Privacy Policy

Effective Date: March [__], 2025

This Privacy Policy describes the types of information gathered by RTC Fuels, LLC dba Pearson Fuels (“Pearson”, “us” or “we”) in providing the website, https://www.pearsonfuels.com, (the “Site”), a web application for mobile devices (the “App”) and the associated services, data, information, tools, functionality, updates, and similar materials (collectively, the “Service”), how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through the Service. It is important that you take the time to read and understand this Privacy Policy so that you can appreciate how we use your personal information.

By using the Service, you hereby consent to allow us to process information in accordance with this Privacy Policy. Please also refer to our Terms and Conditions, available here [LINK], respectively, which are incorporated as if fully recited herein. Terms defined in the Terms and Conditions that are not defined herein shall have the same definition as in the Terms and Conditions.

This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Service and/or otherwise making you aware of the changes. Your continued use of the Service following our notice of changes to this Privacy Policy (or other method of legal acceptance) means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. In all instances in this Privacy Policy, “our servers” means servers that we own or on which the Service is hosted, or which are otherwise utilized by the Service.  BY VISITING THE SITE AND/OR USING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

This Privacy Policy may be subject to the provisions of the California Consumer Privacy Act of 2018, as amended, (“CCPA”) and other applicable privacy laws. Under the CCPA, we are a “Business”, and you, if you are an individual residing in California, are a “Consumer” with certain protected privacy rights concerning your “Personal Information”. Under other applicable privacy laws, Pearson is in a similar position (with respect to your personal data) in that it will determine the means and purposes of the collection and use of your data, and you will be a “consumer” or the analogous term under the applicable law if you reside in that state or country.  We will take commercially reasonable steps to maintain compliance with the CCPA and other applicable privacy laws. Your personal data or Personal Information, as applicable, combined with any other information that may identify you as a person, may be referred to in this Privacy Policy as Personally Identifiable Information (collectively, “PII”).

  1. Who Collects Your Information?

We do. We collect information from you on the Service, and we are responsible for protection of your PII.

  • What Information Do We Collect?

A. Requested Information. We collect certain personal information about you, which may be supplied when you register for the Service, when you create or update your account, when you contact us or use the Service, or otherwise when you submit such information, including:

  • Contact and account information, such as your name, postal address, email address, telephone number, and username;
  • Other user data that we may receive from third-party partners, such as customer feedback, coupon redemptions, estimated location, device type, and demographic data (such as age and income level);
  • Employment[MJ1]  and educational information from individuals wishing to work for Pearson, such as degree and graduation year, school attended, job type, and employer name and location; and
  • Technical information, collected in our logs. Such information may include standard web log entries that contain usage statistics, clickstream data, IP address, your device’s identifiers (such as UDID, MEID, and IMEI), device type and operating system, time zone, previous page URL, the pages you visit, referring page URL and timestamps, notifications when you have read an email that we sent you, and first-party session cookies and collect data from them as described in more detail below.

You may provide us with information when you interact with us through email, submit a review or a post, or through other use of the Service. We may retain such information in order to provide you with services, and you agree that we may share this information as needed with other users in order to resolve any issues that may arise between you and another user of the Service.

The Service may send you push notifications and record your voice if you call customer care.

The Service may also request permission and access to your photo gallery, camera roll, or other device storage area holding your images, audio and/or videos, in order for you to upload and transmit them through the Service.  The Service may also record pictures, audio, and video, and access the internet or use your mobile data plan, create icons/shortcuts on your device, and collect location information about you, in order to use certain features of the Service.

  • Non-personal Information.  Non-personal information is non-personally identifiable or anonymous information about you, including but not limited to links and materials posted, the type of device you use and its operating system, browser information, the pages accessed most frequently, how pages and features are used, time spent on a page, search terms entered, and similar non-personal data.

Automatically tracking Internet Protocol (IP) addresses is one method of automatically collecting information about your activities online and information volunteered by you. An IP address is a number that is automatically assigned to your device whenever you surf the internet. Further, the Service may utilize web beacons, pixel tags, first (session and persistent) and third-party cookies, embedded links, and other commonly used information-gathering tools.

If non-personal information is paired to any of your PII, we will treat the non-personal information as if it were also PII.

  • Aggregate Information. We may also collect anonymous, non-identifying and aggregate information such as the type of browser you are using, the type of operating system you are using, the date and time of any request, language preference, referring site, and the domain name of your Internet service provider.
  • Why Is My Information Being Collected?

