Employee and Applicant Privacy Policy
Effective Date/Last Updated: December 13, 2022
In this Employee and Applicant Privacy Policy (“Policy”), Rewards Network Establishment Services Inc. (“Rewards Network”, “we”, or “us”) describe the types of information that we collect from job applicants, and current and past employees, how we use that information, and how we may share that information.
This Policy applies to current and former Rewards Network employees as well as applicants to open positions at Rewards Network. This Policy does not form part of any contract of employment offered to job applicants hired by Rewards Network. Provisions of this Policy dealing with individuals employed with Rewards Network are not applicable until they begin working for us.
We may change this Policy from time to time, and we will post changes in an area of our website that is accessible to current and former Rewards Network employees.
Personal Information We Collect
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. We collect the following types of Personal Information when you apply for a job with Rewards Network or during the course of your employment at Rewards Network:
- Your name, address, email address, telephone number, and other contact information;
- Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process;
- Information from interviews you may have, if any;
- Details of the type of employment you are looking for, current and/or desired salary and other terms relating to compensation and benefits packages, and job preferences;
- Details of how you heard about the position you are applying for;
- Any sensitive and/or demographic information obtained during the hiring process such as Social Security number, gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin;
- Reference information and/or information received from background checks (as applicable), including information provided by third parties;
- Information relating to any previous applications you may have submitted to Rewards Network and/or any previous employment history with Rewards Network;
- Information about your educational and professional background from publicly available sources that we believe is relevant to your application or a potential future application (e.g., your LinkedIn profile);
- Banking information for direct deposit purposes, income history and income information, and benefits information as well as information regarding your beneficiaries; and
- Information collected from you automatically when you use our website, while using a Rewards Network device, or while connected to Rewards Network’s Internet through cookies, web beacons, pixel tags, and other online tracking mechanisms.
Information Collected From Other Sources
We obtain information about individuals from various third-party and public sources and we may combine that data with Personal Information we have. For example:
- Rewards Network may collect application information from recruiters;
- Rewards Network may collect information regarding your past employment (including performance information) from former employers;
- Rewards Network may collect information regarding your citizenship or eligibility to work in the country where you would be employed from government agencies;
- Rewards Network may collect your credit history and/or criminal record if you consent to a credit check or background check;
- Rewards Network may collect information relating to your qualifications to work with Rewards Network from your references;
- Rewards Network may collect your drug test results from the third-party services provider Rewards Network uses to perform applicant and employee drug tests; and
- Rewards Network will collect tax related information from the Internal Revenue Services.
Children Under 18
We only employ those who are legally eligible to work at the location of employment, which is typically the age of majority (18 years old). Please do not send us application materials if you are under the legal age eligible for employment.
Purposes for Which We Collect Personal Information
Rewards Network processes your Personal Information as described in this Policy for the following purposes:
- To Manage the Application Process. We use your Personal Information to process your job application, to verify the information you have provided in your application, to communicate with you regarding your application, to answer your questions regarding the application process and to confirm your eligibility for a position. We may also save your information for future job openings within Rewards Network.
- To Manage the Hiring Process. We may use your Personal Information in the hiring process to conduct interviews. We may also use your Personal Information to perform background and reference checks, with your consent, if you are offered a position.
- To Communicate with You. We may use your Personal Information to provide information to you, to respond to your questions, to notify you of changes to your compensation and benefits program or to notify you of emergencies.
- To Manage the Onboarding Process. Upon being hired by Rewards Network, we will collect Personal Information when you complete new hire paperwork to assist us in administering salary and benefits and to assist us with complying with governmental and legal requirements.
- To Administer Compensation and Benefits Programs. We will use the Personal Information you provide to process payroll, pay taxes, help employees address employment related tax issues, administer benefits and handle work related expense reimbursement. We may also use this Personal Information to manage requests for accommodations requests. We also use this to administer employee claims such as under workers’ compensation or unemployment benefits.
