Privacy Policy

Reviewed and Effective As of 12/13/2022

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS SITE OR RELATED SERVICES.

Rewards Network Establishment Services Inc. and its affiliates (“Rewards Network,” “we,” “us,” or “our”) which collaborates with Spirit Airlines, Inc. (“Rewards Partner”) to provide the Free Spirit® Dining program (the “Program”) through this website or the mobile application (collectively, the “Site”) values your privacy. We have prepared this Privacy Policy to describe how we collect, use, and share Personal Information (defined below) about you via our Site and the Program. By visiting the Site, enrolling in the Program and participating in the Program, you are accepting the practices described in this Privacy Policy. It also describes your choices about the collection, sharing, and use of your Personal Information.

We may modify this Privacy Notice at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.

• Location of Servers
• What We Collect and How We Use It
  • Personal Information
  • Information We Collect
  • Linked Card Information and Transaction Information
  • Survey Information
  • Personal Information We Utilize for Contests, Giveaways, Sweepstakes, and Other Promotions
  • Linked Card Updates
  • IP Addresses
  • Usage Information and Session Data
  • Geo-Location
  • Cookies
• Disclosure of Personal Information
• Disclosure of Anonymized Information
• Transfer of Personal Information
• Social Network Plugins
• Third-Party Sites
• Choices for Email and Marketing Communications
• Retention and Disposal of Information
• Data Security
• Payment Card Industry Data Security Standard
• Reviewing or Changing Your Information
• No Use by Children
• Information Security Management Group
• Cancellation and Terminating Your Account
• California Residents
• Verification
• Contact Us
• Changes to Our Privacy Policy

Location of Servers

The Site is hosted on servers located in the United States of America and is intended for use by individuals and entities who are United States residents. YOU EXPRESSLY ACKNOWLEDGE AND CONSENT THAT YOUR DATA MAY BE TRANSFERRED TO VARIOUS LOCATIONS AND THIRD-PARTY PROVIDERS, AND MAY BE MAINTAINED AND PROCESSED ON COMPUTERS LOCATED OUTSIDE OF YOUR STATE, PROVINCE, COUNTRY, OR OTHER GOVERNMENTAL JURISDICTION WHERE THE PRIVACY LAWS MAY NOT BE AS PROTECTIVE AS THOSE IN YOUR JURISDICTION.

What We Collect and How We Use It

Personal Information

We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. You may visit our Site without expressly submitting any Personal Information. However, if you wish to register as a participant in the Program, you will be required to submit Personal Information as further set forth below.

Information We Collect

If you register in the Program, the Personal Information we collect may include your name, email, mailing address, phone number, and other information requested on the registration page. We will also collect the primary account number for the eligible credit and/or debit card(s) that you use to enroll in the Program (“Linked Card”). We do not collect your Linked Card’s expiration date or card security code. The primary account number is the full card number that appears on the front of your Linked Card (“Linked Card Number”). We need the Linked Card Number to monitor your Linked Card activity for transactions with participating merchants (“Participating Merchants”) that are eligible for Program rewards. Accordingly, you are authorizing us to obtain and receive information about your Linked Card transactions with Participating Merchants from a payment card network (“Payment Card Network”) such as American Express®, Mastercard®, Visa®, Discover®, or a payment card processor. You are also authorizing us to obtain and receive your Linked Card program identifier, which may be used to determine your eligibility for additional offers.

We may also collect Personal Information about you from Rewards Partner or a bank issuing a credit card on Rewards Partner’s behalf that automatically enrolls you in the Program as a benefit (collectively, “Rewards Partner Information”). If you are automatically enrolled with Rewards Network by Rewards Partner, Rewards Network will only receive, maintain, and use the Rewards Partner Information that Rewards Network needs to operate the Program.

You may need to create a username and password for your Program account with us. We may assign you a unique identification number so that we may more easily identify you and your transactions.

You have the option to also provide us with the month and day of special dates (e.g., birthday, anniversary), dining preferences, and information regarding your personal accounts and/or profiles on third-party social networking sites such as Facebook® and Twitter®, as further described below.

Additionally, we or Rewards Partner (or a non-affiliated third-party supplier, vendor, or contractor on our behalf or on behalf of the Rewards Partner) may collect Personal Information when you send us an inquiry, comment, or request relating to the Program, including any email or mailing address or telephone number you provide, and will use the information you have provided to respond. We may also add this information to your Program profile and use such information as contemplated in this Privacy Policy.

We or Rewards Partner (or a non-affiliated third-party supplier, vendor, or contractor on our behalf or on behalf of the Rewards Partner) use your Personal Information only to operate the Program, including to send you emails, mailings, or other forms of communications (that may be real-time) that relate to the Program, Participating Merchants.