We need to collect your PII so that we can respond to your requests for information or to be added to our email lists, to recruit and hire employees, and to process your requests to access the Service. We also collect aggregate information to help us better design the Service. We collect log information for monitoring purposes to help us to diagnose problems with our servers, administer the Service, calculate usage levels, and otherwise provide services to you. 

A.   We use the PII you provide for the purposes for which you have submitted it including:

  • Internal Uses. We may use your PII to respond to your inquiries, to fulfill your requests for information, track usage trends, conduct experiments, develop and improve the Service and other offerings, and perform research and analytics.
  • Responding To Your Inquiries and Fulfilling Your Requests. We may use your PII to respond to your inquiries and to fulfill your requests for information.
  • Creating and Maintaining Your User Account. We use your PII to create and maintain an account for you to allow you to purchase and use the Service.
  • Communicating With You About Our Services. We may use your PII to send you information about new services and other items that may be of interest to you.
  • Sending Administrative and Promotional Emails. We may use your PII to send you emails to: (a) confirm your account information and your other PII; (b) process your transactions to purchase our Service; (c) provide you with information regarding the Service; (d) inform you of changes to this Privacy Policy, our Terms of Service, or our other terms, conditions, or policies; or (e) provide you with our newsletter, information on our other services and products, or promotions related to the Service or our other services and products.
  • Providing the Service. We’ll use data that we collect in order to create the products and services that we offer to the users of our Site.
  • Mailing You Something.  From time to time, we may send something relating to the Service including, but not limited to, marketing materials, and products that you have ordered, to you at the address provided.  This is usually done via a third-party carrier and/or the United States Postal Service, with whom we share your PII, which they use to coordinate and deliver these items to you.
  • Serve You Targeted Advertisements. We may use your PII to serve you advertisements with the App, and via push notifications, that are targeted to your interests.

B.   We may use anonymous information that we collect to improve the design and content of our Service, and to enable us to personalize your internet experience. We also may use this information in the aggregate to analyze how our Site is used, as well as to offer you programs or services. We may use any anonymous, aggregate information, of which your information may be a part of or the basis of, without restriction.

  • Do We Share Your PII?

We will not share your PII except: (a) for the purposes for which you provided it, including, but not limited to, our affiliates that provide the services (in whole or part) to you; (b) with your consent, including to one or more Platforms, at your option; (c) as may be required by law or as we think necessary to protect our organization or others from injury (e.g., in response to a court order or subpoena, in response to a law enforcement agency request, or when we believe that someone is causing, or is about to cause, injury to or interference with the rights or property of another); and (d) with persons or organizations with whom we contract to perform services for us, including the performance, or development of, aspects of the Service and other internal operations or business activities.

We may also share aggregate information with others, including affiliated and non-affiliated entities. 

Finally, we may transfer your PII to another party (affiliated or non-affiliated), or our successor-in-interest, in relation to, or in the event of, a merger, acquisition, sale of all or substantially all of our assets, reorganization, bankruptcy, or other change of control.  After such disclosure or transfer, the third party or successor in interest may use the information in accordance with applicable law.

After becoming a user of the Service, you may view, revise or edit certain personal information associated with you by logging into the Service, or by sending an email to privacy@pearsonfuels.com. For instructions on how you can further access your personal information that we have collected, or how to correct errors in such information, please send an email to privacy@pearsonfuels.com. If you would like to opt out of sharing your location data, you may do so via the App.  We will also promptly stop processing your information and remove it from our servers and database at any time upon your e-mail request, where required by law. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access to, making corrections to, or removing your information.

  • How We Store and Protect Your Information
  1. After receiving your PII, we will store it on our servers for future use. We have physical, electronic, and managerial procedures in place to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect. Unfortunately, no data transmission over the internet or data storage solution can ever be completely secure. As a result, although we take industry-standard steps to protect your information (e.g., strong encryption, and limiting access to only those employees whose job function truly requires access to your PII), we cannot ensure or warrant the security of any information you transmit to or receive from us or that we store on our or our service providers’ systems.
  • If you are accessing the Service from outside of the USA, you understand that your connection will be through and to servers located in the USA, and the information you provide will be securely stored in our servers and internal systems located within the USA.
  • We store your PII until it is no longer necessary to provide the Service, or longer if our retention policy, or the law, require us to do so. We store our logs and other technical records indefinitely.
  • How Do We Use Cookies and Other Network Technologies?
  1. To enhance your online experience with us, our web pages may use “cookies.” Cookies are text files that our web server may place on your hard disk to store your preferences. Cookies, by themselves, do not tell us your email address or other PII unless you choose to provide this information to us. Once you choose to provide PII, however, this information may be linked to the data stored in the cookie. Certain features of the Services may not function properly without the aid of cookies.  We use session cookies, which are necessary to allow you to seamlessly navigate from one page or area of the Sites to another during your visit, and these are normally deleted when you close your web browser. 
  • Our Service may use Google Analytics, provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 (“Google”) a web analytics service that uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may collect information regarding the use of other websites, apps and online resources.

