National Retail Solutions, Inc.


BR Club Application Privacy Policy


Effective as of January 29, 2020



1. General


National Retail Solutions (“NRS”) is committed to protecting the privacy of your personal information. Through our BR Club Application (the “App”) we offer our customers the ability to order groceries and other products for pick up at certain retail locations in cities throughout the United States (the “Service”).


This Privacy Policy (the “Policy”) sets forth our policies and procedures regarding the collection, use and sharing of your personal information via the App. We also explain the steps we take to protect your information and how you can limit the collection, use and sharing of your information.


This Policy applies to all users of the App and the Service. When we refer to NRS or “us,” or “we,” we’re talking about National Retail Solutions, Inc.


You should also read the terms of service for the Service, which can be found in the App.


We may update this Policy from time to time and you should review it periodically for changes. Any updated Policy will be posted in the App.


2. Information We Collect


NRS receives and collects both personal and non-identifying information from you when we operate and provide you with the Service, when you install, access or use the App or Service and when you communicate with us. Personal information means information either on its own or in conjunction with other data that enables a specific person to be identified, but does not include “de-identified,” “anonymous,” or “aggregate” information, which is not otherwise associated with a specific person. Non-identifying information means information that by itself cannot be used to identify a specific person (e.g., zip code).


A. Information You Provide. When you use the App and the Service you may provide the following personal information:


B. Information We Collect. We may automatically collect the following information when you use the App and the Service:


C. Information Provided by Third Parties. When you access or use the Service we may obtain the following information from third party sources:


3. How We Use Information

We use all the information we collect and receive to help us operate, provide, improve, understand, customize, support, and market the Service. In addition, we use your information for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you. As used in this Policy, the terms “use,” “using” and “processing” information include using cookies or other similar technologies on a computer/phone/device, subjecting the information to statistical or other analysis and using or handling information in any way, including but not limited to, scanning, collecting, storing, evaluating, aggregating, modifying, deleting, using, combining, disclosing and sharing information among our affiliates both in and outside the United States and to select service providers and vendors.

A. The Service. We analyze how our customers use the Service and use that information to evaluate and improve the Service, to research, develop, and test new services and features, and to conduct troubleshooting activities. For example:

B. Web Technologies. The App may use certain web technologies such as “cookies” or “web beacons.” We use cookies, small text files stored locally on your device to serve as markers, to operate, provide, improve and customize the Service and your experiences. For example, we may use cookies to understand which of our FAQs are most popular and to show you relevant content related to the Service. Additionally, we may use cookies to remember your choices, such as your language preferences. Web beacons are used to tell us how and when pages in our sites are visited, by how many people, their point of origin and operating system and to monitor performance with the Service. These technologies do not collect personal information. We do not honor any web browser “do not track” signals or other mechanisms that provide you the ability to exercise choice regarding the collection of information about your online activities over time and across third party websites or online services. We use and share this data and information to deliver customized content and advertising, to ensure that you see the correct product information, to manage the frequency with which you see an advertisement, to tailor advertisements to better match your interests, and to understand the effectiveness of our advertising. The content may be delivered in the App, by our representatives, and via email, SMS, push notifications or other NRS services. In addition, if you respond to or interact with a particular advertisement, you may later receive a targeted advertisement as a result of an ad server or ad network concluding that you fit within a particular audience we are trying to reach.

C. App. We engage certain service providers and vendors who use mobile software development kits to passively collect information from users of the App. We use this data primarily to help us deliver personalized notifications and to identify you in a unique manner across other devices or browsers for the purposes of customizing advertisements or content.

4. How We Share Information

We share all the information we collect and receive with our affiliates, both in and outside the United States, and to select service providers and vendors, to help us operate, provide, improve, understand, customize, support, and market the Service, and for general, operational and administrative purposes, including maintaining your account, authenticating you and contacting you. When we share information with our service providers and vendors, we require them to use your information in accordance with our instructions and terms or with express permission from you and not to sell your information. In addition, you share your information as you use the Service.

A. Information Shared Within the NRS Family of Companies. We share information within the NRS family of companies, including our affiliates both in and outside the United States primarily to operate, provide, support and market the Service. For example, if you place an order with the Service we may share this information with various NRS affiliates in order to process your transaction.

