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The Towny Rewards Program (“Program”) provides local businesses with a loyalty program and the ability to communicate with consumers of the Program, which may include sending special offers or real-time alerts. Roll Forward, LLC (“Company”) provides the technology that runs the Program for businesses who enroll (“Business Participant”).

This Privacy Policy applies to Company’s app for mobile devices (“Towny Rewards App”), Towny’s website ( (“Website”), and to information provided to Company by a consumer or a Business Participant. This Privacy Policy also applies to information gathered by Company as consumers use the Program, but it does not apply to any other services or websites that may be offered by Company or a Business Participant, or to any third party sites that may be accessible from the Program.

Further, this Privacy Policy does not apply to any other third party sites through which the Program may be delivered. To understand how any third party treats your information (including your information related to the Program), you should read the third party’s privacy policy. You should read this entire

Privacy Policy before using the Program or Website, or submitting or uploading information through the Towny Rewards App or business portal.

Do not use the Towny Rewards App, Website, or Program if you are unwilling to accept the terms and conditions of this Privacy Policy. You agree to the terms of this Privacy Policy by using any portion of the Program, which include collection, storage, use and disclosure of that information in accordance with this Privacy Policy.

Active Information Collection From Business Participants

Company actively collects information from Business Participants and prospective Business Participants who visit our Website or who become a Business Participant by accepting the Business Services Agreement (“BSA”), both (i) by permitting them to communicate directly with Company through the

Website, via email, or otherwise and (ii) when they sign up (in person, on the Website or otherwise) to become a Business Participant. Some of the information that a Business Participant submits that is required for a Business Participant to register to become a Business Participant could identify the

Business Participant and its employees, such as business name and address, credit card or bank information (for billing purposes), type of business, telephone number, email address, zip code and names of responsible employees. We refer to such information as “Identifiable Business Information.”

In addition, Business Participants may be asked to answer additional questions that are optional (“Optional Information”).

If a Business Participant does not submit the required information to sign up for the Program or does not accept the BSA Terms or agree to operate in accordance with this Privacy Policy in connection with the Program, the Business Participant will not be able to use the Program.

When a Business Participant uses the Program, Company will collect information related to the Business Participant and consumers, as described in the BSA Terms, the related Consumer Agreement, and this Privacy Policy.

From Consumers

Company actively collects information from our visitors by asking specific questions, by allowing you to upload information, and by permitting you to communicate directly with us through the Website, via email or otherwise. If you sign up to use the Program some of the information you submit is required to register you to use the Program. Some of such information could identify you personally, such as your first and/or last name, telephone number, email address, zip code and birthdate. Such information is called “Personally Identifiable Information.” In addition, you may answer additional questions on the settings tab that are optional. Such optional questions may include demographic information and/or additional Personally Identifiable Information, such as your name (if not previously provided), gender, financial information or other information. You will be informed which information on the registration form is optional. If you do not submit the required registration information you will not be able to use the Program. If you do not answer optional questions, you can still use the Program, but you will not be able to earn rewards that may be awarded to people who answer the optional questions and we may not be able to tailor the Program as closely to your interests.

Company and Business Participants may offer you, directly or through social media sites, or other third parties, the opportunity to participate in activities related to the Program, such as responding to surveys, entering a contest or sweepstakes, playing games or providing information to our customer service representatives. If you choose to participate in such activities (when offered) Company or Business Participants may collect additional Personally Identifiable Information or other information from you.

When you use the Towny Rewards App, use the Program, visit the Website, or participate in activities that are part of the Program, Company and Business Participants may collect information related to such activities. Company does not intentionally collect Personally Identifiable Information about you other than (i) such information that you provide us as described above, either directly or through permissions you authorize with social media sites which are used in conjunction with the Program, or (ii) information submitted to Company by Business Participants. Company may, however, keep track of your responses to Offers, visits to and purchases from Business Participants and associate that information with your registration information, including your Personally Identifiable Information (see “Program Information Collection,” below).

