EFFECTIVE DATE: JANUARY 1, 2023
LAST UPDATED: January 2, 2024
Thorntons brand is owned and operated by Thorntons LLC (collectively, “Thorntons”, “we” or “us” or “our”). Thorntons respects your privacy and is committed to protecting it. We provide this Privacy Policy (“Policy”) to inform you of our privacy practices and of the choices you can make about the way your personal information is collected and how that information is used.
This Policy applies to all personal information collected at Thorntons merchant locations, during any written, electronic, and oral communications with Thorntons representative parties, or by our Thorntons services online (collectively, the “Services”). Thorntons online Services include the website located at https://www.refreshingrewards.com and all corresponding webpages and websites that link to this Policy (“Site”), Thorntons Refreshing Rewards mobile application (e.g., Apple iOS apps, etc.) (collectively and individually, (“App”); and any other content, applications, features, functionality, information and services offered by us though the Site and/or the Apps.
Please read our Terms and Conditions (https://www.mythorntons.com/terms-and-privacy/) and this Policy before accessing or using our Services. By using our Services, you accept the Terms and Conditions and accept our privacy practices described in this Policy. If you cannot agree with this Policy or the Terms and Conditions, please do not access or use our Services.
We may modify this Policy at any time, without prior notice, and changes may apply to any personal information we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advanced notice if we make any material changes to how we collect, use or disclose your personal information that impact your rights under this Policy. If you continue to access or use our Services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.
In addition, we may provide you with real time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your Personal Information.
We collect personal information when you use our Services, create an account with us or submit personal information to us. The types of personal information that we may collect about you include:
We collect this personal information when you use our Services or interact with us, such as when you submit your information through the Services or communicate with us, or through automated means as described below. We also obtain your personal information from other sources, including our affiliates and subsidiaries, our partners, our vendors, third-party online services, and social media platforms. In addition, we may obtain other personal information about you in ways that we describe at the time of collection.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless otherwise done for the purposes identified in this Privacy Statement or permitted by applicable law.
We may use cookies, tags, and similar technologies to automatically collect information on our Services. These tracking technologies allow our technology providers to collect information including your IP address, your mobile device identifier, the type of internet browser you are using, operating system, referral URLs, date/time stamps, pages viewed, and simple keyword tags. Cookies or tags are bits of code that allow our technology partners to collect the information described above. We also use web pixels to analyze usage patterns on our Site. The use of a pixels allows Thorntons to record that a particular device, browser, or application has visited a particular webpage.
If you are a Connecticut, Utah, or Virginia consumer, you may have the right to (1) request access to, (2) correction of, or (3) deletion of your personal information; and (4) opt-out of the processing of your personal information for purposes of targeted advertising, certain profiling, or the sale of your personal information. In addition, you may have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format. To exercise these rights, please contact us by phone at 1-866-473-0017 or by email at guestservices@mythorntons.com. You also may opt out of the processing of your personal information for purposes of targeted advertising by clicking here.You may appeal our decision with respect to a request you have submitted by emailing us at guestservices@mythorntons.com.
We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place.
Operating Our Business
a. To Provide You, Our Services. We will use your personal information to provide information or perform Services that you request. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing applicable Services. All third parties that we work with are contractually obligated to protect your information, as disclosed in this Policy.
b. For Internal Use. We use your personal information for the purposes of furthering our business, including improving our Site’s content and functionality by analyzing where, on which types of devices and how our Site is used, how many visitors we receive, and where they click through to the Site from. We also use it to remember you in case you re-visit our Site, so we will know if you have already been served with surveys or (where Site content is undergoing testing) which version of the content you were served.
Communicating with You
c. To Provide You with Service-Related Communications. We will send you administrative or account-related information to keep you updated about your account and the Services. Such communications may include information about Policy updates, confirmations of your account actions or transactions, security updates or tips or other relevant transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise, you may miss important developments relating to your account or the Services.
d. To Provide Customer Support or Respond to You. We collect any information that you provide to us when you contact us. Without your Personal Information, we cannot respond to you or ensure your continued use and enjoyment of the Services.
Security, Compliance and Enforcement
a. To Ensure the Security of the Services. We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information. We cannot ensure the security of our Services if we do not process your personal information for security purposes.
b. To Enforce Compliance with Our Terms and Agreements or Policies. When you access or use our Services, you are bound to our Terms and Conditions and this Policy. To ensure you comply with them, we process your personal information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your personal information to: investigate, prevent or mitigate violations of our internal terms, agreements or policies and enforce our agreements with third parties and business partners.
c. To Maintain Legal and Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, ensure compliance with employment and recruitment laws or as necessary to manage risk as required under applicable law. Without processing your personal information for such purposes, we cannot perform the Services in accordance with our legal and regulatory requirements.
