Effective Date: January 1, 2020

Last Updated: January 1, 2023

Contents

Categories of Personal Information We Collect

The type of information that we collect depends on your interaction and relationship with us. We collect, and in the preceding 12 months have collected, the below categories and types of personal information with your consent or as otherwise required or permitted by law.

  • Contact Information. We collect full name, email address, current and prior address, telephone number, and business contact information.
  • Identifiers. We collect social security number, driver’s license number, passport number, state identification card number, I-9 documentation, internet protocol address, social media handles or IDs (such as your Facebook ID), account usernames and passwords, and signature.
  • Personal Characteristics or Traits. We collect date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status and disability information.
  • Financial Information. We collect tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, and billing address. If you apply for franchise or ownership opportunities or apply for financing, we may also collect information concerning your credit history, income level, personal wealth, and financial condition.
  • Commercial Information. We collect records of products or services purchased, obtained, or considered and purchasing histories.
  • Internet or Electronic Usage Data. We collect data related to network and website interaction history, IP address, website cookie information, interaction with advertisements and browsing time.
  • Audio/Visual Data. We collect audio, electronic, photographic, visual or similar data including videos, photographs, and audio recordings.
  • Geolocation Data. We collect geolocation data including the general region or area from which you access our Sites.
  • Professional or Employment Information. If you apply for franchise or ownership opportunities, for financing, or to work for us, we will collect certain professional or employment information. We collect job application details, previous work history, current employment information, and professional memberships and certifications.
  • Education Information. If you apply to work for us as an employee or independent contractor, we will collect education history, degrees, transcripts, qualifications and certifications.
  • Sensitive Information. Where permitted by law, we may collect social security number, driver’s license number, passport number, state identification card number, racial or ethnic origin, religious or philosophical beliefs, or union membership, health information, and sexual orientation.
  • Inferences: We use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characters, behavior, and attitude.

Sources of Personal Information

We collect, and in the preceding 12 months have collected, personal information in the following ways:

  • Directly From You. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, audio/visual data, professional or employment information, education information, and sensitive information that you provide directly to us.
  • When You Visit Our Locations. When you visit our offices or facilities, we also collect contact information and audio/visual data.
  • Automatically. When you access our Sites, we collect identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies.
  • From Third Parties: We may collect contact information, identifiers, personal characteristics or traits, commercial information, audio/visual data, professional or employment information, education information, and inferences from third-parties including our vendors, clients, recruiters, suppliers, service providers.
  • From Our Employees or Job Applicants. We collect contact information, identifiers, personal characteristics or traits, financial information, commercial information, audio/visual data, professional or employment information, education information, and sensitive information from our current or former job applicants, contractors and employees.
  • Social Media Platforms. Depending on the information you choose to share and your privacy settings, we may collect contact information, identifiers, audio/visual data, personal characteristics or traits, geolocation data, commercial information, professional or employment information, internet or electronic usage data, and inferences. Based on the way you have set your privacy settings on your social media accounts, most social media platforms, like Facebook and Instagram, analyze data about how you interact with our Sites and combine it with information on other users to provide us information about you. In addition, we may receive information about you if other users interact with us on social media and information about you is visible to us, for example the fact that you are “friends” or other public-facing profile information.

Purposes for Collecting Personal Information

We use personal information for the following business and commercial purposes:

  • Providing our Services. We use contact information, identifiers, financial information, commercial information, audio/visual data, professional or employment information to allow customers to contract for and purchase our Services, provide the products and Services we have contracted for, process payments, and provide updates and reports requested by customers.
  • Transactional Purposes. We use contact information, identifiers, financial information, professional or employment information, and commercial information to:
    • (i) communicate with you;
    • (ii) provide you with customer assistance;
    • (iii) administer contracts with our vendors, customers, and service providers; and
    • (iv) provide supporting business activities such as billing and collections, procurement, and tax related activities;
  • Recruiting and Hiring. We use contact information, identifiers, audio/visual data, professional or employment information, education information, financial information, sensitive personal information, and inferences make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries and schedule interviews, and to reimburse you for any agreed expenses incurred in the application process.
  • Background and Credit Checks. We may require our applicants to complete a background check to verify your identity, check for criminal history, check your credit worthiness, and confirm the validity of your application. We use identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive information to enable the completion of the background check.
  • Financing. We use contact information, identifiers, financial information, commercial information, professional or employment information, and inferences to evaluate your application to obtain credit or financing from us.
  • Franchisee Assessment. We use your contact information, financial information, identifiers, personal characteristics or traits, education information, and inferences in order to assess your suitability to become a franchisee or owner. We may combine the information you provide to us with information we obtain from third parties, such as credit reporting agencies and public records databases. We use this information to conduct due diligence on potential franchisees and owners.
  • Business Operations. We use contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, education information, sensitive information, and inferences for our day-to-day business operations including maintaining records, manage our facilities, planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative and disciplinary purposes and other ethics and compliance reporting tools, and to support our business operations.
  • Analytics. We use identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends and statistics.
  • Marketing and Promotional Purposes. We use contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or consultants, engage in client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
  • Maintenance and Improvement of our Sites and Systems. We use contact information, identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems. Maintenance of our systems includes activities such as applying security controls for company systems, providing new system implementations, applying change management processes, and providing IT Service Desk / Help Desk Support.
  • Develop and Improve Our Services. We use contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing service offerings.
  • Security and Fraud Prevention. We contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences to:
    • (i) protect us, our employees, and our Sites, premises, assets, systems, products, services and intellectual property, including from fraud, theft, and misconduct;
    • (ii) enforce our policies and terms;
    • (iii) conduct vendor due diligence; and
    • (iv) detect and prevent fraud, theft and misconduct including by verifying the identity of those we are conducting business with.
  • Legal: We use contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
  • Other Purposes: We may use contact information, identifiers, personal characteristics or traits, financial information, commercial information, internet or electronic usage data, audio/visual data, geolocation data, professional or employment information, education information, sensitive information, and inferences for other reasons we may describe to you.

How We Disclose Personal Information

We disclose personal information in the following circumstances:

We Combine Information

We combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.

Sensitive Personal Information

Unless specifically requested, we ask that you not send us, and you not disclose to us, through the Services or otherwise, any Sensitive Personal Information (e.g., social security number, taxpayer identification number, passport number, driver’s license number, or other government-issued identification number; credit or debit card details or financial account number, with or without any code or password that would permit access to the account, credit history; or information on race, religion, ethnicity, sex life or practices or sexual orientation, medical or health information, genetic or biometric information, biometric templates, political or philosophical beliefs, political party or trade union membership, background check information, judicial data such as criminal records, or information on other judicial or administrative proceedings).

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in future. We use the following criteria to determine retention periods:

Cookies, Analytics, and Other Tracking Technology

Cookies and Tracking Technology

When you access the website, we (and third-party companies we work with) may collect information and store certain information by either placing small data files on your device or using other technologies such as server logs, cookies, web beacons, clear gifs, tags, e-tags, flash cookies, log files, pixels, mobile advertising IDs (such as Facebook cookies or Google’s Advertising ID), cross-device linking, and similar technologies. The information collected includes information about your activities on our Sites, IP address, browser or operating system type and version, device IDs, and demographic or inferred-interest information, as well as information or communications you have submitted to us through the Sites.

Session Replay

We use session replay technology on our Sites. Session replay technology, also referred to as session playback or user experience (UX) replay, collects information regarding, records, and tracks your interactions with a website or application. It then and transforms those logged user events (such as mouse movements, clicks, page visits, scrolling, tapping, etc.) into a reproduction of what you actually did on the website or application. We use session replays for quality control, customer service, fraud prevention and security, and marketing purposes. Our session replay technology is owned and operated by a third-party who acts as our service provider. The information collected by this technology may be collected by, transferred to, and stored by our third-party service provider.

Do Not Track Signals

Google Analytics

Links to Other Websites

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

This Website is not Intended for Minors

Marketing Communications

Processing in the United States

Please be aware that information we obtain about you will be processed in the United States by or service providers or us. By using the Site or our Services or otherwise providing us with your personal information, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.

California Privacy Rights

If you are a California resident, this section applies to you.

California Consumer Privacy Act ("CCPA")

Contact Us

Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.