Passive Information Collection

As you navigate through the Towny Rewards App or the Website or use the Program, Company may collect certain information passively (that is, information may be gathered without you actively providing the information) using various technologies and means, such as navigational data collection and geolocation data. Like most website operators, Company, its advertisers and third party service providers may track IP addresses, use both session and persistent cookies, and assign Internet tags.

Company also automatically gathers information about the areas you visit on the Website and Towny Rewards App and collection operational information about the technology you use, such as your type of mobile device, operating systems, browser, Internet service provider and the domain names of the websites from which you linked to the Towny Rewards App or Website and to which you go after viewing such sites. If you activate geolocation applications, Company may have access to and store your geolocation information related to the Program.

In addition, when you visit the Towny Rewards App or Website, Company may store some information on your mobile device or computer. This information will be in the form of a cookie or similar file and will help us in many ways. For example, cookies allow us to tailor the Towny Rewards App, Website and the Program or other offerings to you in a way that better matches your interests and preferences. Most Internet browsers enable you to erase cookie from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Company and Business Participants do not collect Personally Identifiable Information automatically, but we may tie information collected automatically to your previously submitted Personally Identifiable Information.

The Towny Rewards App and the Website may contain electronic images known as web beacons- also referred to as single-pixel gifs- that permit Company and/or Business Participants to count users who have visited the Towny Rewards App or Website and for other related statistics- (e.g., recording the popularity of certain Towny Rewards App or Website content and verifying system and server integrity). Web beacons are not used by Company or Business Participants to access your Personally Identifiable Information; they are used solely to compile aggregated statistics concerning the use of the Towny Rewards App and Website. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.

The reason Company collects passive information is that it helps us understand which areas of the Towny Rewards App and Website are most popular, which areas may require improvement and what technologies are being used by our visitors. This information helps Company to update and improve the Towny Rewards App and Website and our Program. Company also uses this information for security purposes, to detect and to block security breaches and to provide you with a safer online environment.

Program Information Collection

After you register with Company you may receive Offers from one or more Business Participants; may have such Offers sent to you automatically via email, mobile communications (e.g. SMS text messaging, mobile notifications), social media; may be able to post those Offers on your own social media page to share with your friends; and/or may be able to use other tools offered by Company. Company may automatically keep track of all of those choices and associate them with the registration information you provided including your Personally Identifiable Information, plus any Optional Information you may have provided. Company may also keep track of, and associate with your Personally Identifiable Information and Optional Information, activities you engage in offline that relate to the Program, such as which Offers you respond to (for example, by purchasing the good or services that are the subject of the Offer) and loyalty rewards you earn from offline purchases. All of the information described in this paragraph is called “Consumer Participation Data.” Company may use Consumer Participation Data for a number of purposes, including keeping track of rewards, categorizing you with respect to your response to Offers and rewards of each Business Participant, and marketing goods or services of Business Participants, Company or third parties to you. Company will offer you the option not to receive such marketing messages. To do so, you should go to the Towny Rewards App and elect not to receive marketing messages.

Third Party Information Collection

The privacy policies of such social media and other sites, and sites that you may link to from the Program, are not under the control of Company or Business Participants. Neither Company nor any Business Participant has any responsibility or liability for the use of your personal information by social media companies, or any other third parties. Company and Business Participants are not responsible for the collection, storage or use of your information by such third parties, for their privacy policies or for their security practices. If you would like information on any other party’s privacy policy, you should contact that party directly, and we encourage you to do so.

