Privacy Policy

Opening
Effective Date: April 25, 2022

Focus Brands LLC (“Focus Brands,” “we,” “our,” “us”) values your privacy. In this Privacy Policy, we describe how we collect, use, and otherwise process the personal information we obtain about users of our website and the services we make available through our website (our “Services”).

This Privacy Policy does not apply to any websites or mobile apps that are created, run, or controlled by our brands, any independently owned or operated franchisees of our brands, or any other third party.

Focus Brands uses our Services to collect personal information on behalf of and for use by our brands. Information about how our individual brands use and protect your personal information and how to exercise your privacy rights can be found in each brand’s privacy policy. If you want to review the privacy policies applicable to our brands, please click on the appropriate link below:

In this Privacy Policy, “personal information” means any information that Focus Brands processes that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person or device.

Privacy Policy Table of Contents

Personal Information We Collect About You

We may collect personal information directly from users of our Services. You can use our Services without registering or directly submitting your personal information to us, but we may automatically collect certain information about your use of our Services through cookies and other tracking technologies. If you use our Services, but decide not to provide this personal information, certain programs, options, and functionalities of our Services may not be available to you.

Information We Collect Directly From You. To access our Services and use certain benefits (for example, to request a franchise kit from us), you must give us your name and other personal information. We also may collect personal information that you enter through our Services or provide to us in other ways, such as through email. The type of personal information that we collect from you will depend on your interaction with us and how you use our Services, but may include personal details, such as full name, mailing address, email address, phone number, and other contact information. If you submit someone else’s personal information to us, you represent that you have been authorized to provide this information.

Information We Collect Automatically. We, and the vendors we work with, may also collect other information about your use of our Services using automated tools. For example, cookies and other passive information collection technologies enable us to compile aggregate statistics concerning use of our Services, analyze trends, enhance the security of our Services, deliver content, and otherwise administer and improve our Services. This information may include your browser type, language preference, operating system, device identifier, device type, access time, Internet Protocol (IP) address, the URLs of websites you visited before and after visiting our websites, the web search that landed you on our websites, the length of your visits to our websites, and the links you click and pages you visit within our websites. Our websites use both session ID cookies and tracking cookies. Session ID cookies make it easier for you to navigate the websites and expire when you close your browser. Tracking cookies help us understand how you use a website and enhance your user experience. You can set your browser not to accept cookies, to remove cookies, or to notify you when you are sent a cookie, giving you the opportunity to decide whether or not to accept it. However, please note that if you disable the use of cookies on your computer, some functionality of our website will not work.

We may use certain third-party web analytics services to help us understand and analyze how visitors use our Services and to serve advertisements on our behalf across the Internet. We have implemented Google Analytics Advertising features such as dynamic remarketing, interest-based advertising, audience targeting, behavioral reporting, demographics and interests reporting, user segment analysis, device reporting, display advertising, and video ads reporting. We may use cookies and other identifiers to deliver advertisements, create a profile of you, measure your interests, personalize content, and detect your demographics, location, or device. For more information on how Google Analytics uses data, visit www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit www.google.com/settings/ads/ and tools.google.com/dlpage/gaoptout/.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our websites are not designed to respond to “Do Not Track” signals received from browsers. However, you can find information on how to opt out of their participating online advertising networks at Network Advertising Initiative and Digital Advertising Alliance. Please note that opting out does not prevent all advertising. Also, if you delete your cookies or change devices, your opt-outs may no longer be effective.

Information We Collect From Others. We may collect personal information about customers, prospective franchisees, and current franchisees from third parties, including name, contact details, and other information. When submitting information to a third party, you are subject to that third party’s terms of use and privacy policies. Focus Brands may combine information about you that we already have with information we obtain from third parties.

How We Use Your Information

We may use your personal information to:

  • communicate with you, including to respond to your questions and requests, provide you with documentation or communications you have requested, send you notices about our Services, offer customer support, or contact you for information or after-sales support;
  • market and advertise our products and brands, including to send you news, updates, special offers and promotions, and targeted advertising;
  • personalize our content, including to make recommendations to you about our Services, to tailor the information we send or show you, and to offer location-based customizations and personalization based on your purchase history or past interactions with our Services;
  • monitor and analyze trends, usage, and the activities of users of our Services to better understand how our users access and use our Services in order to improve them, respond to user preferences, and for other research purposes;
  • improve our Services and notify you about important updates;
  • perform business analyses or for other business purposes, such as evaluating transactions involving our Services;
  • facilitate, manage, personalize, and improve our partnership and franchisee relationships;
  • identify, prevent, investigate, and take other actions with respect to suspected or actual fraud or illegal activity or other activity that violates our policies;
  • ensure the security and integrity of our personal information processing;
  • protect our rights, property, or safety and that of our brands and our confidential and proprietary information;
  • comply with applicable laws, rules, regulations, and legal processes as well as our company policies, including to respond to claims asserted against us and to enforce or administer terms and agreements; and
  • achieve other purposes, with your consent (as required).

