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Privacy Policy

COMPANY NAME their affiliates and franchisees, (“Company name,” “we,” “our,” or “us”) are committed to protecting the information that you share with us, and explaining how we collect, process, and share that information. 

Scope and information that this Online Privacy Notice covers

This Online Privacy Notice (this “Privacy Notice”) applies only to Personal Information (defined below) collected on our websites, mobile applications, or cloud-based services and communication platforms with a link to this Privacy Notice (collectively, the “Site”).  This Privacy Notice includes information on how we collect, use, share, and otherwise process personal information since this Privacy Notice was posted. References to “Personal Information” in this Privacy Notice means information that identifies or can reasonably identify users of the Site (“you”) personally. 

Summary of Key Points

Collection

We generally collect Personal Information that you provide to us.

Use

We generally use Personal Information to provide you with services from our Site, to communicate with you, and improve our services.  Further information about the use of your Personal Information in support of our business activities is available below.

Sharing

We may share your Personal Information with business partners, external service providers, third party vendors, or as otherwise necessary to support the services we provide you and manage our business.  Further information about the use, processing, and disclosure of your Personal Information is available below.

Security

We employ reasonable and current technical, administrative, and physical safeguards that are designed to prevent unauthorized access or disclosure of Personal Information in our custody or control, and maintain data accuracy.

International Transfers

Company Name is based in the United States.  If you are located in the European Union (“EU”), the data protection laws of the United States or other countries may not be considered to provide an adequate level of protection under your local data protection laws.  If you are a visitor to this Site, and prefer not to have your Personal Information transferred to the United States, do not use this Site.  Further information about the cross-border transfer of your Personal Information is available below.

Data Retention

Depending on the program or service, we will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law or regulation that applies to us or the data retention for the program or service.

Children

Persons under the age of 16 are ineligible to use any services on our Site.

Changes

We may amend this Privacy Notice at any time.  If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy Notice on our Site.

Contact Us

If you have questions not answered in this Privacy Notice, you may contact us directly at privacy@companyname.com.

Personal Information You Provide

For public areas of our Site, we generally collect and process only Personal Information you voluntarily provide to us.  We don’t require you to give us Personal Information to access certain public areas of our Site.  This is true unless you live in a jurisdiction that defines personal information to include network identifiers like your Internet Protocol addresses.  For some secure areas of our Site, however, we require you to provide Personal Information, including your login credentials.  We also collect your Personal Information on the Site to perform services on our Site, enhance the services we offer you, maintain and improve the Site, to secure you and our Site, comply with legal obligations, and inform you about other services and products that may be available through us, our affiliated companies, and our marketing partners. 

If you choose not to provide us with the Personal Information that we legitimately require, we may be unable to provide you with the information or services you have requested.  Public areas of our Sites ask for Personal Information from you when you engage in the following activities:

  • Register for an account with us;
  • Make a purchase on our Site;
  • Sign up for newsletters or general information about our programs and services;
  • Interact with us directly or through social networks;
  • Respond to surveys or submit comments, reviews, or other user-generated content;
  • Learn more about franchising opportunities;
  • Request customer or technical support.

Personal Information may include any or all of the following:

  • Name;
  • Postal or billing address;
  • E-mail address;
  • Telephone or mobile number;
  • Payment card information;
  • Location via IP address;
  • Device being used (for our mobile site);
  • Previous login history with our Site; and
  • Other relevant data, including any information you provide when contacting us.

Even if you do not send us any Personal Information, we may collect certain non-personal information about how you use our Site.  This non-personal information cannot reasonably identify you, and is used for certain analytics and statistical purposes.

Information Collected Through Technology

We may also obtain information in other ways through technology.  Some of this information may be linked to you personally.  We process this information to help our Sites function correctly, and better understand the needs of our customers.

Device Information.  Depending on the permissions you’ve granted and other factors, we may receive information about your location and your mobile device, including a unique identifier for your device.  Examples of the device information we collect include:

  • Attributes such as the operating system, hardware version, device settings, battery and signal strength, and device identifiers.
  • Certain device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals are gathered if you enabled the functionality within our product configuration.
  • Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
  • Gathering of IP address is used for our enhanced security. 

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.

How We Use and Share Your Personal Information

We do not share your Personal Information with unaffiliated third parties solely for their own direct marketing purposes.  We will not sell your Personal Information.  Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests and meet our legitimate business and legal objectives.  When we disclose Personal Information to external entities to perform support services for us, we establish by contract that they may access your Personal Information only for the purposes of performing those support services.  We may also use what we know about you to potentially offer you other products and services in the future.  We may combine your online information with information collected from offline or online sources, or information we already have.  We may also use and disclose certain Personal Information to our affiliated companies and others for any purpose allowed by law.

Business Activities. 

We generally process and may disclose your Personal Information to others to:

  • Process purchases at your request;
  • Verify your identity or other fraud prevention measures and reporting obligations;
  • Respond to your questions, complaints, or reviews of our services;
  • Send you communications about a program or service, ads and promotions, electronic newsletters, or other notices you requested or offers tailored to you;
  • Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
  • Help us run our business; or
  • For any other everyday business purposes, such as product development and Site administration.

What are the legal grounds for the collection, use, sharing and other processing of Personal Information?