Administer Our Rewards Programs
d. To Operate the Refreshing Rewards program. We use your information to operate the refreshing reward program, for example to ensure that you can take advantage of the offers we make through the use of our Services, provide other services related to the program and ensure that the applicable Terms and Conditions are observed. We also use your personal information related to the refreshing rewards program for the following purposes:
I. To Send You Relevant Direct Marketing Communications – As part of the registration process, you will be asked to indicate your preferences for receiving Thorntons marketing communications containing information and offers about Thorntons products, promotions, and services and those of our partners in the program. These communications may, depending on your selected preferences, be sent from Thorntons by email, text, push notification, and mail. You can opt out of receiving these direct marketing communications at any time by following the instructions set out in each marketing communication or by changing your preferences within your account settings on the app, or on the Refreshing Rewards website, or by contacting guestservices@mythorntons.com
II. To Provide You Personalized Offers – Thorntons will use your information to analyze and understand your shopping behavior based on your purchases at our locations so that we can provide you with personalized offers and marketing communications which we think will be of interest to you. To help us better understand you as a customer, we will also analyze how you use the refreshing reward program and how you interact with our app and other marketing channels, including assessing the effectiveness of our offers and marketing communications. As part of this, we can show or send you tailored Thorntons offers and advertisements when you are browsing the internet using cookies. Please visit section 2 of this Privacy Statement to find out more about our cookie usage.
III. To Conduct Customer Research and Surveys – We will use your Refreshing Rewards data to send you invitations by email to participate in voluntary surveys so that we can improve the Refreshing Rewards program, our offers and customer communications.
We will also analyze and use your data (on an anonymized, aggregate level, which does not identify any specific information), to carry out research into how customers are interacting with Thorntons and the Refreshing Reward program so that we can improve our products, services, and customer communications.
Certain laws consider the exchange of personal information with third parties as a sale, even in the absence of monetary considerations, therefore, our engagements with third parties may be considered a sale under applicable laws. To opt-out of the sale or sharing of your personal information, please contact us at 1-866-473-0017or by email guestservices@mythorntons.com We may disclose the categories of personal information described above as follows:
e. Within Our Corporate Organization. Thorntons is a part of a corporate organization that has many legal entities, business processes, management structures and technical systems. Thorntons may share your personal information within this organization to provide you with the Services and take actions based on your request and provide you with complimentary offers from Thorntons affiliated brands: bpme, bp pulse, ampm, Castrol and TravelCenters of Americas. Where this is the case, we do this under a comprehensive, flexible, and global compliance framework which implements appropriate measures and safeguards to ensure that your personal information is protected in accordance with applicable data protection laws.
f. Service Providers. We may share your personal information with service providers acting on our behalf to help us operate our Services and for marketing purposes. These service providers can only use your data in accordance with our written instructions and must comply with the information security protections we have put in place.
g. To Maintain Legal and Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on Thorntons. If there is a takeover, sale or purchase of our business, we may disclose your personal information to the new (or prospective) owner of the business.
We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information. We restrict access to your non-public personal information to those employees and third parties who need such information to provide products or Services. Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password.
We will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected as noted in section 3 and section 10(b). We may retain some of your personal information for a longer period insofar as it may be necessary to defend or prosecute any legal claim(s).
Generally, your personal information is held from the date you create your account for as long as the Services exist. If you are a Virginia or California resident and you request account deletion, we will delete or deidentify your associated account data so that it no longer directly identifies you.
If you send us correspondence, including emails and faxes, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from Thorntons to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records, as permitted by law.
Our Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit, as we are not responsible for the privacy practices of those sites.
Our Services are not directed to, and we do not knowingly collect personal information from children under the age of 18. If you are under 18, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information from our files.
We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. You can update your contact details and other data via your account settings in the Thorntons app or on the Refreshing Rewards website. Please notify us at guestservices@mythorntons.com if there are any further changes that you would like our assistance on, providing us with sufficient information to enable us to identify you, so that any changes can be made.
