Speedway Privacy Notice

Table of Contents

1. Personal Information We Collect
2. How We Use Personal Information
3. How We Share Personal Information
4. Children’s Privacy
5. Updating Account Information
6. Communications with Us and Your Choices
7. Speedy Rewards Mall; Speedy Café; & Links to Third Party Sites
8. Cookies and Online Advertising
9. Location of Services
10. Do Not Track Signals
11. Security
12. Updates to the Privacy Notice
13. Contact Us
14. Additional Notice for California Residents

This Privacy Notice describes the practices of Speedway LLC (“Speedway”, “we,” or “us”) with respect to personal information of consumers. This Privacy Notice applies to personal information we collect through our websites including, Speedway.com, www.speedycafe.com, www.mall.speedway.com, and Speedway’s mobile website and other websites owned or operated by Speedway (the “Sites”), mobile apps (the “Apps”), emails, messaging, information collected when you visit Speedway locations, social media pages we control, any other materials that link to this Privacy Notice, and other interactions with our consumers described herein. In this Privacy Notice, we refer to our Sites and Apps, and the services we offer through them as our “Services.”

This Privacy Notice applies to Speedway’s activities within the United States.

1. Personal Information We Collect

We may collect personal information about you when you use our Sites or Apps, visit our stores, or otherwise interact with us. “Personal information” does not include: (i) anonymous or anonymized information; or (ii) transaction data related to purchases at Speedway stores unless we combine such transactional data with information that can uniquely identify you. The information we collect generally falls into four categories: (a) information you provide us; (b) information we collect through automated means, (c) communications with us, and (d) data provided by others.

1. Information You Provide to Us: You may provide personal information to us, depending on how you interact with us. Personal information consumers provide to us often falls into four categories:

   • Personal details, such as your name, postal and email addresses, phone number, and other contact information;
   • Account and profile information, such as your username or password, profile data, birthday information, preferences, demographic information (such as age or gender), products and services you like, and information about how you like to shop with us;
   • Transaction information, including information about the products you buy, prices, method of payment and payment details; and
   • Other personal information you choose to provide us when you interact with us.

   The personal information we collect depends on how you interact with us. Generally speaking, we collect personal information from you in the following situations:

   1. Making purchases or otherwise transacting with us for products and services, whether in our stores, online, or otherwise through our Services (such as purchases on our Sites or Apps);
   2. Joining our loyalty, rewards, or similar programs (such as the Speedy Rewards Program) – including by downloading the Speedway App;
   3. Participating in contests, sweepstakes and promotions;
   4. Providing feedback or participating in surveys, such as our customer insight panels;
   5. Providing information or content to us via our Services;
   6. Scanning your driver’s license for age restricted products (such as tobacco and alcohol products), where we are required to do so;
   7. Otherwise interacting with us or our Sites, Apps, or Services.

2. Data Collected Automatically: We may use automated technology to collect information from your browser or mobile device when you use our Services or visit our stores. Information collected includes:

   1. Data collected by our Sites and Apps: When you use our Site or our Apps, certain data about your web browser or mobile device are automatically collected in connection with our providing the Site or App to you. This can include your IP address, device type, device identifier or advertising identifier (or similar identifier), operating system, referring site or ad or application, online activity on other sites or apps, and information about how you use our Sites or Apps (such as the parts of the Site or App you view, click, or otherwise interact with). If you consent, it can also include your location (which you can disable at any time in your device settings).

   2. Data collected by cookies and similar technologies: Our Sites and Apps, as well as emails we send you, may use cookies or similar technologies to collect information about your browser, device, and activity on our Site or App. Information cookies collect may include the information listed above under “Data collected by our Sites and Apps.” For more information, see the below section titled “Cookies and Online Advertising.”

   3. Data collected automatically in-store: When you visit our stores, certain information may be collected automatically relating to you, your device, and/or your visit, including by our Apps and by in-store technologies.

