Fuel Rewards® program

"We may also disclose personal information with retailers or brands, including our Fuel Rewards® retail and brand partners, social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also disclose personal information with companies that help us learn more about our customers."

Personal information is shared with a wide ecosystem of third parties including advertisers, ad networks, media buying agencies, and data enrichment companies — well beyond what's needed for the loyalty program.

"Internet or other similar network activity. This may include device information, battery level, unique personal identifier, online identifier, IP address and location based on IP address, Wi-Fi information, Bluetooth information, advertising identifier, device identifier, browsing history, search history, and information regarding interaction with an Internet website, application, or advertisement."

The policy collects advertising identifiers, device identifiers, browsing history, and Wi-Fi/Bluetooth information, and explicitly states it may combine information across different devices and from third-party sources to build user profiles.

"You authorize us to, in our reasonable discretion, collect location data using your device to provide you with recommendations based on your location and past dining activity, analyze your general dining patterns and stores that you visit, and also aggregate this data to help understand general Program member patterns and trends, which we may share with third parties with our discretion. You are agreeing that we can continue to collect location data until you turn off data collection in your device."

Location data is collected continuously until the user manually disables it at the device level, used for tracking dining patterns and store visits, and may be shared with third parties at the company's discretion.

"This may include device information, battery level, unique personal identifier, online identifier, IP address and location based on IP address, Wi-Fi information, Bluetooth information, advertising identifier, device identifier, browsing history, search history. Session Data may include browser type and version, time zone setting, browser plug-in types and versions, operating system, platform."

The policy collects battery level, Wi-Fi and Bluetooth information, browser plugins, and device identifiers — data well beyond what a fuel rewards loyalty program needs to function.

"Our Personal Information Retention Criteria: The amount of time that we may retain the above categories of personal information varies based on a number of factors. These factors include what personal information is reasonably necessary to (i) provide our products and services or administer our relationship with an individual; (ii) protect our business, employees, organization and others; (iii) fulfill our legal and regulatory obligations."

The main Fuel Rewards program provides only vague retention criteria with no specific timelines. The Dining program retains data 3-7 years after last transaction, with commercial transaction data kept for 7 years.

"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. 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."

The Dining Program privacy policy can be modified at any time with changes effective immediately upon posting, placing the burden on users to check for updates.

"If you do not agree to have your information collected, shared and used as described in this Privacy Policy, you may terminate your Program account at any time by contacting us at (855) 694-3463 or visiting the 'Manage cards' portion of the Account center while logged in, and deleting all remaining credit and/or debit cards from your account."

Account termination for the Dining Program requires either calling a phone number or manually removing all linked cards one by one — there is no straightforward self-service delete account option.