This section applies only to California residents and does not apply to personal information collected about Thorntons personnel, job applicants or business partners. This section uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). For more information about the personal information, we collect and how we collect it, please refer to sections 1 and 2 above.
a. Personal information categories collected. We may collect (and may have collected during the 12-month period prior to the Last Updated date of this section 10) the following categories of personal information when you use our Services:
b. Purposes for processing personal information. We may use (and may have used during the 12-month period prior to the Last Updated date of this section 9) your personal information for the purposes described in section 3 and for the following business purposes:
c. Retention of Personal Information. We will retain your personal information in accordance with section 6 above, but in no case longer than the time period reasonably necessary to achieve the purposes described in section 3 and section 9(b), or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.
d. Sources of Personal Information. We may obtain your personal information from the following sources::
e. Sale or Sharing of Personal Information. We do not sell your personal information in exchange for monetary compensation; however, we may share your personal information by allowing certain third parties (such as online advertising services and social networks) to collect personal information via automated technologies on our Services for social networking and cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this section 8), the following categories of personal information about you to online advertising services and social networks:
You have the right to opt-out of this disclosure of your information, as detailed below. We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
f. Disclosure of Personal Information. During the 12-month period prior to the Last Updated date of this section 9, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
Categories of Personal Information | Categories of Third Parties |
Identifiers
| · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms · Data analytics providers · Internet service providers · Operating systems and platforms · Online advertising services and advertising networks · Social networks
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Commercial Information | · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms · Data analytics providers · Internet service providers · Operating systems and platforms · Online advertising services and advertising networks
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Online Activity | · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms · Data analytics providers · Internet service providers · Operating systems and platforms · Online advertising services and advertising networks
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Geolocation Data | · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms · Data analytics providers · Internet service providers · Operating systems and platforms · Online advertising services and advertising networks
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Sensory Information | · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms
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Inferences
| · Our affiliates and subsidiaries · Vendors who provide services on our behalf · Professional services organizations, such as auditors and law firms · Data analytics providers · Internet service providers · Operating systems and platforms · Online advertising services and advertising networks · Co-sponsors of contests, sweepstakes, or other promotions
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g. California Consumer Privacy Rights. You have certain choices regarding your Personal Information, as described below personal information.
How to Submit a Request. To submit an access, correction or deletion request please contact us by phone at 1-866-473-0017or by email guestservices@mythorntons.com. To opt out of the sale or sharing of your Personal Information, click here. To submit a request as an authorized agent on behalf of a consumer, please guestservices@mythorntons.com with the subject line Authorized Agent Request”. To submit a Shine the Light request, please contact us at guestservices@mythorntons.com. In your request, please specify that you want a “California Privacy Rights Notice.”
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you have an online account with us, we may verify your identity by requiring you to sign into your account. If you do not have an online account with us and you request access to, correction of or deletion of your personal information, we may require you to authenticate your email address on record with us or to provide information about your transactions or prior interactions with us. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
Notice of Financial Incentive: The Refreshing Rewards Program offers members of the program certain loyalty promotions and benefits in connection with their disclosure of personal information to Thorntons.
To participate in our loyalty program, or other offerings contained in the Services, we require your first and last name, email, phone number, date of birth, and zip code. We also collect the personal information mentioned in Sections 1 and 10(a) above in connection with your participation in the Services.
Subject to certain restrictions, we offer users who create an account and who participate in the Refreshing Rewards program, the opportunity to be eligible for certain loyalty benefits, discounts, promotions, and giveaways. These offers include 5 cents to 25 cents off each gallon of fuel as well as convenience store food and drink discounts and giveaways. For more information on the terms of the Services, please click here.
To participate in the Services, you must first consent to the Refreshing Rewards Terms and Conditions and create an account on the App or Site. You may withdraw from the Program at any time by accessing the deletion option in the App or by emailing us at guestservices@mythorntons.com.
Because the Services offer loyalty benefits, discounts, promotions, and giveaways in exchange for the collection, retention, and the potential sale and sharing of the personal information required for your participation in the Services, they may be interpreted as a “financial incentive” program under California law. The loyalty benefits, discounts, promotions, and giveaways offered in connection with the Services are reasonably related to our good faith estimate of the value provided to Thorntons by your personal information. We estimate that the value to Thorntons of the personal information you provided to facilitate participation in the Services is reasonably related to the financial incentives less the expenses related to offering these financial incentives.
If you have questions or concerns regarding any information in this Policy, please contact us by phone at 1-866-473-0017 or by email at guestservices@mythorntons.com. You can also contact us by mail Thorntons LLC, Attn: Privacy Matters, 2600 James Thornton Way, Louisville, Kentucky 40245.
Thorntons Refreshing Rewards program is available at participating Thorntons locations.
These Terms and Conditions are subject to change, at any time, without notice, at the sole discretion of Thorntons LLC
The following conditions and restrictions apply:
There is no fee from THORNTONS to receive text messages. Message and data rates may apply- this can be checked with your mobile service provider. Charges are billed and payable to your mobile service provider or deducted from your prepaid account. Consent is not a requirement for purchase.