3. Communications with Us: If you communicate with us – for instance if you contact our Customer Service Team – we may collect your name, email address, phone number, any information you provide in your initial and follow-up communications with us. If you speak with our representatives, you will be informed at the beginning of the call if the call is being recorded. Similarly, if you interact with us on social media (such as Facebook or Twitter), we may obtain your username and any information you provide in communications to us.

4. Data provided by Others: We may collect information about you from other companies and organizations, such as data companies, payment processors, delivery partners, or other companies. We may also collect information that is publicly available; for example, we may receive information when you mention us on social media. Also, your friends may provide your information to us so that we can invite you to consider a product or service your friends are using.

We may combine the information you provide us with information that we collect through other sources.

2. How We Use Personal Information

We use the personal information we collect for the following business and commercial purposes:

• Operate our business, including by providing our Services, Site, Apps, our programs, in-store technologies and experiences, and our other products and services to you; and by processing your transactions, orders, or purchases, and maintaining your account(s) with us; identify and validate your device(s); manage and administer our business; or report on or assess the effectiveness of our operations or any other business activities;

• Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;

• Conduct research and analytics, including to monitor and analyze trends, usage and activities in connection with our Services, Site, Apps, and programs, conduct consumer and operations research, learn more about our consumers and their behaviors and preferences, or otherwise evaluate, assess, and improve our business, Services, Site, Apps, programs, experiences, other products and services, and technologies, and develop new products, services, and technologies;

• Market to you and others, including by communicating with you about products, services, offers, promotions, rewards, and events offered by Speedway and others, and provide news, content, or other information we think will be of interest to you or that is tailored to your interest or your use of our Services or programs;

• Customize or personalize your experience in our stores, Sites, Apps, or Services, or any other interaction with us, or customize or personalize rewards, offers, or promotions tailored to you;

• Communicate with you about purchases, orders, accounts with us or inquiries or requests made to us, including by responding to your comments, questions, and requests, and providing customer service;

• Send you technical or transactional notices, updates, security alerts, and support and administrative messages;

• Link or combine information with other information we get from our Services, Site, Apps, or programs, and from others;

• Protect the security and integrity of our Services, including by troubleshooting issues and detecting, using fraud-prevention technology, investigating and preventing errors, fraudulent activity, liability, or any other illegal or potentially wrongful or harmful activities;

• Protect the rights, property, health, and interests of you, Speedway, any other person or third party, or the general public;

• Comply with, make claims relating to, or enforce legal rights or obligations, legal process, our policies, government requests, or prudent security or business practices;

• Monitor, report, and audit compliance issues; and

• Carry out any other purpose described to you at the time the information was collected or permitted by law.

We retain personal information for as long as necessary to fulfill the purposes for which that personal information was collected or for the purposes listed in this Privacy Notice, and as otherwise permitted or required by law.

3. How We Share Personal Information

We may share personal data with third parties for any purpose described in Section 2 above (“How We Use Personal Information”). The categories of third parties who receive personal data are generally as follows:

• The Speedway Corporate Family. We may share the information we collect about you between and among Speedway and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

• Service Providers and Business Partners. We may disclose your information to vendors, consultants and other service providers and business partners who help with our business operations (such as payment processing, web hosting, operations of our Sites or Apps, product and order fulfillment, delivery or shipment, research, IT, consumer requests management, direct mail and email distribution, analytics and insights, fraud detection and investigation, bill collection, or legal and compliance services). Similarly, we may share data with business partners that assist us in providing Services or programs to you, such as social media networks that may facilitate your ability to participate in our loyalty or rewards programs.

• Compliance, Legal Claims, or with Government Agencies. We may share information collected about you in connection with complying with, making claims relating to, or enforcing legal rights or obligations, legal process, our policies, government requests, or prudent security or business practices. This can result in data sharing with law enforcement, governmental agencies, or authorized third parties, for instance in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or others to legal liability, or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;

• In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations concerning, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company or other business transaction.