Linked Card Information and Transaction Information

You agree that we may use your Linked Card Number in connection with our operation of the Program, including determining your eligibility for rewards and applying rewards, requesting that you receive rewards, and compliance with this Privacy Policy, the Program Terms of Use, and any other applicable terms and conditions. We may disclose the Linked Card Number to Rewards Partner, Payment Card Networks, payment card processors, and payment card issuers, as well as non-affiliated third-party suppliers, vendors, or contractors that we have engaged to help us operate the Program.

We will know when you conduct a transaction with a Participating Merchant. We will collect information about that transaction, including a unique Program identification number, the date and time of your transaction, the amount of your transaction, the name and location of the Participating Merchant, and the Linked Card used for that transaction. We receive this information from Payment Card Networks. We may provide all or a portion of the information collected to a Rewards Partner or a Rewards Partner’s non-affiliated third-party suppliers, vendors, or contractors so that we and/or Rewards Partner can facilitate and administer the Program. Transaction data is only shared with the individual restaurant where the transaction took place and with Free Spirit® Dining for reporting purposes. You may receive real-time notification about the sharing of your transaction data. We may also use your transaction information to generate internal financial reporting and analysis regarding our business and for external reporting of anonymized data to market our business and the Program to third parties, including potential Participating Merchants and potential rewards partners.

We use the transaction data that we receive to match your transactions at Participating Merchants with available rewards and otherwise for Program rewards administration. In some cases, a Participating Merchant’s payment card processor may experience a lag time (approximately 24 hours) between when a credit and/or debit card is linked to a Program account and when the payment card processor is able to identify and provide us with the dining transaction data associated with that Linked Card. If you believe that you are eligible for rewards for dining at a Participating Merchant, and those rewards have not registered in your Program account within 10 days of the dine, please contact the Program’s Member Services at (866) 530-3463. We reserve the right to require that you provide a receipt from the Participating Merchant or documents reasonably required by us to evidence an eligible transaction in order to receive your reward.

By enrolling in and participating in the Program, you are authorizing us and Participating Merchants, Payment Card Networks, and payment card processors to obtain, provide, and use transaction information related to your purchases (such as date, time and amount) at Participating Merchants in order to calculate rewards, redeem rewards, and facilitate and make the Program available. You also authorize us to, in our reasonable discretion, collect location data using your device to provide you with recommendations based on your location and past dining activity, analyze your general dining patterns and stores that you visit, and also aggregate this data to help understand general Program member patterns and trends, which we may share with third parties with our discretion.

Notwithstanding anything to the contrary in the Terms and Conditions or Privacy Policy, Free Spirit® Dining and its third-party service providers will use transaction information solely as follows: to operate the Program and for no other purpose.

Survey Information

Following your matched transaction and the processing of any reward, we may send you an email to complete a survey regarding your transaction. When you activate the survey link, you will be taken to a web page operated by us. We (or a non-affiliated third-party supplier, vendor, or contractor on our behalf or on behalf of the Rewards Partner) may collect on an anonymized basis your computer's IP address or use cookies to collect aggregated, anonymized data related to your survey responses. We may share the anonymized survey information with the applicable Participating Merchant. We may also aggregate your survey response with other survey responses for the applicable Participating Merchant and make those results available to other participants in our rewards programs.

For certain qualifying purchases, you may be required to complete the survey in order to earn rewards.

All reviews, surveys, comments, feedback, and other information about your dining experiences, Participating Merchants, or participation in the Program that you choose to disclose, submit, or convey via the Site (which we refer to collectively as "Comments") may be reprinted, used, displayed, redistributed, shared, transmitted, excerpted, modified, and/or disseminated (in whole or in part) by us. Your Comments must comply with our Review Guidelines. We reserve the right to remove any Comments that are inappropriate.

Your provision of Comments to us constitutes a nonexclusive, royalty-free, perpetual, irrevocable, and fully sub-licensable right to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, and display such Comments throughout the world in any media.

You warrant that: (i) any use of Comments by us will not violate any right of any third party; and (ii) any Comments are not libelous, unlawful, or obscene.

Personal Information We Utilize for Contests, Giveaways, Sweepstakes, and Other Promotions

You also may have the option to voluntarily provide us or Rewards Partner, as well as non-affiliated third-party suppliers, vendors, or contractors working on our behalf, with Personal Information in connection with participating in contests, giveaways, sweepstakes, and other promotions, or in connection with completing surveys for us. This information may be added to your member profile, and may be used in accordance with this Privacy Policy or the notice provided at the time of collection. Please review the terms and conditions for such opportunities carefully.

