect your phone number if you respond to an offer through SMS messages, loyalty account information if you access the offer through your loyalty account, and other personal information if you have made it accessible through your social media account and you access the offer through social media;
• Your email address when you open an email and/or click on a link related to an offer in an email;
• An anonymous identifier may be associated with the Information collected using cookies and related technologies;
• analytics information, such as time of visit, pages visited, time spent on each page of the website, IP address, type and version of
operating system used, browser type and version, and other device details such as your make/model device.
The Information we collect automatically may include Information by which you may be personally identified, or we may maintain it or associate it with other Information we collect in other ways or receive from third parties. The technologies we use for this automatic data collection may include:
• Web Beacons. Pages of the G&M Oil Platform 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 G&M Oil to, for example, count users who have visited those pages or opened an email and for other related G&M Oil Platform statistics (for example, recording the popularity of certain content and verifying system and server integrity).
Platform. The information they collect may be associated with your personal information or they may collect Information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
• Business Partners: We may also obtain Information about you from our affiliates and from other third parties, including:
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the Information we hold; and
• Partners with which we offer certain products or services.
• We may Use Collected Information to:
• Operate, maintain, and improve the G&M Oil Platform and related services;
• Assist in the re-targeting or distribution of future campaigns;
• Facilitate an offer experience, particularly around fraud prevention and per user limits;
• Monitor and optimize active offer campaigns;
• Deliver highly targeted or personalized offers based on past activity or attributes provided by our customers or clients;
• Anonymize and aggregate Information for different purposes, such as platform traffic, user experience analysis, product development, market analysis, case studies, and other forms of internal and external marketing purposes;
• For administrative purposes, such as hosting, processing, and client and customer service;
• To comply with our legal obligations, legal process, resolve disputes, and enforce our agreements;
• For analytics purposes, including through third party tracking and analytics tools, to better understand how consumers are using the G&M Oil Platform.
• In any other way we may describe when you provide the Information.
We may also combine or aggregate any of the Information we collect through the G&M Oil Platform or obtain about you from our affiliates and other third parties for any of these purposes.
How G&M Oil Shares Information
• to our affiliates;
• to contractors, service providers, and other third parties we use to support our business, such as to hosting providers, wireless network providers, etc.
• with other companies (such as social media sites and other advertising platforms) that we work with to operate, maintain and deliver the technology that powers the offer content and related campaign and promotion services, including the ability to deliver personalized offers and advertisements, and to help our clients communicate with you by email or SMS text message;
• we may disclose personal information to third parties (other than those making the offer) to market their products or services. You may opt-out of these disclosures when the choice is made available to you. Advertising companies may use information they directly collect from you in combination with personal information we provide;
• To fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.
We may also disclose your personal information to:
• comply with any court order, law, or legal process to disclose your Information.
We will try to take steps to limit any such disclosure;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of G&M Oil, our clients, or others; and
• In addition, We may provide de-identified or aggregated data to third parties without restriction, including:
• G&M Oil may publish, use and make this information available by working with third parties to build predictive models that use de-
identified data to improve future offer and promotion targeting, including the distribution of online advertisements;
• Those third parties might combine with similar information from all other campaigns and sites to learn about customer affinities and interests, and in general for marketing and promotional purposes; and
• We may also share such de-identified or aggregated data publicly to deliver information about our company and its performance.
All above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Choices About How We Use and Disclose Your Information
We do not control the collection and use of your information collected by third parties described above. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with control over your personal information:
You can learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may
provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
• Do Not Track Disclosures. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what Information we collect or how we use that Information based upon whether such a signal is broadcast or received by us.
• Data Security. While we have implemented security measures to protect against the loss, misuse and alteration of the personal information under our control, unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee that our service cannot be compromised. 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 G&M Oil Platform.