This Privacy Policy is applicable only to information you submit to Company. If you link from the Towny Rewards App or the Program to websites controlled by one or more Business Participants, you should be aware that your activities on those sites are subject to the separate privacy policies of the respective

Business Participants applicable to those particular sites. If a Business Participant does not maintain a website with a privacy policy, you should ask such Business Participant about its privacy policies. Company may hire third parties to assist our marketing efforts by placing Towny ads on other websites or search engines. We may also use third parties to display ads of unrelated companies on the Website. Such third party marketers or advertisers may use cookies to serve ads based on your prior visits to the

Website and other sites. Company does not have any control over such cookies. You may be able to modify your browser settings to decline such cookies. If you decline cookies that affect your use of the Website some features may not be available or may not operate properly. For example, if you access the Program through social media, ads you may see framing the Program or presented in association with them are controlled by social media companies. You should review their Privacy Policy and/or contact them for information regarding such advertising, including whether any such advertisements may solicit, or contain technology to collect information from you.


Internal Use of Personally Identifiable Information Except as otherwise stated, Company may use information collected via the Program to improve the context of the Towny Rewards App and Website, to customize the Towny Rewards App to your preferences, to communicate information to you if you have requested it (such as your accrued rewards total), for our marketing and research purposes (including marketing other services provided by Company, Business Participants, or third parties), and for any other purpose specified in this Privacy Policy. You can opt out of receiving such marketing messages through the “Settings” tab in the Towny Rewards App and by choosing the opt-out option provided in email messages. You provide Personally Identifiable Information when you register for the Program. Company may combine any such information with consumer participation data. Company may provide Personally Identifiable Information and Optional Information you have provided to Company to certain Business Participants with which you are following or patronizing, and that have been permitted such information access by Company. When and if permitted by Company, such Business Participants may use that information to send you messages, independently of the Program, about their goods and services and about the good and services of other businesses. If you do not wish to receive such messages you may opt out of receiving them by choosing the opt-out option provided in such messages. All Business Participants granted such permission by Company will agree not to provide your Personally Identifiable Information to third parties except as described in the next section.

Limited Disclosure of Personally Identifiable Information to Third Parties

Company will not disclose Identifiable Business Information or Personally Identifiable Information provided by consumers or Business Participants or that Company collects in conjunction with the Program to third parties (i.e., to parties other than Business Participants) without consent, except as described below. Business Participants have also agreed to limit disclosure of consumer’s Personally

Identifiable Information to the following:

(A) To contractors or service providers Company or a Business Participant uses to support its business (such as programming, providing technical support, enhancing data usage, analyzing data and/or assisting with marketing, customer service and other administrative tasks), and only if Company or the Business Participant providing the information understands that such third parties with treat your personal information consistently with this Privacy Policy; (B) In the event of a sale, merger, liquidation, dissolution, reorganization, assignment, or other transfer of stock in the business of a Business Participant and/or Company, respectively (“Sale of Business”). In the case of any Sale of Business, it is the obligation of the buyer to use the information of Business Participants and/or consumers collected by Company in accordance with this Privacy Policy. If the buyer changes this privacy policy it should do so only prospectively and after providing Business Participants and/or consumers, as applicable, notice of the change;

(C) If required by law or in response to any judicial order, inquiry of any administrative agency; in response to a subpoena or an inquiry from law enforcement or governmental authorities;


(D) If Company or a Business Participant believes the release of such information is necessary to protect the rights of Company or the Business Participant (including BSA Terms or Consumer Agreement) or to address or prevent illegal or harmful activity.

Other than as described above, Company does not distribute Identifiable Business Information or Personally Identifiable Information to third parties, and Business Participants have agreed not to do so either. However, you understand that if you access the Program through any other third party platforms, the operator of such platforms will have access to your registration information and other information generated by your use of the Program, which may be aggregated with other information about you accessible to the operator of such platforms, and may be stored and used by them, subject to the applicable privacy policy.

Neither any Business Participant nor Company will have any liability for disclosure of your information resulting from actions by social media companies or platforms, or from errors in transmission or the unauthorized intervention of third parties.

Information that Does Not Identify Your Business or You Personally Company may provide aggregate statistics or information about its consumers, sales, trends, loyalty program usage, online traffic patterns, related information or other statistical de-identified or aggregated information to third parties, but these statistics or information will not include any Identifiable Business Information or Personally Identifiable Information (“Non-Identifying Information”).