Linked Card Updates

If your card number changes, you are responsible for updating your Linked Card in your account profile. In some cases, we may receive updated credit and/or debit card numbers associated with your Linked Card from payment card processors or Payment Card Networks. If we receive this information, we will update the Linked Card with the new credit and/or debit card number that we receive, and we will use it to operate the Program as described in this Privacy Policy.

IP Addresses

We collect IP address information from any visitor to the Site. We log IP addresses for system administrative purposes only. IP addresses are not used for identification. This information helps us determine how often different areas of the Site are visited. We do not link IP addresses to any information that is personally identifiable.

Usage Information and Session Data

When you visit the Site or click on a link in an e-mail from one of our Participating Merchants, we may collect usage information ("Session Data"). Session Data may include browser type and version, time zone setting, browser plug-in types and versions, operating system, platform, and what Participating Merchants you look at. We may use Session Data for a variety of reasons, including to better understand things like how the Site is navigated, how many visitors arrive at and look at specific pages, and the length and frequency of stays at our Site. We disclose such Session Data to our Participating Merchants to provide proof of attribution metrics.

Geo-Location

We may have the ability to collect location data and provide you with push notifications based on your location and past dining activity. We utilize location information to provide you with more relevant location-based restaurant choices, track your general dining patterns and stores that you visit, and also aggregate this data to help understand general Program member patterns and trends, which we may share with third parties in our discretion. You are agreeing that we can collect and use your location data and can continue to do so until you turn off your location settings.

Your device may allow you to disable the collection of location data and push notifications by accessing your device’s application or notification settings. If you do not want us to have access to your location, you may change your location settings. You are agreeing that we can continue to collect location data until you turn off data collection in your device. We have no responsibility or liability for the functions of location settings within any device.

Cookies

Like most sites, we use cookies, device identifiers, and other similar tracking tools on the Site to automatically collect session data and persistent data about you when you visit the Site. We may place these cookies and tracking tools on our Site, or our third-party vendors may do so on our behalf. We use data from cookies and other tracking tools for several purposes, such as to personalize and improve your individual viewing experiences, store your password if you create an account, track and analyze usage and statistical information in order to constantly improve the quality of the Site, observe your behavior and browsing activities over time and across devices, websites and other platforms, for other administrative purposes, or to serve you interest-based advertising based on your browsing behavior.

Most Internet browsers automatically accept cookies. However, you can instruct your browser to delete, block, stop accepting cookies or prompt you before accepting a cookie from the sites you visit. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy notice of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

We may use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies. To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

We may use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site.

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.

Disclosure of Personal Information

We use your Personal Information and share it with Rewards Partner, Payment Card Networks, and payment card processors to solely operate the Program. We also disclose Session Data to our Participating Merchants, as discussed above. We will not, without your prior express consent, disclose your Personal Information to any third party for them to market to you directly. For example, we may invite you to participate in a survey or special promotional program offered by a non-affiliated third party. Your choice to participate in such a survey or promotional program will indicate your consent for us to share your Personal Information with non-affiliated third parties in connection with the survey or promotional program. If you consent to such disclosure, any information that you provide to the third parties will be controlled by that party's privacy policy, not this Privacy Policy.

We or Rewards Partner may disclose Personal Information that we may have reasonably necessary to (a) defend and bring legal actions; (b) if required by a government authority or legal process; (c) detect, prevent, or otherwise respond to fraud, security, or technical concerns, (d) support auditing and compliance functions, (e) when we or Rewards Partner believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (f) in the good faith belief that disclosure is otherwise necessary or advisable. We may also disclose Personal Information if and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of our business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.

Disclosure of Anonymized Information

We may share anonymized information about you that is not reasonably identifiable to you with our affiliates, rewards partners, Participating Merchants, and other third parties in our discretion. Such information could be used, for example, to provide us with statistical or other analysis and to market our business, the Program or both. This information is de-identified and cannot reasonably be used to identify you personally. This information is most often aggregated demographic and statistical information (such as information derived from use of our Site or your participation in any Program) and information submitted in connection with restaurant reviews or surveys that you submit to us.

Transfer of Personal Information

We reserve the right to transfer all information and data in our possession, custody, or control to a successor organization in the event of a merger, acquisition, reorganization, bankruptcy, or other sale of all or a portion of our assets. Any acquirer will remain subject to the terms of this Privacy Policy.