• After Notice to you, or with your Direction or Consent. We may share your information with your direction or consent, or after providing appropriate notice to you. As an example, if you click on social sharing features on our Services (such as a “Like” button), you are directing information about you to be shared with a social media platform.

4. Children’s Privacy

Our Services – including our Site and Apps – are intended for general audiences and are not intended for individuals under the age of 13. We do not knowingly collect personal information from our Services from users in this age group.

Please note that some Services, loyalty programs, promotions, contests, or portions or features of them, may only be available to individuals who are 16, 18, or 21 years old or older. The terms and conditions applicable to the specific Service, loyalty program, or contest or promotion will inform you of whether you must be a specific age to participate.

5. Updating Account Information

You may update and correct certain account information you provide to us at any time by logging into your account. If you wish to delete or deactivate your account, please contact us as directed in the “Contact Us” section below. Please note, even if you delete or deactivate your account, we may retain certain information as permitted or required by law. Also, if you elect to delete your Speedy Rewards loyalty account, you will lose all points and rewards you have earned.

6. Communications with Us and Your Choices

We may send you marketing communications via email or text message, as permitted by law. If you would like to stop receiving marketing emails or text messages, you can opt-out at any time as follows:

• If you no longer wish to receive marketing text messages you may text the word “STOP” to 54181 from the mobile device on which you no longer wish to receive texts.

• If you no longer wish to receive marketing emails, click on the hyperlink titled “Unsubscribe” at the bottom of any marketing email, and then follow the directions to unsubscribe from email.

You can also opt-out of both texts and emails by modifying your communications preferences in your account settings located in the Apps. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.

Lastly, with your consent, our Apps may send you push notifications. You can turn push notifications off at any time in your mobile device settings.

7. Speedy Rewards Mall; Speedy Café; & Links to Third Party Sites:

We work with third-party partners to complete and process customer orders on Speedy Rewards Mall and on Speedy Cafe. To process your transaction, and to make sure that the products that you order are correctly shipped, our third-party partners require certain personal information from you. Specifically, for Speedy Rewards Mall, you are required to create an account with our third-party partner, which requires your name, address, method of payment information, telephone number and email address. And for Speedy Café, which is available in select markets, you are required to provide our third-party partner with your first name, last name, email, telephone number, and Speedy Rewards number to process your order, and if you are paying online, your method of payment information.

This personal information is used by Speedway and its third-party partners to process your transaction, including shipping products to you. In addition, if you’ve set up an account with our third-party partner to process your Speedy Rewards’ Mall purchases, you may receive marketing offers from our third-party partner.

Please be aware, however, that by deleting your account(s), Speedway and our third-party partners will not be able to process future Speedway Mall or Speedy Café orders unless you set up a new account.

Our Services may contain links or plugins to other web sites, including our affiliated or co-branded web sites. Other web sites may also reference or link to our Services. These other web sites are not controlled by Speedway. We encourage our users to be aware when they leave our Services to read the privacy policies of each and every web site that collects personally identifiable information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other web sites or mobile applications. Visiting these other web sites is at your own risk.

8. Cookies and Online Advertising

Our Services may use cookies and similar technologies (like pixels or web beacons). Both we and others (such as our advertising networks) may use these technologies to collect information about your online activities, over time and across our Services and third-party websites and devices. This information may be used by Speedway and others for the purposes listed in Section 2 above (“How We Use Personal Information”), including, among other things, to provide Services, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, personalize your experience, and better understand your online activity.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. Your web browser or device may also include features or settings that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes; for more information, consult the settings of your browser or device.

9. Location of Services

Speedway is based in the United States. We collect, process and store information in the U.S. and other countries. If you use our Services, your information may be collected and stored in the United States or other countries. This may mean your personal information is collected in a country, or transferred to a country, that may not provide equivalent levels of data protection as the country where you live. If so, your personal information will be subject to the laws of the country in which it is collected and/or to which it is transferred.