B. Information Shared with Service Providers and Vendors. We work with various service providers and vendors for a variety of business purposes such as to help us offer, operate, provide, improve, understand, customize, support and market the Service. We share information with these service providers and vendors to the extent reasonably necessary for them to perform work on our behalf. For example, we provide your order to the applicable retailer so it can be filled. In addition, NRS shares certain information, including unique marketing identifiers, email addresses and mobile phone numbers, with some of our service providers and vendors, including Google and Facebook, for marketing, advertising and analysis purposes, including the delivery of advertising campaigns and preparing and sharing aggregate business and marketing reports, demographic profiling and to deliver targeted advertising about products and services. When we share information with our service providers and vendors, we request that all these parties protect your information and limit their use of the data to the purposes for which it was provided, and not to sell your information. NRS does not sell, rent or lease its customer lists to third parties. Finally, if you purchase products or services offered jointly by NRS and one of our partners, your customer information may be received by both NRS and our partner that is providing the product or service. For these jointly offered products and services, you should also review the partner company’s privacy policy, which may include practices that are different from the practices described here.

C. Special Circumstances. We may share information in certain special circumstances. For example:

D. Information Shared with Advertising Entities or Social Networks. You may see third party advertisements in the App. Some advertisements are chosen by companies that place advertisements on behalf of advertisers. These companies, often called ad servers, may place and access cookies on your device to collect information about your visit. The information they collect from our App is in a form that does not identify you personally. This information may be combined with similar data obtained from other websites or apps to help advertisers better reach their targeted audiences. Targeting may be accomplished by tailoring advertising to interests that they infer from your browsing of our sites and your interaction with other websites where these ad servers also are present. If you choose to interact with specific advertisers who advertise in the App, the information you provide to them is subject to the conditions of their specific privacy policies. The App also includes plug-ins and widgets that may provide information to their associated social networks or entities about your activity in the App, even if you do not click on or otherwise interact with the plug-in or widget.

E. When You Share Information. You share your information as you use and communicate through the Service.

5. Your Rights and How To Limit Sharing Of Information

You have choices about how we use and share your information and there are additional protections that may apply with regard to certain information we collect.

A. Telemarketing. Federal “Do Not Call” laws allow you to place your phone numbers on the National Do Not Call Registry to prevent telemarketing calls to those numbers. To add your numbers to this list, please call 1-888-382-1222, or visit www.donotcall.gov. Most telemarketing laws allow companies to contact their own customers without consulting the Federal or State Do Not Call lists. If you would like to be removed from NRS’s do-not-call telemarketing list, please contact us at AppSupport@nrsplus.com. Please allow 30 days for your telephone number to be removed from any sales programs that are currently underway. Please note that we may still call you regarding the Service and account even if you remove your number from our telemarketing list.

B. Email, Text Messages and Push Notifications. Marketing emails you receive from us will include an unsubscribe feature usually found at the bottom of the email that you may use to opt out of receiving future marketing emails. Marketing text and SMS messages from us also contain an opt-out feature that you can use to prevent future marketing text and SMS messages from us. You may refuse to consent to receive calls and texts from NRS and its affiliates that require your consent, including autodialed, pre-recorded or artificial voice telemarketing calls. You may also withdraw your previously given consent to receive such calls and texts. You can opt out of receiving push notifications from us via the App by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for the App. Please note that you cannot withdraw your consent to receive certain in-App messages from NRS. NRS does not recommend using those Services without authorization to receive such messages.

C. Online Information. You have choices about whether certain information collected from your use of the App is used to customize advertising based on predictions generated from your visits over time and across different websites and apps. Similarly, many mobile devices offer controls you can set to limit the advertising use of information collected across mobile apps on your device. Please note that many opt outs use browser cookies or device controls and are specific to the device and browser you are using. If you buy a new computer, change web browsers or devices or delete the cookies on your computer, you may need to opt out again. In addition, ads you receive may still be tailored using other techniques such as publisher, device or browser-enabled targeting. You should check the privacy policies of the products, sites, apps and services you use to learn more about any such techniques and your options. You also can limit the collection of certain website information by deleting or disabling cookies. Most browsers enable you to erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Disabling cookies may prevent you from using specific features on our sites and other websites, such as ordering products or services and maintaining an online account.