• No Under Age 13: Our G&M Oil Platform is not intended for children under 13 years of age. We do not intentionally gather Information about visitors who are under the age of 13. If you are under 13 years of age, then please do not use or access the G&M Oil Platform at any time or in any manner. If we learn that personally information of persons under 13 years of age has been collected on the G&M Oil Platform, then we will take the appropriate steps to delete this information.
• Children: Certain offers may only be available to you if you meet certain age requirements. You may be required to provide your age or birthdate so we can verify the applicability of certain offers. We respect the age restrictions provided by our clients. We will not knowingly provide any offer to you in violation of federal or state law, including any advertising or marketing any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age.
• Links to Third Party Sites: Our websites may contain links to other sites and services, which are owned and controlled by others. These websites have their own policies regarding privacy, and you should review those policies.
State-Specific Privacy Rights
The law in some states may provide you with additional rights regarding our use of Information. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see the privacy addendum for your state referred to below.
• Your California Privacy Rights: You have the additional rights described the California Privacy Addendum.
have a dispute or complaint about privacy practices, please first contact us regarding the issue. We will do our best to resolve it!
PO Box? [email protected] Effective from January 1, 2022
G&M Oil Privacy Notice Addendum for California Residents
Effective Date: January 1, 2022
Last Reviewed on: January 1, 2022
This Privacy Notice Addendum for California Residents (the “California Privacy Addendum”) describes our collection and use of Personal Information and supplements the information contained in G&M Oil’s ( “we”, or “us”) Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.
Note that this California Privacy Addendum does not apply employment-related personal information collected from our California-based employees, job applicants, contractors, or similar individuals. Please contact your local human resources department if you are a California employee and would like additional information about how we process your Personal Information.
Information We Will Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect the following categories of personal information from our consumers:
Category Applicable Pieces of Personal Information Collected
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
We may also collect your driver’s license number, passport number or other information you provide us to verify your age.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, address, telephone number, passport number, driver’s license or state identification card number.
We may also collect education, employment, employment history, or financial information if required by our clients to redeem an offer.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
We collect your age to verify your eligibility to receive and/or redeem certain offers.
We may also collect race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information) if requested by our clients to redeem an offer.
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data. Physical location or movements.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
Use of Personal Information
We may use, “sell” for monetary or other valuable consideration, or disclose the personal information we collect for one or more of the following business or commercial purposes:
• To fulfill or meet the reason you provided the information. For example, if you give us your contact information to send you offers from our clients, we will use your contact information to send you those offers. This may include verifying your eligibility for some offers (Categories A, B, C, D, F, G, K).
• To provide, support, personalize, improve, and develop the G&M Oil Platform and related products and services (Categories A, B, F).
• To facilitate an offer experience, particularly around fraud prevention and per- user limits. (Categories A, B, F, G).
• To monitor and optimize active offer campaigns (Categories A, B, F, G, K).
• To deliver highly targeted or personalized offers based on your past activity or attributes provided by our vendors through our websites, services, mobile and
software applications, SMS and email messages (with consent where required) (Categories A, B, C, D, F, G, K).
• To perform age verification for certain offers (Categories A, B, C)
• To help maintain the safety, security, and integrity of the G&M Oil Platform, and G&M Oil’s other products and services, databases and other technology assets, and business, and prosecuting those responsible for that
activity (Categories A, B, C, D, F, G, K).
• For internal testing, research, analysis, and product development, including to develop and improve the G&M Oil Platform, and to develop, improve, or demonstrate our products and services (Categories A, B, C, D, F, G, K).
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations (Categories A, B, C, D, F, G, K).
• As described to you when collecting your personal information or as otherwise set forth in the CCPA (Categories A, B, C, D, F, G, K).
• Auditing relating to a current interaction with you and concurrent transactions, including, but not limited to, counting advertising impressions to unique users, verifying positioning and quality of offers, and auditing compliance with any applicable specification and other standards (Categories F, G).
• Debugging to identify and repair errors that impair existing intended functionality (Categories A, F, G, K).