10. Do Not Track Signals

As of the effective date of this Privacy Statement, there is no commonly accepted response to Do Not Track signals initiated by browsers. Therefore, our Services are not designed to respond to such signals.

11. Security

Speedway implements security measures in an effort to protect your personal information. But note, given the inherently open nature of the Internet, Speedway cannot guarantee that information transmitted between you and us will always remain secure. We may also require you to assist us to safeguard your personal information. For instance, if you create an account with our Services, you should use unique and strong passwords, not share your passwords with others, and take any other measures we may require under the terms & conditions applicable to the Service you use.

12. Updates to the Privacy Notice

This Privacy Notice is effective as of the date noted at the top of this page. We may change this Privacy Notice from time to time and, if we do, we will post the revised version here and update the effective date below. We may also provide additional notice or information about changes if we deem it required under applicable law. You should check this page regularly for the most up-to-date version of the Privacy Notice.

13. Contact Us

If you have any questions or comments about our Privacy Notice, you may email us at privacypolicy@7-11.com. Please do not email any confidential, sensitive or personal information to this email.

You may also send any questions, comments, or concerns about our Privacy Notice to the following address:

Speedway LLC
c/o 7-Eleven, Inc.
Attn: Privacy Office
3200 Hackberry Road, Irving, TX 75063

• https://www.speedway.com/about/contact
• privacypolicy@7-11.com
• 1-800-643-1948

14. Additional Notice for California Residents

This part of our Privacy Statement applies to consumers who reside in the State of California.

1. Personal Information we collect about California Consumers

   We describe the personal information we have collected about California consumers in the last twelve (12) months in the part of this Privacy Notice titled “Personal Information We Collect”. The information we have obtained includes the following:

   • Identifiers
   • Personal information described in Cal. Civil Code Section 1798.80(e) (California’s Customer Records Statute)
   • Commercial Information
   • Internet or other electronic network activity information
   • Geolocation data (as stated above, you can disable location data collection at any time in your device or browser settings)
   • Characteristics of protected classifications
   • Audio information (e.g. from calls placed with customer service centers)
   • Inferences drawn from any of the above-listed types of personal information

   We obtain the above categories of personal information from a variety of sources, which are described above in the section titled “Personal Information We Collect”.

2. Business Purposes for which we Use Personal Information

   We use the personal information we collect for our operational purposes, including all purposes notified to you in “How We Use Personal Information”. For clarity, our uses of personal information include all uses that constitute “business purposes” or “commercial purposes” under the California Consumer Privacy Act.

3. Disclosures of Personal Information

   Within the last 12 months, we have shared disclosed personal information in all or substantially all of the categories identified above for business purposes to the categories of third parties set forth in the above section titled “How We Share Personal Information”.

   Additionally, as is common practice among businesses that operate Internet websites and mobile apps, within the past 12 months, we and our business partners use tracking technologies to help us to understand our customers and visitors to the Services, to enhance your online experience, and customize our offerings in ways that may be deemed a “sale” of personal information under the CCPA. This includes working with third parties such as ad networks which collect personal information via tracking technologies to serve personalized advertisements on and off our Services, provide us with data collection, reporting, ad response measurement. Under certain state laws, this may be considered to be a “sale” of personal information, To the extent these activities amount to a “sale” of personal information under state law, see Section 8 above for links by which you can opt out.

   We do not knowingly sell or otherwise disclose the Personal Information of minors under 16.

4. Notice of Financial Incentive

   Speedway is the owner and operator of the Speedy Rewards program. You opt-in to the Speedy Rewards Program by creating a Speedy Rewards account. You can opt into Speedy Rewards by enrolling online here. You may also withdraw from the Speedy Rewards Program at any time by asking us to delete your personal information. Click here to submit a Deletion request or call 1-800 643-1948.

   Please note, deleting your personal information may result in the loss of some or all accumulated points, offers, and/or other Rewards.