Social Network Plugins

The Site utilizes plugins from various social networking sites (such as Facebook® and Twitter®) to allow you to share and post materials between your Program account with us and your social network accounts. Social networks may use cookies and other tools to collect data regarding your browsing activity. Please be advised that your browser-related information and personal information collected in connection with your use of the social media plug-ins will be transferred to such social networking sites and will be used in accordance with each social networking site’s privacy policy. Your browser-related information may be transferred regardless of whether or not you use the plugin.

If you give us permission to use and post information about your restaurant visits, restaurant reviews, and other activities on our social networking accounts or your social networking accounts, usage of that social network site is governed by and subject to the privacy policy of that third-party social network site and any privacy settings that are available on that third-party site.

Third-Party Sites

We neither own nor control any third-party sites that may be accessible through the Site, and do not control the privacy policies of such third parties. As a result, we assume no responsibility or liability for the actions of such third parties (which include, but are not limited to, third-party providers of Online Ordering Available and Online Ordering Only, through links on the Site). We suggest that you review the privacy policy and terms of use of any third-party site before submitting information to them. For a complete list of third-party sites accessible from the Site, please contact legal@rewardsnetwork.com.

Choices for Email and Marketing Communications

You may opt out of receiving Program emails from us. However, doing so will affect your eligibility for all or some Program benefits. You may not opt out of receiving administrative emails related to your account except by terminating your Program participation.

If you do not wish to receive email communications from us, you can unsubscribe from the link in the email you received, change your selections within the Account Information section, or indicate your preferences within a direct communication to us. You may also email us if you wish to unsubscribe, but for your security, please do not send credit and/or debit card information via email.

Retention and Disposal of Personal Information

We retain your information as long as we determine it is required for the operation of our business and Program, and to meet legal, regulatory, and other requirements.

We take reasonable steps to ensure that information is disposed of securely when we no longer require such data.

Data Security

We take commercially reasonable steps to maintain physical, electronic, and procedural safeguards to protect your information. These safeguards may include data encryption, access authorization, firewalls, and physical access control to our data centers. We use industry-standard encryption technologies when transferring and receiving identifiable information. We maintain PCI DSS compliance. You can find our listing on the Visa Global Registry of Service Providers.

We maintain a Service Organization Control (SOC) 3 report. This assessment of our security practices enables you and your stakeholders to validate that we have obtained independent auditor assurance, which attests to our alignment with the American Institute of Certified Public Accountants (AICPA) Security Trust Principles. We may elect in the future to assess our security practices through a standard other than SOC, and we will in any case maintain and routinely test our controls related to the security, integrity, confidentiality, and privacy of the information we collect, store, and process.

Payment Card Industry Data Security Standard

In order to protect your Personal Information, Rewards Network complies with the security standards (PCI DSS) required by the PCI Security Standards Council.

The Council was founded in 2006 by five prominent payment brands — including American Express®, Discover Financial Services®, JCB International®, Mastercard®, and Visa, Inc.®. This global forum is responsible for the development, management, education, and awareness of security standards for credit and debit cards.

PCI DSS applies to all entities involved in payment card processing. This includes retailers where consumer purchases are made, payment card processors, credit card issuers, and service providers. Rewards Network continually reviews its payment card security practices to ensure that those practices satisfy the requirements of the most current version of the PCI DSS compliance standards.

If you suspect that you have received a phishing or other type of fraudulent communication, you should not: (i) click on any links in the offending email; (ii) open any attachments related to the communication; (iii) call any telephone numbers provided in the communication; or (iv) follow instructions contained in the communication. If the phishing or other fraudulent communication purports to be associated with the Program, you should report the communication to Rewards Network by sending an email to security@rewardsnetwork.com. You should attach the unsolicited communication to your email report. If you received the communication by postal mail, rather than by email, you should photograph any mailer, letter, and envelope received and attach those materials to the email report that you send to Rewards Network.

Reviewing or Changing Your Information

You can contact us (by email, telephone, or postal mail) to request access and/or modify any information that we have for you, or otherwise modify your preferences pertaining to our marketing communications. To review, change, or update your information:

• Online: When the Program Site is available, sign in to your account and click on the "Profile" link to change your Personal Information or modify your communication preferences.
• By postal mail: Please include your email address and mail your request to us at Rewards Network Establishment Services Inc., 540 West Madison Street, Suite 2400, Chicago, IL 60661, Attn: Member Services.
• By phone: Members may contact Free Spirit® Dining Member Services toll-free at (866) 530-3463.
• By email: freespiritdining@rewardsnetwork.com.

To protect your privacy and security, we will take commercially reasonable steps to verify your identity before making corrections or granting access to your information.

