Privacy policy
Reviewed and effective as of May 7, 2024
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS SITE OR RELATED SERVICES.
Rewards Network Establishment Services Inc. (“Rewards Network” “we”, “us” or “our”) is committed to protecting your privacy and the security of your information. We have prepared this Privacy Policy to describe how we collect and share Personal Information (defined below) about you and/or your business via our websites and other platforms where this Privacy Policy is posted, including any mobile versions thereof (collectively, “Site”), and in connection with providing our services (“Services”). 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.
- United States only
- What we collect and how we use it
- Personal information
- Information we collect
- IP addresses
- Non-personally identifiable information
- Geo-location
- Cookies
- Session data
- Disclosure of personal information
- Disclosure of anonymized information
- Transfer of personal information
- Third party sites
- Choices for email communications
- Retention and disposal of information
- Data security
- Reviewing or changing your information
- No use by children
- Our information security management group
- Cancellation and terminating your account
- Your California privacy rights
- Changes to our privacy policy
United States only
The Site is hosted on servers located in the United States of America and is intended for use only by individuals and entities located in the United States. BY USING THIS SITE, 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 about you. You may indicate your interest in becoming a participating merchant by submitting certain information as further described in the section entitled “Information We Collect.”
Information we collect
If you indicate your interest in becoming a participating merchant, we will collect your name, business name, email, telephone, and mailing address. We offer our participating merchants two products: Merchant Cash Advance (“MCA”), through which we purchase future receivables of your business and market your business to our rewards program members, and Marketing Services (“MS”), through which we market your business to our rewards program members. If you enter into an agreement with us to become a participating merchant (“Participating Merchant”) of Rewards network, you become either an MCA client (“MCA Client”) or MS client (“MS Client”).
If you are interested in becoming an MCA Client, we ask you to submit an MCA Client application. Through the MCA Client application, we collect information about your business (including its sales, credit card processing, bank account, and legal entity information) as well as information about you as the owner of your business (including your name, address, telephone number, email address, social security number, date of birth, and driver’s license information). When you enter into an agreement to become an MCA Client, we use this information in order to support your relationship with us — to generate account balance statements, to respond to your account service inquiries via telephone or email, or to contact you about payment or other account service matters. We also collect content about your business as an MCA Client, such as menus, photos, and logos. We use this content in order to market your business to our rewards program members.
If you are interested in becoming an MS Client, we collect information about your business (including your business name, address, telephone number, and email address) and financial information about your restaurant’s historical sales. When you enter into an agreement to become an MS Client, we use this information in order to support your relationship with us — to generate billing statements, to respond to your account service inquiries via telephone or email, or to contact you about program performance, payment or other account service matters. We also collect content about your business as an MS Client, such as menus, photos, and logos. We use this content in order to market your business to our rewards program members.
If you are an MCA Client or MS Client, or otherwise registered with us, we may also use the information you provide us to send you emails or to serve you ads about products and services or special offers.
If you are an MCA or MS Client, you will receive access to our Comment Management System, a valuable tool for participating restaurants that allows you to connect with your diners outside of the restaurant — online, 24/7. When you log in to the CMS, you can build customer relationships to encourage loyalty and respond to customer feedback. In order to access the Comment Management System, your user name will be your email address and you will need to create a user name and password for your account with us.
We also collect information about your business’s credit card transactions as a Participating Merchant. We collect through your payment processor and American Express. As a Participating Merchant, we also collect information about your business’s credit card transactions and ACH debit transactions. This includes routing and account numbers, if you enable integration with our third-party service provider Plaid. We may use your transaction history to extend personalized offers to you.
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 Personal Information.
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.
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 use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Site and on other websites, and may be sent to you via email.
We 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 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.
Session data
When you visit the Site, we automatically collect usage information about how you use and navigate the Site (“Session Data”). Session Data may include browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform. Session Data may also include the number and frequency of visitors to each page on the Site, the length of their stays, the type of operating system each visitor is using, the address (or URL) of the web site that the visitor came from before visiting the Site, and which links were clicked on. 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.
Disclosure of personal information
We do not sell information that identifies Merchants to any third party and we will not disclose your contact or other Personal Information to any third party for them to market to you directly without your prior express consent. No mobile information will be shared with or sold to third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with or sold to any third parties.
We may disclose any information, including Personal Information of any Participating Merchant, to non-affiliated third-party suppliers, vendors, contractors, and payment card networks (for example, American Express®, Mastercard®, or Visa®) as necessary for the non-affiliated third party to provide services to us in connection with operating and managing our Programs, business, products, and services, including addressing any issue that may arise in connection with a Merchant’s bank account.
We may disclose Personal Information that we may have as 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, or (e) when we 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 anonymous or aggregated information that is not reasonably identifiable to you or your business with our affiliates, partners, merchants, and other third parties in our discretion. Such information could be used, for example, to provide us with statistical or other analysis. This information is de-identified and cannot reasonably be used to identify you personally or your business. This information is most often aggregated demographic and statistical information (such as information derived from your participation in any of our rewards programs (“Program(s)”).
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 and any acquirer will remain subject to the terms of this Privacy Policy.
Third party sites
We neither own nor control any third-party sites that may be accessible through our 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. We suggest that you review the privacy policy of any third-party site before submitting information to them.
Choices for email and marketing communications
You may opt-out of receiving promotional emails from us. However, doing so will affect your eligibility for all or some the benefits and participation in any event hosted across our Site.
If you do not wish to receive email communications from us, you can unsubscribe from the link in the email you received, 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. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. If you block cookies, certain features on our Site may not work. Certain options you select are browser and device specific.
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.
Reviewing or changing your information or communications preferences
At any time, if you are a registered Merchant, you can contact us to access and/or modify any information that we have for you or otherwise modify your preferences pertaining to communications (whether made by email or telephone). To review, change, or update your information or if you do not wish to receive email communications from us, contact us via one of the methods below:
- By phone: Contact Client Services toll-free at (800) 422-5155
- By email: [email protected]
- Merchants may also contact their Account Executive or Account Manager for assistance.
To protect your privacy and security, we will take 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 [email protected] or contact us using the information listed below.
Information Security Management Group
We have appointed an Information Security Management Group (“ISMG”), which is responsible for ensuring the protection of your Personal Information, Business Information, and Program Data is carried out in accordance with our Privacy Policy. The ISMG monitors and enforces compliance with our Privacy Policy.
The following person serves as the contact person for the ISMG:
Robert Kauffman
VP, General Counsel & Secretary
540 West Madison Street, Suite 2400
Chicago, IL 60661
Phone: (800) 422-5155
Email: [email protected]
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 / contract at any time by contacting us at (800) 422-5155. If you no longer consent to this Privacy Policy and our collection and maintenance of this information, you must un-enroll from the Program / cancel your contract. If you elect to un-enroll / cancel, we will also need to disclose that information to Rewards Partners, 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.
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 this category of Personal Information. However, we share this information with our advertising vendors for purposes of cross-context behavioral advertising. | 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 Personal Information. However, if we did, you would have the right to opt out. You do have the right to opt out of us sharing your Personal Information with our advertising vendors for purposes of cross-context behavioral advertising. |
| Limit Use of Sensitive Personal Information | You have the right to limit the use of your sensitive Personal Information only that which is necessary for providing our Services. |
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.
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 [email protected].
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.
