PLEASE READ THIS PRIVACY DISCLOSURE CAREFULLY BEFORE USING THIS SITE
Rewards Network Establishment Services Inc. and its affiliates (“we”, “us” and “our”), which collaborates with Spirit Airlines, Inc. (“Rewards Partner”) to provide FREE SPIRIT® Dining (the “Program”) through this website or mobile application (collectively, the “Site”) values your privacy. We have prepared this Privacy Disclosure to describe how we collect and share information 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 Disclosure.
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
You may visit our Site without expressly submitting any personally identifiable information about you. However, if you wish to register as a participant in the Program, you will be required to submit information that specifically identifies you as further set forth below.
Information We Collect
If you register in the Program, we will collect your Personal Information (defined in the next sentence) and your primary account number for the eligible credit or debit card(s) that you use to enroll in the Program ("Registered Card"). "Personal Information" may include your name, email, mailing address, phone number, Registered Card and any other information that you voluntarily provide us. We may also collect this 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. If you enrolled with Rewards Network by Rewards Partner, Rewards Network will only maintain the information Rewards Network needs to operate the Program.
You may need to create a user name 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.
We collect the credit or debit card account number for your eligible Registered Card. We do not collect your credit or debit card expiration date or card security code. We do this to protect you as a participant in the Program. You must agree to allow us to collect this information to participate in the Program. Your transactions with your Registered Card will be monitored and you are authorizing us to obtain and receive information about those transactions from a payment card network ("Payment Card Network") such as American Express®, MasterCard®, Visa® or Discover®, or a payment card processor.
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.
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, including any email or mailing address or telephone number you provide, and will use the information you have provided to respond. We will also add this information to your Program profile and use such information as contemplated in this Privacy Disclosure.
We (or a non-affiliated third-party supplier, vendor, or contractor on our behalf or on behalf of the Rewards Partner) use your Personal Information to operate the Program: to send you emails, mailings or other forms of communications (that may be real-time) that relate to the Program, participating merchants ("Participating Merchants") or other products or services that may be of interest to you. We (or a non-affiliated third-party supplier, vendor, or contractor on our behalf or on behalf of the Rewards Partner) will send email confirmations when you open an email from us if your computer supports such capabilities.
Registered Card Information and Transaction Information
You agree that we may use your Registered Card in connection with our operation of the Program, including to determine your eligibility for rewards and applying rewards, requesting that you receive rewards, and compliance with this Privacy Disclosure and any other applicable terms and conditions. We may disclose the Registered Card 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 Registered 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. 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 or debit card is registered 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 Registered 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.
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 Content Guidelines for Dining Reviews. 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 use such information as contemplated by this Privacy Disclosure. Any other use of information provided in connection with such opportunities may also be used in the manner described at the time of collection. Please review the terms and conditions for such opportunities carefully.
Registered Card Updates
If your card number changes, you are responsible for updating your Registered Card. In some cases, we may receive updated credit or debit card numbers associated with your Registered Card from payment card processors or Payment Card Networks. If we receive this information, we will update the Registered Card with the new credit or debit card number that we receive, and we will use it to operate the Program as described in this Privacy Disclosure.
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.
Non-Personally Identifiable Information
When you visit the Site, we may collect usage information ("Session Data") that is anonymous and is not linked to you as an individual. Session Data may include browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform. 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 specific pages, and the length and frequency of stays at our Site.
We may have the ability to collect location data and provide you with push notifications based on your location. 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 with 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. We have no responsibility or liability for the functions of location settings within any device.
- Session cookies track the user's progression through the Site and session data for a single visit. These cookies enable us to follow the user as they progress from one page to another. Your session cookies expire at the end of your browser session. In addition, if you leave your browser open for a prolonged period, they are set to automatically expire.
- Persistent cookies are stored on your device between browser sessions, allowing us to remember you and your preferences on the Site. We may use a persistent cookie to remember such information as your user name, name, preferred dining area, and favorite restaurants.
Most Internet browsers automatically accept cookies. However, you can instruct your browser to stop accepting cookies or prompt you before accepting a cookie from the sites you visit.
We use Google Analytics in order to analyze traffic and performance related to the Site. To learn how Google uses data when you use our Site, visit www.google.com/policies/privacy/partners/.
Disclosure of Personal Information
We may disclose information that we may have, identifiable or not, as necessary for defending and bringing legal actions, or if required by a government authority or legal process.
We have full rights to any information collected on the Site, and we may freely collect, use, and disclose such information unless prohibited by this Privacy Disclosure, applicable law or an applicable agreement.
Disclosure of Anonymized Information
We may share anonymized information about you that is not reasonably identifiable to you with our affiliates, rewards partners, 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 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 Disclosure.
Social Network Plugins
Third Party Sites
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 or debit card information via email.
Do Not Track
We will automatically collect cookies and other non-personally identifying information when you visit the Site and, therefore, do not respond to Do Not Track (DNT) signals.
Retention and Disposal of 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.
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.
Securing Your Personal Information
Rewards Network and the Program will never ask you for personal information, including financial information, via unsolicited telephone calls, emails, postal mailers, or fax transmissions.
Specifically, Rewards Network and the Program will never send you unsolicited requests for the following types of Personal Information: (i) username or password; (ii) email address; (iii) social security number; (iv) credit card or debit card number; (v) credit card expiration date or card security code; (v) bank account numbers; or (vi) names of your family members. This list is provided for illustrative purposes only and is not intended to include all categories of information that may be the subject of an unsolicited request for Personal Information.
Any request for personal information of this nature in a conversation not initiated by you should be considered suspicious, even if the communication includes Rewards Network or the Program logos, links to websites that look “like” the Program, or a request for you to take immediate action, such as verifying your account information. Unsolicited communications of this type are often fraudulent “phishing” communications, and could be an attempt to acquire your sensitive personal information for malicious reasons.
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 email@example.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 to access and/or modify any information that we have for you, or otherwise modify your preferences pertaining to our marketing communications (whether made by email, telephone, or postal mail). To review, change, or update your information:
- Online: When the Program Site is available, sign in to your account and click on the "My Account" link at the top of the homepage. Then click on the appropriate 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., 2 N. Riverside Plaza, Suite 200, Chicago, IL 60606, Attn: Member Services.
- By phone: Members may contact Member Services toll-free at (866) 530-3463.
To protect your privacy and security, we will take reasonable steps to verify your identity before making corrections or granting access to your information.
Our IT Security & Privacy Office
We have appointed an IT Security & Privacy Steering Committee, which is responsible for ensuring that the protection of your Personal Information, Registered Card, or other information collected is carried out in accordance with this Privacy Disclosure.
The following person serves as the contact person for the IT Security & Privacy Office:
Alice L. Geene
2 N. Riverside Plaza
Chicago, IL 60606
Cancellation and Terminating your Account
If you do not agree to have your information collected, shared and used as described in this Privacy Disclosure, you may terminate your Program account at any time by contacting us at (866) 530-3463 or visiting the "My Account" portion of the Program Site while signed in and clicking on the "Cancel Your Membership" link. If you no longer consent to this Privacy Disclosure 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, Payment Card Networks as necessary to allow them to remove you from the Program.