FRANCHISE BRANDS PRIVACY POLICY
Franchise Brands, LLC

Your Privacy is very important to us. This privacy policy discloses how Franchise Brands, LLC collects, protects, uses and shares personal information gathered about you, in conformance with the applicable law. All personal information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal Information is not accessible to anyone outside the specific function for which it is collected. Franchise Brands respects the privacy of our customers, employees and job applicants, and other visitors to our websites who may choose to provide personal information. We recognize the needs for appropriate protections and management of personal information that you provide to us. This Privacy Policy will assist you to understand what types of information we may collect, how that information may be used, and with whom the information may be shared.

In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies with respect to personal information.

What type of information do we collect?
Personal Information is defined as any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Personal Information shall include but is not limited to: identifying information such as name, home address, home telephone number, email address, Social Security number, financial information and employment related information such as may be on resumes, applications, background verification information, and employment references.

Franchise Brands, LLC takes measures to maintain the confidentiality of your Social Security Number, to protect your Social Security Number from unlawful disclosure, and to limit access to your Social Security Number. Franchise Brands, LLC will not make your Social Security Number available to the general public, print your Social Security Number on any card, require you to provide your Social Security Number to access any products or services, transmit your Social Security Number over the Internet unless the connection is secure or your Social Security Number has been encrypted, or require the transmittal of your Social Security Number to access our Website without requiring additional authentication.

We will never collect sensitive Personal Information except to comply with Affirmative Action data requirements. Sensitive Personal Information can include but is not limited to: information pertaining to: gender, disabilities, and veteran status.

Cookies – Internet Users
In addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

Children and Data Collection
Franchise Brands adheres to the federal privacy protection standards as stated in the Children's Online Privacy Protection Act (“COPPA”). We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, e-mail address, and phone number) over the Internet. If a child has provided us with personally-identifiable information without the consent of a parent or guardian, the parent or guardian of that child should contact the Privacy Officer immediately at privacyofficer@franchisebrandsllc.com. We will use reasonable efforts to promptly delete the child's information from our servers.

A Special Note about Children who reside in the State of Maine, USA
Franchise Brands adheres with the Maine state law titled "An Act To Prevent Predatory Marketing Practices against Minors". The law applies to the collection and use of personal information for marketing purposes of children who are under the age of 18. Franchise Brands website www.franchisebrandsllc.com  is not intended to solicit information of any kind from children under 18 years of age. It is possible that due to fraud or deception by others, we may unknowingly receive information pertaining to children under 18 years of age. If this is the case, the parent or guardian of the minor must notify the Privacy Officer immediately at privacyofficer@franchisebrandsllc.com. Once we have verified the accuracy of the information received by the parent or guardian regarding the child under 18 years of age, we will promptly delete the child’s information from our servers.

Our Use of Your Personal Information
We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately advise of the use of your Personal Information.

Collection and Use of Employee Personal Information
Franchise Brands also collects personal information of its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to, job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to Franchise Brands facilities and computer networks, employee profiles, internal intranet employee directories, Human Resource recordkeeping, and other employment related purposes.

It is the policy of Franchise Brands to keep all past and present employee information private from disclosure to third parties. There are certain business related exceptions and they are:

1. County, state or federal agencies;
2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below);
3. Third parties of which Franchise Brands has contractual agreements to assist in administration of company sponsored benefits.

Verifications of Employment
Prospective employers, financial institutions, and residential property managers routinely contact Franchise Brands requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the Human Resources Department.

For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed in the employee's personnel record. 

Medical Information
Franchise Brands is compliant with federal HIPAA regulations and only utilizes information related to the company sponsored healthcare plan on a "need to know" basis for administration of the healthcare plan.

Collection and Use of Personal Information
By filling out the on-line application, you consent to the collection, use, and disclosure of your Personal Information in accordance with the following terms and conditions. We collect and use Personal Information in order to assist Franchise Brands in selecting potential franchise concepts. Personal Information collected from applicants includes but is not limited to: name, address, telephone number, and email address.  This Personal Information may be shared between Franchise Brands and its affiliates, and other third parties, pursuant to service contracts between them, to better service applicants.

An applicant’s information may be shared with the Legal Department, Accounting Department, and Advisory Board of a third party providing consulting services as part of our due diligence team.  If an applicant does not wish this information disclosed, they must notify the Privacy Officer in writing as described in the section titled “Contact Information” below.