   Enrolling requires consenting to the Speedy Rewards Terms & Conditions and verifying that you are at least 13 years of age. Participation in the Speedy Rewards program is at all times subject to the Terms & Conditions and we encourage you to read them prior to registering.

   Speedway collects personal information in connection with providing the Speedy Rewards Program. In general, we may collect (a) identifiers and personal information under the California Consumer Records Act (name, email, phone number, address, zip code, date of birth, payment information); (b) commercial information (account credentials, transaction records, points balance and history, records of Reward redemptions, records of participation in Rewards-related offers or promotions); (c) Internet or other electronic network information (such as data reflecting your interaction with the Speedway app, in-store technologies, or ads connected to the Speedy Rewards Program); (d) geolocation data (if you allow your mobile device to collect your location); and (e) inferences drawn from any of the foregoing relating to consumers.

   We may also present a short survey after enrollment asking about your household’s consumer activities and preferences. This information helps us create special Speedy Rewards offers tailored to you. Filling out this survey is completely voluntary on your part. From time to time, we may ask you to supply other information about your household’s consumer interests. This, too, is voluntary. Your decision not to participate in a Speedy Rewards survey or questionnaire will never affect your ability to use the Speedy Rewards Card to collect points, or to redeem them for rewards.

   In addition, we and our third-party partners will not be able to provide you with opportunities to earn Speedy Rewards points unless you re-enroll in Speedy Rewards. Lastly, if you opt-out of Speedy Rewards offers and programs or delete your Speedy Rewards account, you may still receive offers from the third-party partners that you’ve registered with, but you will not be able to earn Speedy Rewards points unless you re-enroll in Speedy Rewards.

   Speedy Rewards Program participants may receive Rewards points for every dollar spent on qualifying purchases. Points may also be earned in other ways available to Speedy Rewards Program members, such as by participating in periodic offers (like weekly deals), making regular purchases of select products, or by participating in surveys or other customer insight opportunities. Accumulated points may be redeemed for purchases of eligible products. Speedy Rewards Program members may also be eligible for discounts on fuel purchases at participating Speedway stores, as well as for certain other benefits like exclusive offers or punch programs that can earn free products at participating stores.

   Speedway does not calculate a monetary value for the personal information it collects through the Speedy Rewards Program. The value each Speedy Rewards Program member receives can vary substantially by individual, and depends on a number of variables such as (without limitation) (a) the extent to which members make qualifying purchases, (b) the extent to which members redeem points, (c) the extent to which members take advantage of fuel discounts and/or other offers and Rewards, (d) whether members are regular or occasional customers, and (e) whether members elect to participate surveys, customer insight opportunities, or other points earning opportunities.

   Speedway believes the value members receive from the Speedy Rewards Program is reasonably related to the value of personal information it collects through the Speedy Rewards Program. Speedway provides a good-faith estimate of the value of the personal information collected through the Speedy Rewards Program by estimating the 2021 expenses related to the offer and provision of the Speedy Rewards Program (as provided in Reg. §999.337 (a)(5) and (a)(6)). Using this method, Speedway estimates the value of consumer’s personal information to be $0.75 per member.

5. Your California Privacy Rights

   If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

   1. Right to Know / Right of Access: You have the right to know what personal information we have collected about you. You may request a copy of the specific pieces of personal information we have collected about you.

   2. Right of Deletion: You have the right to request that we delete personal information that we have collected from you.

   3. Right of Non-Discrimination: Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your personal information.

   You can request to exercise any of these rights by:

   • Visiting https://www.speedway.com/privacy-request, or
   • Calling us at: 1-800-643-1948

6. Agent Authorization

   You may designate an authorized agent to request any of the above rights on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. Your agent may contact us as set forth in this Privacy Notice. Even if you choose to use an agent, as permitted by law, we may require verification of the agent’s authorization to act on your behalf, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity.

   We cannot respond to your request or provide you with personal information if we cannot verify your identity, or identity of the agent authorized to make the request and confirm that the personal information relates to you.