6. California Consumers. If you are a resident of California, then the following section also applies to you.

A. Personal Information. Personal information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. NRS collects and discloses the following categories of personal information regarding California residents:


Categories of Personal Information Collected

Specific Personal Information Collected within Category

Categories of Sources of Personal Information

Is this info Shared and/or Sold and Categories of to Whom

Business or Commercial Purposes for Collection and Sharing of Personal Information

Personal Identifiers and Information, including items listed in subdivision (e) of Section 1798.80 of California Civil Code

name, address, email address, phone number, birthdate, device and marketing identifiers, IP address, payment and financial information, credit/debit card number and details, bank account number and information, personal information necessary to verify you or your account, security code and login credentials, and other personal information you provide

consumer, consumer’s device, automatic collection by NRS, credit reporting companies, financial companies, 3rd party vendors that provide NRS with transactional services, data resellers

Shared – yes

Categories of third parties with whom NRS shares personal information: NRS family of companies, including our affiliates both in and outside the United States; our service providers and vendors to the extent reasonably necessary for them to perform work on our and your behalf (e.g., credit card processors); ad networks; data analytics providers; social networks; law enforcement; prospective purchasers of our business; outside auditors and lawyers; and government entities, agencies and regulators

Sold – no


To manage our products and services, including to help us operate, provide, evaluate, improve, monitor, customize, bill and support our products and services

To maintain and service your account, including to process orders and payments

To communicate with you about our terms and policies

To verify you, your account activity and your information

To detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts

To provide customer service

To perform due diligence, credit and fraud prevention checks

To maintain accurate record keeping

To perform product, marketing and organizational analysis

To provide advertising and marketing to our customers

To measure our marketing campaigns and to audit consumer interactions

To comply with regulations and legal requirements

To comply with contractual requirements

For risk management and compliance

For legal advice and defense of claims

For general, operational and administrative purposes

Commercial information

records of products or services purchased and used, diagnostic and service performance information, credit information from reporting agencies, transactional information, and other purchasing or consuming histories or tendencies

consumer, consumer’s device, automatic collection by NRS, credit reporting companies, financial companies, 3rd party vendors that provide NRS with transactional services, data resellers

Shared – yes

Categories of third parties with whom NRS shares personal information: see list under Personal Identifiers and Information

Sold – no

Internet or other electronic network activity information

browsing history, search history, messages, personal, phone or social network contact information, device information, device contacts, and information regarding a consumer’s interaction and usage with our websites, apps and advertisements

consumer, consumer’s device, automatic collection by NRS, credit reporting companies, financial companies, 3rd party vendors that provide NRS with transactional services, data resellers

Shared – yes

Categories of third parties with whom NRS shares personal information: see list under Personal Identifiers and Information

Sold – no

Geolocation data (if use location features)

location of device

consumer, consumer’s device, automatic collection by NRS

Shared – yes

Categories of third parties with whom NRS shares personal information: see list under Personal Identifiers and Information

Sold – no

Inferences drawn from any of the information above

profile reflecting the consumer’s marketing preferences; aggregate information from third parties

consumer, consumer’s device, automatic collection by NRS, credit reporting companies, financial companies, 3rd party vendors that provide NRS with transactional services, data resellers

Shared – yes

Categories of third parties with whom NRS shares personal information: NRS family of companies, including our affiliates both in and outside the United States; our vendors and partners to the extent reasonably necessary for them to perform work on our and your behalf (e.g., credit card processors); ad networks; data analytics providers; social networks; and prospective purchasers of our business

Sold – no

C. Your Rights. As a California resident you have certain additional rights regarding your personal information under the California Consumer Privacy Act of 2018 (“CCPA”).

(i) Right to Know Personal Information Collected – you have the right to request the following from NRS: categories of personal information collected; categories of sources of personal information; business or commercial purpose for collecting or selling your personal information; categories of third parties with whom we share your personal information; and the specific pieces of personal information that we have collected about you.

(ii) Right to Know Personal Information Sold or Disclosed – you have the right to request the following from NRS: categories of personal information collected; categories of personal information sold by NRS; categories of third parties to whom NRS has sold your personal information; and categories of personal information NRS has disclosed for a business purpose.

(iii) Right of No Discrimination - NRS does not discriminate against any California consumer who exercises any of the consumer’s rights under the CCPA. Pursuant to the CCPA, NRS is permitted to charge a consumer a different price or rate and/or provide a different level of service to the consumer if that difference is reasonably related to the value provided to the consumer by the consumer’s data.

(iv) Right of Deletion/Erasure – you have the right to request that NRS delete any personal information that it has collected about you. There are exceptions to this right and NRS does not have to delete your personal information including if necessary to complete a transaction, to provide you with services, to detect fraud, to comply with our legal obligations, and to use internally in a lawful manner compatible with the context in which the personal information was given. In addition, if your personal information is deleted you may not be able to purchase or use our products and services.