Franchise Brands will not collect applicants Personal Information, unless the applicant contacts Franchise Brands directly.  In the future, we may use this information to contact you regarding products or promotions, as well as other products and services, which may be of interest to you.   If you do provide us with Personal Information we may use the information to contact you, via e-mail, regular mail, telephone or other means, to provide you with information you requested about specific products or services, provide additional future information about products or services that may be of interest to you, and to learn about and develop products and services. At any time you may “opt out” of future contacts by un-subscribing from our database or contacting the Privacy Officer.

Sharing of Personal Information
We may share personal information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, Franchise Brands will not share your Personal Information with a third party, unless you request or otherwise consent to such disclosure, or disclosure is required or authorized by law. Franchise Brands reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. Personal information may be provided to a courier or freight forwarder in order to fulfill a business transaction, which may have been requested from us.

As described above, Franchise Brands, its affiliates, and third party service providers are prohibited from using your Personal Information for any purpose other than described in this Privacy Policy.

Disclosure, Storage, Retention and Accuracy of Personal Information
Except as described in this Privacy Policy, Franchise Brands will not disclose Personal Information to a third party, unless such disclosure is requested, there is consent to such disclosure, or disclosure is required by law.  Franchise Brands insures that Personal Information is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

Franchise Brands will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Franchise Brands may store your Personal Information in its databases located in the United States and/or other countries outside of the United States. Additionally, some of our service providers may reside in the United States or other countries outside of the United States and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, the United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by Franchise Brands.

Contact Information
You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another individual to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: 1-800-797-2308; by Facsimile at: (203) 783-7952; by email at: privacyofficer@franchisebrandsllc.com, or by mail at Franchise Brands, 300 Bic Drive, Milford, CT , 06461, USA. We will address your concern and attempt to resolve any problem.

Links to Non-Franchise Brands Web Sites and Third Parties
Please note that Franchise Brands web sites may contain links to other web sites for your convenience and information. Franchise Brands does not control those sites or their privacy practices, which may differ from ours. Franchise Brand’s privacy policy cannot and does not apply to external Web areas. We do not endorse or make any representations about third party web sites. The personal data you choose to give to unrelated third parties is not covered by the Franchise Brands privacy policy. We encourage you to review the privacy policy of any company before submitting your personal information. Some third party companies may choose to share there personal data with Franchise Brands; that sharing is governed by that third party company’s privacy policy.

Safe Harbor Compliance
Franchise Brands is in compliance with the U.S. Department of Commerce Safe Harbor requirements regarding the transfer of personal information from European Union member countries to the United States.  Franchise Brands has been Self-Certified in accordance with the EU Directive on Personal Data Protection. The principles of Safe Harbor compliance are: 

• Notice - Individuals must be informed that their data is being collected and about how it will be used;
• Choice - Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
• Onward Transfer - Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
• Security - Reasonable efforts must be made to prevent loss of collected information;
• Data Integrity - Data must be relevant and reliable for the purpose for which it was collected;
• Access - Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
• Enforcement - There must be effective means of enforcing these rules.  

Further information regarding the Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.

In addition, the U.S. Department of Commerce maintains a list of all compliant organizations, which can be accessed at http://web.ita.doc.gov/safeharbor/shlist.nsf/webPages/safe+harbor+list.

Members of the European Union
If you are a resident of a Member State of the European Union and have any concerns or complaints, please first address these issues to the Privacy Officer. Franchise Brands is located in the United States, as are the servers that make their site available. All matters relating to privacy issues and this website are governed by the laws of the United States and the State of Connecticut. If the Privacy Officer does not satisfactorily address a complaint within thirty (30) days, any dispute, controversy or claim shall be settled by an arbitration administered by an arbitration agency, such as the American Arbitration Association (“AAA”). All arbitrations will be conducted in English. Judgment rendered by the arbitrator may be entered in any court having jurisdiction. The costs of the arbitration will be borne equally by the parties. Connecticut, U.S.A. shall be the site of all hearings, and such hearings shall be before a single arbitrator. You may also submit complaints to the Federal Trade Commission at http://www.ftc.gov/ftc/complaint.htm or via phone at (202) 382-4357.

Changes to our Privacy Policy
This Privacy Policy may be amended at any time, without prior notification.

Franchise Brands:  Revised 09-02-09