Data obtained from you in connection with this SMS service may include your mobile phone number, your carrier’s name and the date, time and content of your messages. We may use this information to contact you and provide the services you request from us. Alerts sent via SMS may not be delivered if the mobile phone is not in range of a transmission site, or if sufficient network capacity is not available at a particular time. Even within a coverage area, factors beyond the control of the wireless operator may interfere with message delivery, including the customer’s equipment, terrain, proximity to buildings, foliage, and weather. Wireless operators do not guarantee message delivery and will not be held liable for delayed or undelivered messages.
For information on data collection and us, please read our full corporate Terms and Privacy – Thorntons (mythorntons.com)
We will not be liable for any delays in the receipt of any SMS message as delivery is subject to effective transmission from your network operator.
By subscribing to THORNTONS alerts, the user consents to receive automated text messages from THORNTONS. Recurring messages. Message & data rates may apply.
If you have any questions, text HELP to 80313 or contact us at 866-473-0017 or guestservices@mythorntons.com. To stop receiving messages, text STOP to 80313.
Thorntons brand is owned and operated by Thorntons LLC (collectively, “Thorntons”, “we” or “us” or
“our”). Thorntons respects your privacy and is committed to protecting it. We provide this Privacy Policy
(“Policy”) to inform you of our privacy practices and of the choices you can make about the way your
personal information is collected and how that information is used.
This Policy applies to all personal information collected at Thorntons merchant locations, during any
written, electronic, and oral communications with Thorntons representative parties, or by
our Thorntons services online (collectively, the “Services”). Thorntons online Services include the website
located at https://www.refreshingrewards.com and all corresponding webpages and websites that link to
this Policy (“Site”), Thorntons Refreshing Rewards mobile application (e.g., Apple iOS apps, etc.)
(collectively and individually, (“App”); and any other content, applications, features, functionality,
information and services offered by us though the Site and/or the Apps.
Please read our Terms and Conditions (https://www.mythorntons.com/terms-and-privacy/) and this Policy
before accessing or using our Services. By using our Services, you accept the Terms and Conditions and
accept our privacy practices described in this Policy. If you cannot agree with this Policy or the Terms and
Conditions, please do not access or use our Services.
We may modify this Policy at any time, without prior notice, and changes may apply to any personal
information we already hold about you, as well as any new personal information collected after the Policy
is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will
provide you with advanced notice if we make any material changes to how we collect, use or disclose
your personal information that impact your rights under this Policy. If you continue to access or use our
Services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.
In addition, we may provide you with real time disclosures or additional information about the personal
information handling practices of specific parts of our Services. Such notices may supplement this Policy
or provide you with additional choices about how we process your Personal Information.
We collect personal information when you use our Services, create an account with us or submit personal information to us. Personal information is any information that relates to you, identifies you personally or could be used to identify you, including but not limited to your user ID, name, email address, phone number and address. The types of personal information that we may collect about you include, but are not limited to:
We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place.
Other than sharing your personal information so that you can use our Services, or as required or permitted by law, we do not share personal information about our members or former members with non-affiliated third parties. We may disclose your personal information as described below.
We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information. We restrict access to your non-public personal information to those employees and third parties who need such information to provide products or Services.
Please recognize that protecting your personal information is also your responsibility. We ask you to be responsible for safeguarding your password.
We will retain your personal information only for as long as is necessary in order to fulfill the purposes for which it was collected as noted in section 3 and section 9(b). We may retain some of your personal information for a longer period insofar as it may be necessary to defend or prosecute any legal claim(s).
Generally, your personal information is held from the date you create your account for as long as the Services exist. If you are a Virginia or California resident and you request account deletion, we will delete or deidentify your associated account data so that it no longer directly identifies you.
If you send us correspondence, including emails and faxes, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from Thorntons to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records, as permitted by law.
Our Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit, as we are not responsible for the privacy practices of those sites.
Our Services are not directed to, and we do not knowingly collect personal information from children under the age of 18. If you are under 18, please do not attempt to fill out our forms or send any personal information about yourself to us. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information from our files.
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Categories of Personal Information |
Categories of Third Parties |
| Identifiers |
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| Commercial Information |
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| Online Activity |
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| Geolocation Data |
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| Sensory Information |
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| Inferences |
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If you have questions or concerns regarding any information in this Policy, please contact us by phone at 1-866-473-0017 or by email at guestservices@mythorntons.com. You can also contact us by mail Thorntons LLC, Attn: Privacy Matters, 2600 James Thornton Way, Louisville, Kentucky 40245.
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