We also use certain Firebase services from Google in order to derive application behavioral analytics, we use that information to see how users interact with our Site and App.  Firebase is part of the Google Cloud Platform and offers a number of services for developers, and we use the following in our Service:

  • Firebase Cloud Messaging (and the associated Application Programming Interface (“API”)) which uses Firebase installation IDs to determine which devices to deliver messages to.  Firebase retains Firebase installation IDs until the Firebase customer makes an API call to delete the ID. After the call, data is removed from live and backup systems within 180 days.
  • Google Analytics for Firebase is used to provide us with analytics and attribution information, and will collect your mobile device advertising identifiers (you can restrict the usage of these identifiers through the settings on your mobile device), which will be discarded after 60 days with other information possibly held for up to 14 months.
  • Cloud Functions for Firebase (and the associated API) uses IP addresses to execute event-handling functions and HTTP functions based on end-user actions. Cloud Functions only saves IP addresses temporarily, to provide the service.
  • Firebase App Distribution (and the associated API) which uses the data to distribute app builds to testers, monitor tester activity, enable tester features like in-app feedback, and associate data with tester devices.  User information is retained in Firebase App Distribution until the Firebase customer requests its deletion, at which point the information will be removed from live and backup systems within 180 days.
  • Firebase Dynamic Links (and the associated API) uses device specs and IP addresses on iOS to open newly installed applications to a specific page or context. Dynamic Links only stores device specs and IP addresses temporarily, to provide the service.
  • Firebase Hosting (and the associated API) uses IP addresses of incoming requests to detect abuse and provide customers with detailed analysis of usage data.  Firebase Hosting retains IP data for just a few months.
  • Firebase In-App Messaging (and the associated API) uses Firebase installation IDs to determine which devices to deliver messages to.  Firebase retains Firebase installation IDs until the Firebase customer makes an API call to delete the ID. After the call, data is removed from live and backup systems within 180 days.
  • Firebase Remote Config (and the associated API) uses Firebase installation IDs to select configuration values to return to end-user devices. Firebase retains Firebase installation IDs until the Firebase customer makes an API call to delete the ID. After the call, data is removed from live and backup systems within 180 days.

For more information on how Google uses data when you use our Sites or Service, please follow this link: https://policies.google.com/technologies/partner-sites.  You may be able to opt out of some or all of Google Analytics features by downloading the Google Analytics opt-out browser add-on, available at, https://tools.google.com/dlpage/gaoptout.  Google may additionally use your information as described here, https://policies.google.com/technologies/partner-sites?hl=en-US.  You may be able to opt out of Google’s collection and/or use of your information. Please visit Google’s Ads Preferences Manager or the Google Analytics opt-out browser add-on for more information.

  • We or our service providers may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (collectively, “Pixel Tags”) in connection with some pages of the Sites and HTML-formatted email messages for purposes of, among other things, compiling aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1×1), that is ordinarily not visible to website visitors and may be associated with cookies on visitors’ hard drives. Pixel Tags allow us and our service providers to count users who have visited certain pages of the Sites, to deliver customized services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can inform the sender of the email whether and when the email has been opened.
  • As you use the internet, you leave a trail of electronic information at each website you visit. This information, which is sometimes referred to as “clickstream data”, can be collected and stored by a website’s server. Clickstream data can reveal the type of computer and browsing software you use and the address of the website from which you linked to our Sites. We may use clickstream data as a form of non-personally identifiable information to determine how much time visitors spend on each page of our Sites, how visitors navigate through the Sites, and how we may tailor our web pages to better meet the needs of visitors. We will only use this information to improve our Site, App, and Services.
  • Do Not Track. At present, the Sites does not specifically respond to browser do-not-track signals.
  • Collection of Information by Others

Our Site or Terms and Conditions may provide links to certain third-party websites. When you leave our Service, please check the privacy policies of these other websites to learn how they collect, use, store, and share information that you may submit to them or that they collect.  We are not responsible for the privacy practices of such other sites.  This privacy policy applies solely to information collected by us through the Service.