Non-Identifying Information collected about consumers, Business Participants and prospective Business Participants is also used by Company and/or third parties we contract with to troubleshoot, operate and improve the Towny Rewards App, the Website, to assist us with marketing or ad placement, to cooperate with law enforcement activities or legal orders, to protect our rights (including enforcing the BSA and Consumer Agreement) or to address or prevent illegal or harmful activity. In addition, Company may use all information submitted by consumers, Business Participants or prospective Business Participants or that Company collects about any of the foregoing that is Non-Identifying Information in any way Company deems useful, including publishing statistics such as those described above to promote Company or the Program.

Interest Marketing

Company may use information that consumers provide or that Company collects about consumers from their use of the Program including their response to Offers from Business Participants, other information to send consumers marketing messages related to goods or services Company believes will be of interest to them. Such goods or services may be offered by Company, Business Participant, or other third parties. Such marketing messages may be sent via mobile communications, email, social media or otherwise, depending on how the consumer has elected to receive Offers from various Business

Participants. Consumers can opt out of receiving such marketing messages through the “Settings” tab in the Towny Rewards App and by choosing the opt-out provided in email messages.


Company strives to provide Business Participants, and Company and Business Participants strive to provide consumers, with choices regarding the information Business Participants and consumers provide. Company has created mechanisms to provide Business Participants and consumers with the following control over their information: (i) You may view and modify the Identifiable Business Information or Personally Identifiable Information and/or Optional Information you submitted through the Towny Rewards App or Business Portal, as follows: if you are a Business Participant, you may modify the information you submitted when you signed up to become a Business Participant as described in the BSA. If you are a consumer you may modify the information you submitted when you registered by going through the Towny Rewards App. To stop receiving Offers from a particular Business Participant, consumers should opt out of such messages through the “Settings” tab in the Towny Rewards App and choose the opt-out option provided in emailed messages sent by such Business Participant. Company keeps track of consumers’ transaction with Business Participants, as well as communications about Business Participants that consumers make through the Towny Rewards App. Consumers cannot delete information associated with such transactions and communications. (ii) Marketing messages from Company and, when and if permitted, Business Participants or third parties, will contain an option for the consumer to choose not to receive such messages in the future. (iii) If a consumer does not wish Company to collect cookies, he or she may set the browser to refuse cookies, or to alert the user when cookies are being sent. Please note that some parts of the Program may then be inaccessible or may not function.


Company works hard to protect the personal information of consumers, using both technical and procedural methods to maintain the integrity and security of our databases. These include the use of SSL encryption, firewalls, administrative access level controls and employee training. Consumers should keep in mind, however, that no Internet transmission or data storage is ever completely secure or error-
free. While Company believes it uses commercially reasonable security procedures, it cannot guarantee the security of any information submitted by consumers, Business Participants or prospective Business Participants, information gathered about consumers or information stored by Company. Each Business Participant has agreed to abide by this Privacy Policy. Company is not responsible for Business Participants’ compliance with this Privacy Policy or for Business Participants security policies and practices. Each consumer acknowledges and agrees that Company has no responsibility or liability for the security policies or practices of any Business Participant, or for any security breach of any Business Participants’ systems or databases. Neither Company nor any Business Participant is responsible for the actions of any third party, including but not limited to social media sites or other sites, with whom information about you may be shared or who may otherwise obtain such information. The safety and security of information of Business Participants and consumers also depends on the consumer. Business Participants and consumers should never share their Company passwords, or any other password with anyone else, and should notify Company or other relevant provider promptly if you believe your password security has been breached. Remember to log off the Towny Rewards App before you leave your mobile device. The Towny Rewards App, Website, or other sites through which consumers may use the Program may contain links to other sites and/or resources over which Company and Business Participants have no control. Company and Business Participants make no representations or warranties with respect to the content, ownership, or legality of any such linked sites. Links to third party sites are provided solely as a convenience to consumers and should not be construed as an affiliation with or endorsement by Company or Business Participants of such third parties or any content, items, or services on third-party sites. Access and use of such other sites, including the content, items, or services on those sites, are solely at the risk of the consumer, and neither Company nor any Business Participant has any responsibility or liability resulting from consumer’s access or use of such other sites. These linked sites may collect personal information from consumers when entering their site. Any such collecting of information is not subject to the control of Company or any Business Participant. To ensure protection of privacy, consumers should always review the privacy policies of the sites they visit when linking from the Towny Rewards App, Website or any other site associated with the Program. Consumers acknowledge and agree that neither Company nor any Business Participant has any responsibility or liability for the availability of such external sites or resources, or for the content, advertising, products, or other materials available through such sites or resources.