- Recruiting. We may use Personal Information to communicate with you regarding the recruiting process, to learn where you heard about Rewards Network, and to evaluate and improve our recruiting process.
- For Performance Management. Rewards Network collects Personal Information in order to assess your performance, assist in career development, conduct pay and grading reviews, and to handle any employment related disputes. We may also use Personal Information to respond to violations of company policies and to gather information for disciplinary actions. We use Personal Information for purposes of the internal performance improvement and disciplinary process and to respond to complaints. We may monitor any activity you perform online while using a Rewards Network device or while connected to Rewards Network’s internet, such as monitoring the websites you visit and your activity on those websites when using a Rewards Network device or internet connection. We may also track the emails you send using your Rewards Network-provided email address, the phone calls you make using a Rewards Network-provided device, and the chat messages you are involved in using the Rewards Network-provided instant messaging program(s).
- Education and Professional Services. We may use your Personal Information to assist with education, training and professional development. We may use this information to assist with professional development.
- Law Enforcement and Courts. We may disclose your Personal Information in response to a subpoena, a search warrant or other legally valid process. We may use your Personal Information to cooperate with law enforcement or other government entities if you are suspected of having violated applicable laws.
- Record Keeping. We may use Personal Information to comply with applicable legally required or industry standard business and employment record keeping requirements and to respond to governmental requests for information.
- Health and Safety. We use Personal Information to protect your health and safety, or the health and safety of others, including through the use of technology to allow contract tracing if you may have been exposed to communicable diseases such as COVID-19. We may also use this information to respond to an employee related emergency. We also use this Personal Information to protect our facilities and personal property.
- Protect Our Legal Rights. We may use your Personal Information to protect our legal rights, to defend a claim or lawsuit, and to investigate or prevent actual or suspected loss or harm to persons or property. We may use your Personal Information to seek legal, accounting or other professional advice. We may use your Personal Information when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Rewards Network or any other party.
- Security. We may use your Personal Information to monitor the use of our information systems and electronic resources, to conduct internal audits or investigations and for safety and security of Rewards Network employees, visitors and facilities. We also may use such information to protect Rewards Network against illegal activity and misconduct such as fraud, deceptive practices and data security incidents. We use this to offer, operate, maintain, deliver, troubleshoot and update the Sites, programs, network and systems used by Rewards Network in the course of its business.
How We Share Your Personal Information
We share your Personal Information in the following circumstances:
- Within Rewards Network. We may share your Personal Information internally within Rewards Network and among Rewards Network’s affiliates for purposes of recruiting and/or evaluating applicants, resource planning, and talent and recruiting, human resources and business administration functions. All Rewards Network employees who access or process applicant Personal Information are required to comply with Rewards Network’s privacy and security policies.
- Service Providers. Rewards Network may share Personal Information with third-party service providers or suppliers (“Service Providers”) that include, without limitation, data storage providers, website or mobile application hosting providers, and e-mail service providers as needed to provide the applicable services to us. Rewards Network will take steps to help ensure appropriate protections are in place before we share or disclose Personal Information with any Service Provider.
- Legal Requirements. We will cooperate with law enforcement and other governmental agencies. We may disclose Personal Information for the following legal purposes:
- If we believe in good faith we are legally required to disclose that Personal Information
- If we are advised to disclose Personal Information by our legal counsel
- When necessary to identify, contact or bring a legal action against someone who may cause or is causing harm to, or interfering with the legal rights of, Rewards Network or any other party
- For tax and payment purposes (e.g. Internal Revenue Service)
- To protect our rights or property, protect your health and safety, or the health and safety of others
- To detect and investigate fraud or illegal activity, or to respond to a government request
- To respond to an emergency
- Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys and accountants, in their capacity as advisors, including for advice on potential or actual litigation matters.
- Change in Ownership. We may use and disclose Personal Information in connection with the evaluation of a change of control of Rewards Network such as in the event of a merger, acquisition, or sale of assets. We may provide Personal Information both in connection with a due diligence process or it could be transferred as part of the change of control to subsequent owner(s). If we (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change of control or reorganization, Personal Information and other information could be one of the assets transferred to or acquired by a third party, or reviewed as part of the due diligence process.