  1. Children and Young People’s Information

We do not knowingly collect any information from any minors, and we comply with all applicable privacy laws including the CCPA, and the Children’s Online Privacy Protection Act (“COPPA”), and associated Federal Trade Commission (“FTC”) rules for collecting personal information from minors. Please see the FTC’s website (www.ftc.gov) for more information. If you have concerns about the Site, wish to find out if your child has accessed our services, or wish to remove your child’s personal information from our servers, please contact us at privacy@pearsonfuels.com. Our Site will not knowingly accept personal information from anyone under 13 years old in violation of applicable laws, without consent of a parent or guardian. In the event that we discover that a child under the age of 13 has provided PII to us, we will make efforts to delete the child’s information in accordance with the COPPA. If you believe that your child under 13 has gained access to our Site without your permission, please contact us at privacy@pearsonfuels.com.

  1. General Privacy Rights

You have the following rights with respect to our practices regarding your PII:

  1. You have the following rights with respect to our practices regarding your PII:
  2. The right of access. This is your right to be informed about what PII we are processing, why, and who else the data may be passed to.
  3. The right to rectification. This is the right to have your PII corrected or amended if what is held is incorrect in some way.
  4. The right to deletion. Subject to certain exceptions, and limitations, this is the right to have your PII deleted.
  5. The right to data portability. This is the right to ask for your PII to be provided to you in a structured, commonly used, and machine-readable format.
  6. Right to Non-Discrimination. In the event that you exercise one of your rights described in this policy, you will not be discriminated by us in any way, including by the denial of goods or services, providing you a different level of goods or services, or charging you different prices or rates for the goods or services, unless the change in price is reasonably related to the value we receive from your PII.
  7. Exercising Your Rights. You can find instructions for enforcing some of these rights in Section 6 and elsewhere in this Privacy Policy. Otherwise, if you wish to find out more about, or to exercise, any of your rights as described in this Agreement, please contact us at privacy@pearsonfuels.com and include “Privacy Rights Request” in the subject line of your email.

We will acknowledge receipt of your request within 10 business days of receiving it, and will do our very best to respond within 30 calendar days of receipt of your request, and in no event will our response come more than 90 days after receiving your request. 

Before we respond to any requests relating to your personal information, we will take steps to reasonably verify the identity of the person making the request (“Requestor”) to make sure it’s you, or your authorized agent.  We do this to this avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way. As the sensitivity of the information subject to the request increases, so will our verification efforts. If an agent is acting on behalf of the consumer, we will need to also verify the agent’s identity and their authority to act on the consumer’s behalf.  If the identity of the Requestor cannot be reasonably verified, either as the consumer or their agent, then in order to protect that consumer, we shall not honor the applicable request(s).

  1. Notice to California Residents

The CCPA applies to our practices with respect to Personal Information of California residents (“Consumers”).  In addition to the rights described in Section 11 above, under the CCPA, Consumers have certain rights regarding their Personal Information.  California residents may exercise any of their privacy rights by emailing us at privacy@pearsonfuels.com, or by calling 833-385-3835[MJ2] .

  • Additional Information Regarding Your Right to Access (Collect). As a Consumer, your Right of Access in Section 11 extends to any Personal Information we have collected about you and disclosed in the previous 12 months including, but not limited to, the categories of information collected by us, the specific pieces of information collected, the source(s) of such information by category, and the business purpose for collecting such information.  In the previous 12 months, we have collected the following categories of Personal Information about Consumers;
    • Identifiers.  Identifiers can be your name, mailing address, email address, technical identifiers (device identifier, IP Address, cookies, beacons, pixel tags, mobile ad identifiers), account names, and similar information; 
    • Records Law PII.  Personal Information Under the California Customer Records Law (Cal. Civ. Code §1798.80) (“CCRLPI”), which is largely the same as Identifiers;
    • Internet/Network Activity.  Internet Activity Information includes browsing history, cookies, search history and a Consumer’s interaction with a website;
    • Employment Information.  Employment Information includes employment history;
    • Geolocation Data.  Such geolocation data includes GPS data;
    • Commercial information. Such information includes the records of goods and services that you have purchased; and
    • Inferences. Inferences drawn from any other category of personal information.

We may collect Personal Information in the above categories from the Consumers themselves, and by automatic means, for the business purposes described in Section 4 above, and as required to comply with applicable law.

  • Right to Access (Sale/Share). As a Consumer, you also have the right to request that we tell you which of your Personal Information we have disclosed for a business purpose, sold, and/or shared. To the extent we do any of the foregoing, the Consumer shall receive the categories of information disclosed, sold, and shared, the types of entities that received such Personal Information, and the specific pieces of Personal Information that has been disclosed or sold to. 