How We Share Your Information

We may share your personal information within our company, with our brands, business partners, franchisees, and vendors. We also may share your personal information to:

  • provide you with products or services;
  • better respond to your inquiries;
  • advertise or market our products and services;
  • perform marketing research and for sales, support, and service-related purposes;
  • protect rights, property, life, health, security, and safety;
  • respond to legal process, including to disclose personal information to a court, legal authority, opposing party in litigation, our legal counsel, or other advisors in connection with a judicial proceeding, court order, subpoena, or other legal process;
  • negotiate or complete any proposed or actual merger, purchase, sale, or any other type of acquisition or other transaction, including a transfer of all or a portion of our business to another organization;
  • disclose personal information with your consent or at your direction; and
  • achieve any other purpose consistent with our statements in this Privacy Policy or otherwise allowed by applicable law.

We may disclose your personal information to comply with applicable law, such as in response to requests from law enforcement agencies, regulators, other public authorities, courts, and third-party litigants in connection with legal proceedings or investigations.

Links to Other Websites

Our Services may include links to other websites that we do not own or operate. This Privacy Policy does not apply to those websites, which may have their own privacy policies that you should review to understand how they may collect, use, or disclose your personal information. We are not responsible for the content or privacy practices of any linked websites that are not under our control.

Security of Your Personal Information

We maintain appropriate safeguards designed to protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, no data security measures can guarantee 100% security.

Our Retention of Your Personal Information

We retain your personal information for no longer than is necessary to achieve the purposes for which the personal information was collected, or as may otherwise be permitted or required under applicable law. To determine the appropriate retention period, we will consider the scope and sensitivity of the personal information; the potential risk of harm from unauthorized access to, use, or disclosure of the data; the purposes for which we process the data; whether we can achieve our purposes through other means; our business needs; and applicable legal requirements. Unless otherwise required by law, at the end of the retention period, we will either anonymize or securely destroy your personal information.

 

Updating Your Information

If you wish to correct or change your personal information, you may do so by logging in to your account with the appropriate brand, following the instructions in the relevant brand’s privacy policy (linked at the beginning of this Privacy Policy), or by contacting the relevant brand through the Contact Us page on each brand’s website. PRIVACY OF CHILDREN

Our Services are not intended for children, and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will delete it in accordance with applicable law.

Notice to Franchisees

Focus Brands collects and otherwise processes personal information about franchisees as a service to our individual brands, who each remain the controller of information submitted throughout the franchisee process. If you wish to exercise your privacy rights with regard to personal information you submitted through the franchisee process, you should submit your request to the brand(s) that you are a current, former, or prospective franchisee of. The privacy policies for each brand, including their contact information and information about submitting privacy-related requests, are linked at the beginning of this Privacy Policy.

If you submit your personal information to request more information from us about our franchise opportunities, we may use that information to contact you to discuss our franchise opportunities. We may ask that you complete our franchise application, which requests the following additional types of personal information from you:

  • Franchise ownership details and history
  • Financial information, including details of current assets and liabilities, annual income, investments, mortgages, insurance, and any history of bankruptcy
  • Criminal history (if any)

We may share the information provided in our franchise application with our brands and vendors as needed to process your franchise application, including to run background checks and to determine creditworthiness.

If you provide personal information related to other people, such as your spouse, investment partners, or personal references, as part of the franchise application process, you guarantee that you do so with the knowledge and permission of those people. We may use any information you provide to contact those people and share it, as necessary, with our brands and vendors during the franchise application process.

International Users

Focus Brands is based in the United States. If you are using our Services outside the United States, please be aware that personal information we obtain about you may be transferred to and processed in the United States or other jurisdictions outside your own. Your personal information may be accessible by public authorities where it is processed. By using our Services and providing your personal information, you acknowledge that your personal information may be transferred to and processed in jurisdictions other than your own. Please be aware that the data protection laws and regulations that may apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence.

Changes to this Policy

We may update or modify this Privacy Policy from time to time at our discretion. We will indicate changes to this Privacy Policy by updating the “Effective Date” at the beginning of the Privacy Policy. Please review this Privacy Policy periodically and especially before you provide any personal information to us. Your continued use of our Services after any update will constitute your acceptance of our changes.

Contact Us

If you have questions about this Privacy Policy or Focus Brands privacy practices, please contact us at privacy@focusbrands.com or by mail at 5620 Glenridge Drive NE, Atlanta, GA 30342.

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