The Towny Rewards App, Website, and Program are not intended for children under the age of 13 and are not designed to attract anyone under the age of 13. Business Participants who use the Program may sell goods or services for children that are intended to be purchased by adults. Company will not knowingly collect Personally Identifiable Information from site visitors under the age of 13, and Business

Participants have agreed they will not knowingly collect such information. Company and Business Participants encourage parents to talk to their children, including children between the ages of 12 and 18 about their use of the Internet and the information they disclose online. If a child of any age has provided Company with Personally Identifiable Information, and a parent or guardian of that child would like this information deleted from Company’s records, such parent or guardian may contact Company by going to the Website and clicking on the appropriate tab. Company will then use reasonable efforts to delete the child’s information from our databases.


Consumers may be allowed to post public comments, including comments about Business Participants and their goods and services, on Business Participants’ social media. Such capability is offered by social media company, and is subject to the privacy policy of such social media company. We encourage you to review such privacy policies before submitting any such comments. Consumers may also be allowed to post similar comments on the Website. Any messages posted in public access portions of social media sites or the Website may be read, saved, used and/or distributed by such social media companies,

Company, Business Participants and any other users of the sites. Any such postings may be re-posted by any of such users on other websites, used in blogs, etc., and may appear in web searches. Neither Company nor any Business Participant can control who views information so posted or what they do with it, so care should be used when sending any personal information to any public access site. Company and Business Participants also cannot control and are not responsible for the accuracy, truthfulness or tastefulness of any information posted by other users on social media sites, on the Website or any other public access site.

Contacting Company

Questions, comments or concerns about this Privacy Policy or the information practices of this site should be addressed to:


3700 W. Parmer Ln., Ste 202

Austin, TX 78727


Or directly to the Business Participant to which such questions, comments or concerns relate. Please review this Privacy Policy carefully. If you do not agree with this Privacy Policy, your ultimate choice is not to use the Program. Remember, by registering with Towny or using any part of the Program, you accept and agree to the privacy practices described in this Privacy Policy. Business Participants agree that this Privacy Policy is incorporated by reference with the BSA. Consumers agree that this Privacy Policy is incorporated by reference into the Consumer Agreement. By using the Towny Rewards App, visiting the Website, or using the Program, you accept that any dispute over privacy is subject to this Privacy Policy and the BSA or Consumer Agreement (as applicable), including but not limited to limitations on liability, disclaimers of damages, releases, waivers and application of the law of the State of Texas. If you have any concern about privacy issues, please contact Company as directed above.

Company and Business Participants reserve the right to update this Privacy Policy at any time. If this Privacy Policy is materially changed, the revised policy, or a notice that the policy has been revised, will be posted on the Towny Website and the Towny Rewards App. You are responsible for periodically reviewing the Privacy Policy, and should do so frequently, especially before you provide any Identifiable

Business Information or Personally Identifiable Information. When Company changes this Privacy Policy, we will also revise the “last updated” date at the end of this Privacy Policy. If Company updates this

Privacy Policy, continued use of the Program (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy. Company recommends that you periodically review this Privacy Policy.

This Privacy Policy was last updated on April 14, 2017.