In the past 12 months, we have not sold or shared Personal Information, and we do not intend to do so while this version of the privacy policy is effective.  We have, however, disclosed your name and mailing address (Identifier and CCRLPI categories) to shipping companies/common carriers to deliver mail and other goods to Consumers, both at their specific request, and as a result of our rewards program (explained in more detail below).

  • Right to Limit the Use and Disclosure of Sensitive Personal Information. Residents of California may, at any time, request that we cease using or disclosing any sensitive personal information that we have collected about them to only such uses as permitted by the CCPA.
  • Right to Opt-Out of Selling and/or Sharing of Your Personal Information. If you are a California resident, you have the right to opt-out of the “sale” or “sharing” of your Personal Information to third parties, to the extent it is occurring, including when we do so for cross-context behavioral advertising.

While we do not believe that we are ‘selling’ or ‘sharing’ your Personal Information with third parties, to the extent a court or regulator disagrees, you can request that all or a portion of your Personal Information in our possession or control not be “sold” or “shared” by clicking the “Do Not Sell or Share My Personal Information” link, available here [LINK], and on our Site and following the instructions to submit your request.[MJ3] 

  • Right to Opt-In.  If you are a Consumer under the age of 16, or have previously opted out of the sale or sharing of your Personal Information, you may elect to opt-in, or back in, as applicable
  • Right to be Notified of a Financial Incentive. We offer a rewards program through our App. In exchange for Consumers participating, which in some cases may provide additional Personal Information, for certain internal marketing and business improvement purposes, we will issue the Consumers points and enter them into a giveaway for certain merchandise and even free fuel.  However, when our rewards store is completed and operational within the App, the giveaway portion of the rewards program will end, and the Consumers will be able to redeem their points directly for items in the rewards store.

California law also allows its residents to request information regarding our disclosures to third parties in the prior calendar year, if any, of their personally identifiable information. To make such a request, please contact us at privacy@pearsonfuels.com with “Shine the Light” in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure to you will only include information covered by the law.

  1. Notice to Nevada Residents

If you are a Nevada resident, you have to the right to opt-out of the “sale” of your “covered information” as such terms are defined in Chapter 603A of the Nevada Revised Statutes (“Nevada Privacy Law” or “NPL”).  For the avoidance of doubt, we do not “sell” your “covered information”.  As someone that is subject to the NPL, under your Right of Access described in Section 11, you are entitled to additional information about the covered information of yours that we have or process.  For this information, please see Section 12 above, specifically the subsections on the Right of Access and what categories are collected, sold, and disclosed. Please note that defined terms may vary among different state laws, and that the NPL definitions of certain terms apply to this Section 13, and your reading of Section 12 in reference to this Section.

  1. Changes to this Privacy Policy

Because our business needs may change over time, we reserve the right to modify this Privacy Policy. If at any time in the future we plan to use your data, or our general privacy practices, change(s) materially from as described in this Privacy Policy, we will revise this Privacy Policy as appropriate. In the event of a change to our Privacy Policy, we will email the updated policy to the email address that you provided to us. Your continued use of the Service following our notice of changes to this Privacy Policy means you accept such changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

  1. Our Contact Information

If you have any questions or concerns about this Privacy Policy, you may email us our Privacy Officer at privacy@pearsonfuels.com.

Copyright © RTC Fuels, LLC. All rights reserved. The Site and Service are the property of Pearson, and are protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of the Site and Service, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.

 [MJ1]Note to Pearson: Included employment information (throughout) because there is a link on the site about contacting Greg to become a station worker.

 [MJ2]Note to Pearson: Because you have brick and mortar locations, you have to offer at least 2 methods to exercise rights, one of which must be a toll-free number.  Found this toll free to the Main Office on the website.  Are you comfortable using this number for the purpose of fielding inquiries about data privacy and requests to exercise privacy rights, or would you like to get a separate toll-free number?

 [MJ3]Note to Pearson: While it is not required to add a “Do Not Sell or Share My Information” link at the bottom of your website (because you aren’t doing either), I like to suggest doing so in the event the newly formed regulator takes an overly broad interpretation of these two terms such that it may cover what Pearson does

In which case, by having the link (directing users to a web form that allows them to opt-out of selling their data for money (or other valuable consideration) or sharing it for the purpose of engaging in targeted advertising with third parties.

Our Company

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