• Short-term, transient use, provided that G&M Oil will not disclosure personal information to another third party and is not used to build a profile about you or otherwise alter you experience outside the current interaction, including, but
not limited to, the contextual customization of ads shown as part of the same interaction (Categories A, B, C, D, F, G, K)
G&M Oil will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sources of Personal Information
Except as otherwise noted below, G&M Oil obtains the categories of personal information listed above from the following categories of sources:
• Directly from you. For example, from forms you complete or offers that you redeem (Categories A, B, C)
• Indirectly from you. For example, from observing your actions using the G&M Oil Platform. (Categories D, F, G, K).
• From third party sources when we verify your age (Categories A, B, C)
• From our other third party sources that provide us your information for other purposes (Categories A, B, C, D, F, G, K)
Sharing Personal Information
G&M Oil may disclose your personal information to a third party for a business purpose or sell your personal information for monetary or other consideration, subject to your right to opt-out of those sales (see Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Sales of Personal Information
monetary and other valuable consideration. Until such guidance has been issued, we continue to consider it a “sale” in order to be as transparent as possible with users of our G&M Oil Platform and will comply with the restrictions of the “sale” of this information to the extent technologically feasible.
In the preceding twelve (12) months, G&M Oil has “sold” the following categories of personal information to the following categories of third parties for monetary or other valuable consideration:
Categories of Third Parties: None
1. California Customer Records personal information categories:
Categories of Third Parties: None
1. Protected classification characteristics under California or federal law:
Categories of Third Parties: None
1. Commercial information:
Categories of Third Parties: None
1. Internet or other similar network activity:
Categories of Third Parties: None
1. Geolocation data:
Categories of Third Parties: None
1. Inferences drawn from other personal information:
Categories of Third Parties: None
We do not sell the personal data of minors under the age of 16 for monetary or other valuable consideration without affirmative authorization.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. You may exercise these rights yourself or through your authorized agent.
You may authorize your agent to exercise your rights under the CCPA on your behalf by registering your agent with the California Secretary of State. You may also provide your authorized agent with power of attorney to exercise your rights. If you authorize an agent, we may require that your agent provide proof that they have been authorized exercise your rights on your behalf. We may request that your authorized agent submit proof of identity We may deny a request from your agent to exercise your rights on your behalf if they fail to submit adequate proof of identity or adequate proof that they have the authority to exercise your rights.
Access to Specific Information and Data Portability Rights
You have the right to request that G&M Oil disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request). We will not disclose your driver’s license number or other government-issued identification number, financial account number, or your account password or security question or answers. We will also not provide this information if the disclosure would create a substantial, articulable, and unreasonable risk to your personal information, your account with G&M Oil, or the security of our systems or networks.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B personal information. Deletion Request Rights
You have the right to request that G&M Oil delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
• Calling us at Phone Number 1 800 403-6142, Option 1.
• Emailing us at customerservi[email protected]
Only you, or your agent that authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, see above. We may request additional information so we may confirm a request to delete your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Opt-Out and Opt-In Rights.
Response Timing and Format
We will respond to a verifiable consumer request within ten (10) days of its receipt. We will generally process these requests within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Opt-Out and Opt-In Rights Regarding the “Sale” of Your Personal Information
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us at the following email: [email protected]
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into the sale of personal information at any time by
emailing [email protected]
You do not need to create an account with us to exercise your opt-out rights. You may be required to provide us with additional contact information so that we may verify your request to opt-in to the sale of your personal information. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of the G&M Oil Platform that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of personal information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared your personal information with for the immediately prior calendar year (e.g. requests made this year will receive information regarding such activities for last year). You may request this information once per calendar year. To make such a request, please send an email to [email protected]
Changes to Our Privacy Notice
G&M Oil reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this notice, the ways in which G&M Oil collects and uses your information described below and in the Privacy Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1 800 403-6142 Option 1 Email: [email protected]