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We’ve updated our Privacy Policy.

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Rewards Network

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   * * * In our 35 years, Rewards Network has helped nearly 100,000 local
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PRIVACY POLICY



Reviewed and effective as of October 17, 2023

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.

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: clientservices@rewardsnetwork.com
 * 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
legal@rewardsnetwork.com 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: 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 /
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 InformationCategory of Source from which Personal
Information is CollectedPurpose of CollectionCategory of Service Providers to
whom Personal Information is DisclosedCategory of Third Parties to whom Personal
Information is Sold or SharedRetention PeriodIdentifiers, 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 usThe 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
usCommercial 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
usInternet 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 yearsGeolocation 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 RightDescriptionNoticeThe 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.AccessThe 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 PortabilityThe right to receive the Personal Information you
have previously provided to us.ErasureThe 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.CorrectionYou 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 MakingYou 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 InformationWe 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 InformationYou 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 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.


FOOTER


REWARDS NETWORK

540 W Madison St, Suite 2400
Chicago, IL 60661
(800) 766-3463



Rewards Network is the nation’s leading promotional program for the restaurant
industry. For more than 35 years we’ve helped local restaurants thrive by
filling seats with full-price customers and offering flexible funding options
that help operators grow their business.


HOW IT WORKS

 * Our rewards partners
 * Full price guests
 * Restaurant success stories
 * FAQs


RESTAURANT RESOURCES

 * Blog
 * Free downloads
 * Restaurant guides


PROGRAM BENEFITS

 * Pay for performance
 * Data-driven insights
 * 100% turnkey marketing
 * Verified customer reviews
 * Flexible funding options


ABOUT US

 * Leadership
 * Careers
 * Newsroom
 * Security and accreditations

Get started

CLIENT LOG-IN

Not a restaurant owner?
Dining member rewards

 * Privacy policy
 * Terms of use
 * Sitemap
 * Do not share my data

© 2024 Rewards Network Establishment Services Inc. All rights reserved.

Individual results within the Rewards Network program may vary. Please contact
us for details.

Any testimonials, statements, and opinions are applicable only to the
individuals depicted. Testimonials were provided voluntarily. Participants were
not paid or provided with any benefits in exchange for their statements.

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