CCPA

CALIFORNIA CONSUMER PRIVACY ACT NOTICE

Franchise Focused Marketing, LLC.

I. INFORMATION COLLECTED ABOUT CONSUMERS

Personal Information We Collect

Franchise Focused Marketing, LLC. (“FFM,” “we,” “us” or “our”) collects, stores, and uses certain information from users of franchisefocusedmarketing.com, shop.franchisefocusedmarketing.com, ffmclicks.com or any of our branded CLICKS landing page sites (collectively, “Website”).  Such information may include “personal information” which means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.  Personal Information we collect includes identifiers such as your name, telephone number, and email address. We may also collect non-personally identifiable information, such as the date and time of your visit to the Website, pages accessed, the type of browser used, and other “traffic data”. We may link traffic data to the Personal Information you submit while on the Website, when you are logged into the Website, or in connection with a service you have requested.

How We Collect Personal Information

We collect information you provide to us when you access or use the Website, register with us or otherwise interact with us online or offline.

From time to time we may also use the “cookies” feature of major browser applications. This feature allows us to store a small piece of data on your computer about your visit to the Website. Cookies are small files of information that save and retrieve information about your visit to the Website. We may use cookies to make your visit to the Website easier. Most browsers are initially set-up to accept cookies. If you do not wish information to be gathered on a cookie, it may be possible to disable the acceptance of cookies by changing the settings on your web browser. However, disabling cookies may impair your access to and ability to utilize certain features on the Website. Your experience at the Website may be diminished and some features may not work as they were intended if you disable cookies. If you are not sure whether your browser has the capability to opt out of receiving cookies, you should check with the software manufacturer or your internet service provider.

We may collect information using third-party analytics tools such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the User experience and the convenience of the Website.  For more information or to opt-out, see “Google Privacy & Terms”.

FFM is not responsible for the privacy practices or the content of other websites that may be linked to the Website. You should carefully review the privacy policies of those websites to determine how they treat your Personal Information.

II. PURPOSE AND USE OF COLLECTING PERSONAL INFORMATION

Our Use of Personal Information

We may use Personal Information for business purposes, including to facilitate processing of transactions, to send you information about FFM, or to otherwise contact you. We may also use your Personal Information to inform you of any changes to the Website, to verify your identity or check your qualifications. We may also use your Personal Information to operate, understand, optimize, develop, or improve the Website, including bug detection and error reporting, and to ensure security, fraud, and legal compliance.

Personal Information may be shared with third-party service providers utilized by FFM to perform services for the Website, including website hosting, maintenance of the Website, providing key functions of the Website, information processing, completing audits, responding to inquiries and sending email. Service providers and affiliates may be provided with your Personal Information to perform core services related to the operation of the Website (such as hosting or data storage and security) or perform services on your behalf that you initiate through the Website. The service providers utilized by FFM and its affiliates are obligated to protect your Personal Information.

Notwithstanding the above, we may disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to:

• conform with the law or comply with legal process such as a search warrant, subpoena, or court order;
• enforce or investigate potential violations of our policies, procedures, disclaimers, and conditions of use for the Website;
• protect and defend our rights or property;
• investigate and defend ourselves against any third-party claims or allegations;
• protect against misuse or unauthorized use of the Website; or
• during emergencies, such as when we believe someone’s physical safety is at risk or to protect the safety of the public or users of the Website.

We reserve the right to send communications to you which alert you to important information regarding the Website, including, but not limited to, communications regarding administrative, policy, or legal matters which may affect your use of the Website.

How We Share Personal Information with Third Parties

FFM does not sell your Personal Information.  We do share your Personal Information, such as your name, address and email address with our clients with whom you’ve chosen to interact to purchase a service or product, receive free or discounted offers or for any other reason.

In the event that all or a portion of our business is acquired by or merged with a third-party, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you, including Personal Information, to the third-party as part of such merger, acquisition, sale, or other change of control.

III. CONSUMERS’ RIGHTS CONCERNING THE COLLECTION, DISCLOSURE OR SALE OF THEIR PERSONAL INFORMATION UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

The following information on the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.) (“CCPA”), applies to California residents who have certain rights regarding Personal Information collected by FFM. It does not cover Personal Information not subject to the CCPA rights identified below, such as Personal Information we collect from our employees or job applicants. The CCPA does not extend all the rights identified below to Personal Information collected from employees, owners, directors, officers, or contractors of businesses in the course of our provision or receipt of business-related services.

Under the CCPA, California residents have the following rights:

• Right to Know. Subject to certain exceptions, you have the right to know what specific pieces of Personal Information FFM has collected about you in the 12 months preceding your request, along with the categories of Personal Information we have collected, the categories of sources of that Personal Information, our business or commercial purpose for collecting your Personal Information, and the categories of third parties with whom we share your Personal Information. You may make this request no more than twice per 12-month period.
  
  
• Categories of Personal Information We Collect. We collect the following categories of Personal Information, as described in more detail in this Privacy Policy: identifiers and commercial information.
  
  
• Categories of Personal Information We Sell.  FFM does not and will not sell your Personal Information.
  
  
• Categories of Personal Information We Disclose. We provide the following categories of Personal Information to third parties for business purposes, as described in more detail in this notice: identifiers and commercial information.
  
  
• Right to Delete. Subject to certain exceptions, you have the right to request deletion of the Personal Information FFM has collected from you.  Pursuant to the CCPA, the exceptions include:
  • Completing the transaction for which the Personal Information was collected;
  • Detecting security incidents or protecting against and prosecuting malicious, deceptive, fraudulent, or illegal activity;
  • Complying with our legal or compliance obligations; and
  • Other reasons that are in connection with our lawful internal uses that are consistent with your relationship with us and the context in which the Personal Information was collected.

• Non-Discrimination. FFM will not discriminate against you if you exercise your rights under CCPA. However, if your request requires us to delete, restrict, or not share information, please be advised that this may inhibit some functionality of the Website. Any subsequent interaction with the Website after deletion will require new requests for action on your data.

Exercising Your Rights under CCPA

You can exercise any of your rights under the CCPA, or obtain more information for you questions or concerns, by filling out the form provided for this purpose below, or by calling our toll-free telephone number at 855-217-9377.

You are permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide written permission for the authorized agent to make such requests or a power of attorney. We may also follow up with you to verify your identity according to the following methods before processing the authorized agent’s request.

We will take reasonable steps in light of the nature of the Personal Information requested to verify your identity before responding to a request.  To complete the verification process, we will ask you to both: (1) provide at least two pieces of evidence that match the Personal Information that we have on file for you, such as your email address or billing information such as the last 4 digits of the credit card used or the billing address for a transaction; and (2) provide a statement that you “declare under penalty of perjury” that you are the person about whom the request has been made. 

In the unlikely event that we are not able to verify your identity from the Personal Information that we already have on file for you, we may request additional information from you.  Such additional information would only be used for purposes of verifying your identity and for security or fraud-prevention purposes, and we would delete such additional information as soon as practical after processing your request.

LAST UPDATED: June 5, 2020.