PRIVACY POLICY

Last Updated: January 16, 2025

1. Introduction

FutureFWD LLC (“Company,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals who use our services. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our digital marketing and customer engagement services, including QRewardR gamification platform, Go SoCo Go LoCo business directory, and Blast Creative marketing automation services (collectively, the “Services”).

We prioritize privacy for both our merchant clients and their end-user customers. By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

2.1 Information from Merchants (Our Direct Clients)

When merchants subscribe to our Services, we collect:

∙ Business name and contact information

∙ Email address and phone number

∙ Billing and payment information (processed securely through third-party payment processors)

∙ Account credentials and authentication information

∙ Business-related preferences and settings

2.2 Information from End Users (Merchant Customers)

When end users interact with our Services through merchant implementations (such as QRewardR games), we may collect:

∙ Basic contact information (name, email address, phone number)

∙ IP addresses and device information

∙ Interaction data related to game participation and reward redemption

∙ Communication preferences

∙ Any other information voluntarily provided during service interactions

Important: End users interact with our Services at the direction of our merchant clients. Merchants are responsible for obtaining appropriate consent from their customers and honoring customer communication preferences.

2.3 Automatically Collected Information

We may automatically collect certain technical information, including:

∙ Browser type and version

∙ Device information (type, operating system)

∙ IP address and general location data

∙ Usage patterns and interaction data with our Services

∙ Cookies and similar tracking technologies (as described in Section 6)

3. How We Use Information

3.1 Merchant Information

We use merchant information to:

∙ Provide, operate, and maintain our Services

∙ Process subscription payments and manage accounts

∙ Communicate about services, updates, and support

∙ Improve and optimize our Services

∙ Comply with legal obligations

∙ Detect and prevent fraud or security issues

3.2 End User Information

End user information is collected and processed on behalf of our merchant clients to:

∙ Operate gamification features and customer engagement tools

∙ Facilitate reward distribution and redemption

∙ Enable merchants to communicate with their customers

∙ Analyze service performance and improve functionality

∙ Comply with legal requirements

We do not use end user information for our own marketing purposes. Merchants retain control over their customer data and are responsible for all marketing communications sent to their customers through our Services.

How We Share Information

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including:

∙ Payment processing (Stripe and other payment processors)

∙ Cloud hosting and infrastructure (Go High Level and other platforms)

∙ Communication services (email and SMS delivery platforms)

∙ Analytics and performance monitoring

∙ Customer support tools

These service providers are contractually obligated to protect information and use it only for the purposes we specify.

4.2 Merchants

When end users interact with merchant-deployed Services, the information collected is shared with the applicable merchant client. Merchants are responsible for their own use, storage, and protection of their customer data in accordance with applicable privacy laws.

4.3 Legal Compliance

We may disclose information when required by law or in response to:

∙ Valid legal processes (subpoenas, court orders, legal proceedings)

∙ Government or law enforcement requests

∙ Protection of our rights, property, or safety

∙ Investigation of fraud, security issues, or violations of our Terms of Service

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, user information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

4.5 What We Don’t Do

∙ We do not sell end user information to third parties

∙ We do not share end user information for third-party marketing purposes

∙ We do not use merchant customer data for our own sales or marketing campaigns

5. Data Retention

5.1 Merchant Data

We retain merchant account information for as long as the account is active and for a reasonable period thereafter as necessary for:

∙ Legal and regulatory compliance

∙ Dispute resolution

∙ Fraud prevention

∙ Legitimate business purposes

5.2 End User Data

End user data is retained as directed by our merchant clients and as necessary to provide ongoing Services. When a merchant cancels their subscription, associated end user data may be retained for a reasonable period to comply with legal obligations and resolve potential disputes.

5.3 Data Deletion Requests

Merchants may request deletion of their data by contacting us at [email protected]. End users should contact the applicable merchant directly to request deletion of their information.

6. Cookies and Tracking Technologies

6.1 Essential Cookies

We use only essential cookies necessary to enable the functionality of our Services, including:

∙ Session management and authentication

∙ Security features

∙ Service functionality and performance

∙ Load balancing and system stability

6.2 No Third-Party Advertising Cookies

We do not use cookies for third-party advertising or non-essential tracking purposes.

6.3 Your Choices

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies. Please note that disabling cookies may limit your ability to use certain features of our Services.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, or destruction. These measures include:

∙ Encryption of data in transit and at rest

∙ Secure authentication and access controls

∙ Regular security assessments and updates

∙ Restricted access to personal information

∙ Third-party security audits and compliance measures

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

8. Merchant Responsibilities

Merchants who use our Services are responsible for:

∙ Obtaining appropriate consent from their customers for data collection and communications

∙ Honoring customer preferences regarding marketing messages and emails

∙ Complying with applicable privacy laws (including CAN-SPAM, TCPA, GDPR, CCPA, and other regulations)

∙ Maintaining their own privacy policies for end user interactions

∙ Curating and managing their customer opt-out requests

∙ Protecting customer data accessed through our Services

FutureFWD LLC does not contact merchant customers directly for marketing purposes. All communications to end users are initiated and controlled by the merchant.

9. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

9.1 Access and Correction

You may request access to the personal information we hold about you and request corrections to inaccurate information.

9.2 Data Portability

You may request a copy of your personal information in a portable format.

9.3 Deletion

You may request deletion of your personal information, subject to legal retention requirements and legitimate business needs.

9.4 Opt-Out

∙ Merchants may opt out of marketing communications by following unsubscribe instructions in our emails or contacting [email protected]

∙ End users should contact the merchant directly to manage communication preferences

9.5 Exercising Your Rights

To exercise these rights, please contact us at [email protected]. We will respond to requests within a reasonable timeframe as required by applicable law.

Children’s Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected information from a child without parental consent, we will take steps to delete that information promptly.

10. International Data Transfers

Our Services are operated in the United States. If you access our Services from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. By using our Services, you consent to such transfers.

11. Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with third-party platforms. This Privacy Policy does not apply to those external services. We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you access.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on our website with a new “Last Updated” date. Material changes will be communicated through:

∙ Email notification to registered merchants

∙ Prominent notice on our website

∙ In-service notifications

Your continued use of the Services after changes are posted constitutes acceptance of the updated Privacy Policy.

13. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

∙ Right to know what personal information is collected, used, shared, or sold

∙ Right to request deletion of personal information

∙ Right to opt out of the sale of personal information (Note: We do not sell personal information)

∙ Right to non-discrimination for exercising your privacy rights

To exercise these rights, contact us at [email protected].

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

FutureFWD LLC7679 E. Chaparral Rd.Scottsdale, AZ 85350Email: [email protected]