De-Identified/Aggregate Information
We may collect or create information that is de-identified or aggregate information that does not identify a natural person (“De-Identified Information”). Rewards Network is the sole and exclusive owner of De-Identified Information and may use or share such information for any legal business purpose. For example, Rewards Network may create aggregate information about applicants to learn about the success of its recruiting processes.
Data Security
Rewards Network makes commercially reasonable efforts to protect employees’ and applicants’ Personal Information. We protect Personal Information using technical and organizational measures designed to reduce the risks of loss, misuse, and unauthorized access, disclosure, alteration, and destruction of Personal Information appropriate to the type of Personal Information processed.
Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances. Rewards Network employees and applicants are responsible for safeguarding the security of any password, user ID, or other form of authentication involved in obtaining access to password-protected or secure areas of any Rewards Network-owned or licensed platforms. It is your sole responsibility to use the appropriate level of care whenever communicating with us.
If you have reason to believe that your interaction with us is no longer secure, you must immediately notify us of the problem. If a breach of your Personal Information occurs, we will notify you of the breach if and as required under applicable law. In order to protect you and your Personal Information, Rewards Network may suspend your use of any Rewards Network programs or platforms without notice pending an investigation if any breach of security is suspected.
Retention of your Personal Information
Personal Information will be stored in accordance with appliable laws and kept as long as needed to carry out the purposes described in this Policy or as otherwise required by applicable law, taking into consideration any statutorily required minimum periods of time in applicable jurisdictions. Generally, this means your Personal Information will be retained until the end or your employment, or work relationship with us plus a reasonable period of time thereafter to respond to employment or work-related inquiries or to deal with any legal matters, document the proper termination of your employment or work relationship, or to provide you with any ongoing benefits.
Personal Information which is no longer to be retained will be securely and effectively destroyed or permanently erased from our systems and we will also require third parties to destroy or erase such Personal Information where applicable.
California Employees/Applicants
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, as amended by the California Privacy Rights Act (the “CPRA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, 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
Pursuant to applicable California law, including the CPRA, Rewards Network makes the following disclosures regarding Personal Information collected and/or sold 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 | See Section above titled “Purposes for Which We Collect Personal Information” | Data storage providers, website or mobile application hosting providers, and e-mail service providers | We do not sell or share this category of Personal Information. | Applicants: Duration of application process plus 7 years Employees: Length of your employment plus 7 years |
| Internet or other similar network activity. | You | See Section above titled “Purposes for Which We Collect Personal Information” | Data storage providers, website or mobile application hosting providers, and e-mail service providers | 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 |
| Professional or employment-related information. | You, background check providers, former employers, recruiters, your references, and publicly available sources | See Section above titled “Purposes for Which We Collect Personal Information” | Data storage providers, website or mobile application hosting providers, and e-mail service providers | We do not sell or share this category of Personal Information. | Applicants: Duration of application process plus 7 years Employees: Length of your employment plus 7 years |
| Sensitive personal information (e.g. Social Security number, gender, information about your citizenship and/or nationality, medical or health information, and/or your racial or ethnic origin) | You | See Section above titled “Purposes for Which We Collect Personal Information” | Data storage providers, website or mobile application hosting providers, and e-mail service providers | We do not sell or share this category of Personal Information. | Applicants: Duration of application process plus 7 years Employees: Length of your employment plus 7 years |
If you are a resident of California, 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 your Personal Information. However, if we did, you would have the right to opt out of the sale or sharing of your Personal Information. |
| Limit Use of Sensitive Personal Information | You have the right to limit the use of your sensitive Personal Information (e.g. Social Security number and driver’s license information) to 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 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.
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.
Changes to this Policy
We may change this Policy from time to time, and we will post any changes on this page. Each version of this Policy is identified at the top of the page by its Effective Date.
Contact Us
For any questions or concerns, please contact us at [email protected].