No Use by Children

We do not knowingly collect or solicit any Personal Information from children under the age of 18. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at legal@rewardsnetwork.com or contact us using the information listed below.

Information Security Management Group

We have instituted the Information Security Management Group (ISMG), which is responsible for ensuring that the protection of your Personal Information, including your Linked Card, and other information collected is carried out in accordance with this Privacy Policy.

The following person serves as the contact for the ISMG:

VP, General Counsel & Secretary
Rewards Network
540 West Madison Street
Suite 2400
Chicago, IL 60661
(312) 521-6767
legal@RewardsNetwork.com

Cancellation and Terminating your Account

If you do not agree to have your information collected, shared and used as described in this Privacy Policy, you may terminate your Program account at any time by contacting us at (877) 491-3463 or visiting the “Manage cards” portion of the Account center while logged in, and deleting all remaining credit and/or debit cards from your account.

If you no longer consent to this Privacy Policy and our collection and maintenance of this information, you must un-enroll from the Program. If you elect to un-enroll or are otherwise deactivated from the Program, we will also need to disclose that information to Rewards Partner, non-affiliated third-party suppliers, vendors, contractors, payment card issuers, payment card processors, and Payment Card Networks as necessary to allow them to remove you from the Program.

California Residents

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (“CCPA”), as amended by the California Privacy Rights Act (the “CPRA”), where “Personal Information” has the definition set forth in the CCPA. This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in the Contact Us section below.

Categories of Personal Information

Rewards Network makes the following disclosures regarding Personal Information collected by us within the preceding 12-month period.

Category of Personal Information	Category of Source from which Personal Information is Collected	Purpose of Collection	Category of Service Providers to whom Personal Information is Disclosed	Category of Third Parties to whom Personal Information Is Sold or Shared	Retention Period
Identifiers, such as your name, address, and email address.	You, and sometimes the Rewards Partner.	To facilitate the program, communicate with you, and accurately award rewards.	Rewards Partner, Credit Card Processor/Payment Card Network, Service Providers who provide email and customer service support.	We do not sell or share this category of Personal Information.	3 years after your last transaction with us.
The credit card number used to register for the Program.	You, and depending on the type of card you use, the issuing bank or Rewards Partner.	To facilitate the program and accurately award rewards.	Credit Card Processor/Payment Card Network.	We do not sell or share this category of Personal Information.	3 years after your last transaction with us.
Commercial information, relating to transactions you make at restaurants.	The Payment Credit Card Processor/Payment Card Network, Participating Merchants.	To facilitate the program and accurately award rewards.	Restaurant Partners (in the aggregate only), Credit Card Processor/Payment Card Network, Service Providers providing email and customer service support.	We do not sell or share this category of Personal Information.	7 years after your last transaction with us.
Internet or other electronic network activity information, including cookies and utilizing Google Analytics Tools.	You, and your activity on the Program websites. Depending on the type of information, sometimes through email communications.	To improve the Program to provide you with the best experience possible, including suggesting restaurants.	Service Providers providing email and customer service support, Service Providers who assist with marketing initiatives.	We do not sell or share this category of Personal Information.	Varies depending on the type of cookie collecting this Personal Information, but no more than 3 years.
Geolocation data, including where you are when you open the dining app or website.	You, and the device you use to access the mobile site and website.	To improve the program and make suggestions based on your location.	Service Providers who provide technical support for this functionality.	We do not sell or share this category of Personal Information.	3 years after your last transaction with us.

If you are a California resident, you have the following rights:

Privacy Right	Description
Notice	The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	The right to receive the Personal Information you have previously provided to us.
Erasure	The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
Automated Decision Making	You have the right to request information about the logic involved in automated decision-making and a description of the likely outcome of processes, and the right to opt out. Rewards Network does not currently engage in any automated decision making practices.
To Opt Out of Sales or Sharing of Personal Information	We do not sell or share Personal Information. However, if we did, you would have the right to opt out.
Limit Use of Sensitive Personal Information	You have the right to limit the use of your sensitive Personal Information to only that which is necessary for providing our Program.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child.

You may only make a request for access or data portability twice within a 12-month period. The request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

To submit a request, please complete this form.

• Rewards Network will not discriminate against you in the event you exercise any of the aforementioned rights under CCPA, including, but not limited to, by:
• denying goods or services to you;
• charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• providing a different level or quality of goods or services to you; or
• suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Verification

We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.

We will deliver our written response electronically via e-mail.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes.

Contact Us

For any questions, or to request further information regarding this Privacy Policy, please contact us at legal@RewardsNetwork.com.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or possibly through a notice on our Site’s home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and this Privacy Policy to check for any changes.