(v) Right to Not Sell Personal Information – NRS does not sell your personal information to third parties. Nonetheless, you have the right to request that NRS not sell your personal information should NRS decide in the future to sell personal information to third parties. To exercise this right please go to https://www.idt.net/ccpa-do-not-sell and complete the form. NRS does not intentionally collect the personal information of a consumer under the age of 16. NRS does not intentionally sell the personal information of a consumer under the age of 16 unless the consumer (if age 13-16) or the consumer’s parent (for consumers under 13) affirmatively authorizes the sale.

D. How to Exercise Your Rights. To exercise your rights to know personal information collected, sold or disclosed, or to exercise your right to delete your personal information, please go to https://www.idt.net/ccpa-request and complete the form. To exercise your right to opt out of the sale of your personal information please go to https://www.idt.net/ccpa-do-not-sell and complete the form. In addition, you can exercise your rights by calling the following toll-free number: 973-438-3176.

E. Verification of Consumer Requests. In order to comply with a consumer request, NRS must reasonably verify the requestor. A record of each request is made as soon as it is received by our data protection team. NRS will use all reasonable measures to verify the identity of the individual making the request. We will utilize the requested data to ensure that we can verify the requestor’s identity and where we are unable to do so, we may contact you for further information, or ask you to provide evidence of your identity prior to responding to your request. This is to protect your data and rights. If a third party, relative or representative is requesting the data on your behalf, we will verify their authority to act for you and may contact you and them to confirm you and their identity and gain your authorization prior to responding to the request.

F. Responding to Consumer Requests. NRS will attempt to confirm receipt of each request by contacting the requestor either at the email or telephone number submitted, through the consumer’s account or by other electronic means. NRS will attempt to verify each request and if it is able to verify a request will provide a response (if necessary and applicable) within 45 days of the receipt of the request, which time period may be extended by NRS for an additional 45 days. If a delay is necessary, NRS will contact the requestor within the original 45 day period and provide the reasons for the delay. If a request is particularly complex, NRS may take an additional 90 days to respond. NRS may charge a fee or refuse to act on any request that is manifestly unfounded or excessive. All NRS responses shall be in writing and cover the previous 12 month period. Where possible the response shall be sent through the consumer’s account. Otherwise, the response shall be sent by mail or electronically. NRS is not obligated to provide a response to a consumer more than two times in any 12 month period. The CCPA contains certain exemptions and exceptions from the right of deletion and/or the provision of personal information. If one or more of those exemptions or exceptions applies to your request, then we may not be able to act upon your request. Where possible we will inform you of the reasons for not acting upon your request.

F. For More Info. For more information on your rights and our obligations under the CCPA please send an email to ccpa@idt.net. For California residents with a disability please send an email to ccpa@idt.net for information on how to access this policy in another format.



7. Other Information

A. Keeping Children Safe. NRS does not knowingly market to or collect information from children under the age of 16 without obtaining verifiable parental consent. If you allow a child to use your Device or the Service, you should be aware that their information could be collected as described in this Policy. We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

B. Security. NRS has technical, organizational and physical safeguards in place to help protect against unauthorized access to, use or disclosure of the information we collect and store. Employees are trained on the importance of protecting privacy and on the proper access to, use and disclosure of customer information. NRS secures information on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. In order to safeguard your credit card information, the App uses a PCI compliant third party (Braintree) to handle data entry and processing of your credit card. The App does not itself receive, store or otherwise have access to your credit card information. However, no program is 100% secure and we cannot guarantee that our safeguards will prevent every unauthorized attempt to access, use or disclose that information. NRS maintains security and incident response plans to handle incidents involving unauthorized access to information. If you become aware of a security issue, please contact us.

C. Contact Information. If you have questions, concerns or suggestions related to our Policy or our privacy practices you may contact us at:

National Retail Solutions, Inc.

520 Broad Street, 3rd floor

Newark, NJ 07102

Telephone: 973-438-3176

Email: AppSupport@nrsplus.com

D. Links to and from non-NRS Websites and Content. The App may contain links to non-NRS sites. In addition, NRS content may be included on websites that are not associated with NRS. We have no control over these non-NRS sites and are not responsible for the content on these sites or platforms or the privacy policies and practices employed by these sites and platforms. We recommend that you review the policies and practices of the sites you visit.

E. Social Networking. The App may allow you to participate in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews. Please be aware that these forums are accessible to others. We urge you to not submit any personal information to these forums because any information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. NRS is not responsible for the information you choose to submit in these forums. If you post content to information sharing forums, you are doing so by choice and you are providing consent to the disclosure of this information.

F. Changes to this Policy. We reserve the right to make changes to this Policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the beginning of the Policy.

©2019 National Retail Solutions, Inc. All Rights Reserved.