Certain jurisdictions require the identification of the legal grounds for the collection, use, sharing, and other processing of Personal Information.  We rely on the following legal grounds for the collection, use, sharing, and processing of Personal Information as described in this Privacy Notice:

  • Necessary to provide information or otherwise carry out the performance of a contract with you as an individual;
  • Compliance with legal obligations and/or defense against legal claims, including those in the areas of agriculture, energy, labor, social security, data protection, tax, and corporate compliance laws.
  • Protection of the vital interests of any individual;
  • Performance of a task carried out in the public interest or in the exercise of official authority vested in us; and
  • Consent, as permitted by applicable law

Authorized Service Providers.  We use other companies and individuals to perform certain functions on our behalf.  Those functions include payment card processing, analyzing or hosting data on cloud-based servers, website support and design, and other companies that help us improve our products and services.  We may disclose certain Personal Information to these companies and other individuals performing services in the United States or other locations where we conduct business. 

Sale of the Businesses.  If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction.  We will use reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information consistent with the terms of this Privacy Notice. 

Other Disclosures.  We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or enforce our Site’s terms and conditions or any applicable rules, or to protect the rights of others.  We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena.  We may also aggregate information that we gather about you (e.g., online sales, traffic patterns) and provide these statistics to others in aggregate form. 

Any access to your Personal Information is restricted to those individuals who have a need to receive or access this data in order to fulfill their job responsibilities.  We may also disclose your Personal Information as required or permitted by applicable law to governmental authorities, courts, external advisors, and similar third parties.

What Are Your Rights Concerning Your Personal Information

Certain jurisdictions maintain local data protection regulations that confer certain data protection rights on individuals.  We will address those rights as required by applicable laws.  If you wish to exercise any of these rights, please contact us as specified in the “How to contact us” section below.  If you have declared your consent regarding certain types of processing activities, you can withdraw this consent at any time with future effect.  This withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.  To the extent you’ve provided your consent and wish to withdraw it, you can contact us as stated below.

You also have the right to lodge a complaint with a competent data protection supervisory authority.  To exercise your rights, please contact us as set out below.

Cookies and Similar Tracking Technologies

Information Collected Through Technology. 

Information is also obtained in other ways through technology we deploy.  Some of this information may be linked to you personally.  In accordance with applicable law, we use and allow third parties to use essential and non-essential cookies, online tracking tools, web beacons, and similar technologies (collectively, “cookies”) on our Site.  We process this information to help our Site function correctly, and better understand the needs of our customers.

Cookies on our Site generally fall into the following categories:

  • Strictly Necessary Cookies: These are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas. These cookies are session cookies which are erased when you close your browser.
  • Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Site and see how those users navigate through our Site.  This helps to improve how our Site works, for example, by ensuring that users can find what they are looking for easily. These cookies are session cookies which are erased when you close your browser.
  • Functional Cookies: These improve the functional performance of our Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it.  These cookies are session cookies which are erased when you close your browser.

Use of cookies. 

We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications.  To understand how our advertising campaigns are performing, we may collect certain information via cookies on our Site through our advertising service providers.  The information we collect includes IP addresses, the number of page visits, pages viewed via our Site, search engine referrals, browsing activities over time and across other websites following your visit to our Site or applications, and responses to advertisements and promotions on the websites and applications where we advertise. 

We also use certain information to identify new visitors to our Site, recognize returning visitors, advertise on other websites and mobile applications not affiliated with us, analyze the effectiveness of our advertisements, better understand our audience, customers, or other Site visitors, and determine whether you might be interested in new products or services.

Controlling Our Tracking Tools. 

Your browser may give you the ability to control cookies.  How you do so, however, depends on your browser and the type of cookie.  Certain browsers or browser plugins can be set to reject all browser cookies.  If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Site. (e.g., we will not be able to provide you with searches that you have asked us to save). You can change your cookie settings at any time.

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked.  These browser features are still not uniform, so we are not currently set up to respond to those signals.

Data protection laws in your jurisdiction may treat cookie use differently or provide you an additional right to opt-out of such cookie use.  If you are a visitor to this Site, and have any concerns about our collection, or use of cookie information, contact us directly at privacy@companyname.com.

Security

The security and confidentiality of your Personal Information matters to us.  That’s why we have technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure.  Despite our reasonable efforts, no security measure is ever perfect or impenetrable.

Data Retention

Depending on the product or service, we will retain your Personal Information only for the period necessary to fulfill the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by a law that applies to us.

How do we protect international transfers of Personal Information? 

Company Name is based in the United States of America.  If you are located in a jurisdiction that does not consider the United States to provide an adequate level of protection as your home country, cross-border transfer of your information is necessary for the conclusion or performance of a transaction that you requested, and for the establishment, exercise, and defense of legal claims.  To the extent permitted by local law, your use of this Site or provision of any Personal Information constitutes ̶ where legally permitted ̶ your consent to the cross-border transfer of Personal Information and other activities identified in this Privacy Notice.

Minors

This Site is not intended or directed to individuals under the age of 16, and we do not knowingly collect any Personal Information from minors, or knowingly track the use of our Site by children.  If you believe we have impermissibly collected Personal Information from someone under the age of 16, please contact us directly at privacy@companyname.com

How can you contact us to update your Personal Information, file a complaint, ask questions, or send us comments about this Privacy Notice?

If you have any questions or concerns about this Privacy Notice or wish to correct or update your Personal Information, or unsubscribe from any updates you have requested, write to customer service using the following contact details.  We will investigate your complaint, and use reasonable efforts to respond to you as soon as possible.

COMPANY NAME

Attn: Privacy Office

Contact Information

privacy@companyname.com

Changes or Other Updates to this Privacy Notice

We may amend this Privacy Notice at any time.  If we make any material change in how we collect, use, disclose, or otherwise process Personal Information, we will prominently post an updated Privacy Notice on our Site.  Any changes to this Privacy Notice will be effective immediately upon posting of the updated Privacy Notice or as otherwise required by applicable law.  Where required to do so by law, we will seek your prior consent to any material changes we make to this Privacy Notice.

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