Privacy Statement for Circle K Drive App
1. Who are we?
Circle K AS is a company registered in Norway with an office at Schweigaards gate 16 Oslo, Norway, with company number 995532921, and its affiliates (collectively, “Circle K”, the “Company”, “we”, “us” or “our”) in the European Union / European Economic Area countries where this privacy statement is posted. The relevant Circle K entity in the region is the controller of the data processing described in this privacy statement.
This privacy statement will help you understand how we process your personal data. It will tell you what information we use to provide you with services, what we do to keep your data safe, what partners we engage to process our data, and what your privacy rights are.
2. How and when does a privacy statement apply?
This privacy statement describes how personal data is processed when using the Circle K Drive App (“Service/-s”). It consists of general privacy information related to the service, partners engaged, and your privacy rights and how to use them.
3. Purposes of the processing
We will process non-personal data to provide you with service and to ensure Service functionality. The different purposes of data use are described below.
To ensure service functionality and measure performance
We will process some personal data to ensure the Service's safety and functionality, resolve issues and errors related to the Service, and improve the overall service level. In addition, we will measure and improve the Service performance – we will use data on user interactions on an aggregated level or in an anonymized state.
The legal basis for using personal data is the legitimate interest of Circle K to ensure the functionality and performance of the Service.
4. What personal data do we process?
Personal data is processed to ensure service functionality and security, and to measure performance
The personal data we will collect to ensure Service functionality and security is described below:
1. User interactions with the application, such as the frequency of app usage and generic interaction data. The data shall be used on an aggregated level or anonymized state.
2. Crash logs
3. Diagnostic data such as IT system problems and errors that may originate from user interaction with the Service. These diagnostic data usually do not contain any user data.
Personal data processed to provide you with service
When using the app, Circle K does not process personal data. The following data is used solely on your device and is not transmitted to Circle K:
1. Generic registration code (same for all users in a country)
2. Geolocation data (used only on the device to show surrounding areas without being sent to Circle K systems)
5. What are your rights?
Exercising your rights
You may exercise your rights as a data subject, including the right to object, the right to restrict processing, or ask us questions by contacting Circle K via e-mail, phone, or post or through the Circle K ID page: https://id.circlekeurope.com. The contact details are available in paragraph 10 of this statement. Some requests, like access to data, specific questions related to data analysis as such, or any other question you can request further access, need to be made in writing.
Right to information
These terms and conditions constitute special information about how we will process your personal data and what data will be processed as part of the Services. They supplement the general Circle K Privacy Statement, which is available at https://www.circlek.no/personvern.
Access to data
You have the right to, at any time, request from us a copy of the information about you that we store. Such request shall be in writing. If you have specific questions related to data analysis or any other questions, you can request further access. Most information is available to you on the mobile application, which contains the necessary personal data we store about you to provide you with the Services. Requests for access to data shall be made in writing; see more at https://id.circlekeurope.com.
Rectification of data
If your personal data changes, you can rectify (correct) your own personal data in the application's account settings.
If you have specific questions or experience problems related to rectification as such or any other question, you can request further assistance by contacting Circle K. Such request shall be made in writing.
Right to data portability
You have the right to ask that we transfer the information you gave us to another. This only applies to the information you have given us. Commercially sensitive information that was created based on your anonymized data shall not be transferred.
Rights related to profiling and automated decision-making
You have the right not to be subject to a decision based solely on automated processing, including profiling. You can submit an objection to any automated decision we have made and ask a person to review it.
Deletion of personal data
You have the right to request deletion of some of your personal data. However, some data, such as transactions, must be retained in accordance with local jurisdiction requirements.
Right to object
You may have the right to object to processing if we are processing your information on the basis of legitimate interests. You may submit an objection by contacting our customer service.
Right to restrict processing
You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.
You may exercise your right to restrict processing by contacting Circle K via e-mail, phone, or post or through the Circle K ID page: https://id.circlekeurope.com. The contact details are available in paragraph 10 of this statement.
Dispute resolution
Should you have any concerns related to personal data processing, you may reach out to privacy@circlekeurope.com to resolve the issue, and if you wish, you can request the involvement of the group Data Protection Officer.
Our supervisory authority, in most cases, is the Norwegian Data Protection Inspectorate, whose contact information is available here: https://www.datatilsynet.no.
You may also contact your local Data Protection Supervisory Authority if you wish to lodge a complaint. Contact details can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
6. Data processors and transfer of data
Circle K will share the personal data gathered through the Service with its partners (also known as "data processors") to administer the functionality and availability. However, please note that external service providers supplying data (such as locations of charging points and stores) do not process personal data on behalf of Circle K. Before processing your personal data with our partners, Circle K shall ensure that relevant data protection procedures are in place to comply with applicable data protection laws, such as but not limited to GDPR. As such, Circle K shall sign relevant data processing agreements with the partners.
Currently, no specific third-party processors are listed for this app, as no personal user data is shared externally beyond what is necessary for geolocation services, which are handled locally on your device.
At the same time, we may process some personal data in our internal systems, which we use to maintain our business. These systems are usually supported by Microsoft, Oracle, or other partners specializing in ICT services.
Circle K datacenters and datacenters of our partners enabling you to receive Circle K ID services are generally located in the EU / EEA or in countries recognized by the European Commission to provide an adequate level of data protection. In case Circle K engages partners from other countries outside of EU / EEA (also known as “third countries”), Circle K shall ensure that relevant data protection procedures are in place to comply with applicable data protection laws, such as but not limited to GDPR.
7. Personal data retention
Circle K will retain user data for as long as necessary for the purposes for which it was originally collected. This means that we will retain different categories of data for different time periods depending on the data type and the purposes for which it was collected.
8. Protecting your personal data and respecting privacy
Circle K will not gather, use, or disclose any personal data about a customer that is not aligned with the original purposes and without ensuring an appropriate legal basis. We will never sell your data. We will maintain the security and confidentiality of the information according to the relevant laws and industry standards, and we will ensure that only authorized personnel may access your personal data.
We may grant our partners access to personal data. This will be done to the extent necessary to support our maintenance and administration of the Service.
Data that may be used for our research, scientific, and business performance analysis purposes is anonymized, so you cannot be identified from it.
9. Updates to this statement
We hope you will find this privacy statement easy to understand.
Data protection laws are important – they strengthen your rights and ensure fair and transparent information processing by organizations. While many of these rules may appear complicated, most of them derive from common sense and general respect for each other and the environment. We take our data protection responsibilities seriously, and we require the same from our partners.
We may periodically update this statement to improve it as part of our commitment to protecting your privacy.
10. Circle K Europe affiliate contact information
Couche-Tard Deutschland GmbH & Co.
By e-mail: privacy@circlekeurope.com
By post mail: Couche-Tard Deutschland GmbH & Co. KG, Jean-Monnet-Straße 2, 10557 Berlin, GERMANY
Circle K Nederland BV
By e-mail: privacy@circlekeurope.com
By post mail: Bezuidenhoutseweg 273, 2594 AN The Hague, NEDERLANDS
Circle K Belgium SA
By e-mail: privacy@circlekeurope.com
By post mail: Circle K Belgium SA – Legal Service, Boulevard Anspach 1 box 2, 1000 Brussels, BELGIUM
Circle K Luxembourg SA
By e-mail: privacy@circlekeurope.com
By post mail: Circle K Luxembourg SA, GDPR Correspondent 310 Route d’Esch L-1471 Luxembourg, LUXEMBOURG