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”).
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”).
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.
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
HOW COMPANY AND BUSINESS PARTICIPANTS USE AND MAY DISCLOSE INFORMATION OBTAINED THROUGH THE PROGRAM
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:
(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.
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.
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 by choosing the opt-out provided in email messages.
CHOICES CONSUMERS HAVE ABOUT HOW COMPANY AND BUSINESS PARTICIPANTS USE THEIR INFORMATION
HOW YOUR INFORMATION IS PROTECTED
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-
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.
ROLL FORWARD, LLC
2028 E Ben White Blvd
Austin, TX 78741