Privacy Policy

Last Updated: December 4, 2023

Smalls Sliders Franchising LLC, Smalls Holding, LLC, Smalls Sliders IP, LLC, and their affiliates (collectively, “Smalls Sliders,” “we,” “our,” “us”) value your privacy. In this Privacy Policy, we describe how we collect, use, and process the personal information we obtain about people who use our websites or mobile apps, browse or purchase our products, apply to become franchisees, or who otherwise interact with us online or offline (collectively, our “Services”). Please note, this Privacy Policy does not apply to information collected by our franchisees, or through any other entity sites that link to or are accessible from our Services.

BY DOWNLOADING OR USING ANY OF OUR SERVICES, YOU ARE AGREEING THAT YOU HAVE READ AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND ALL OTHER TERMS AND CONDITIONS CONTAINED HEREIN, AND CONSENT TO OUR COLLECTION, USE AND DISCLOSURE PRACTICES AND OTHER ACTIVITIES DESCRIBED IN THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT DOWNLOAD OR USE ANY OF OUR SERVICES OR PROVIDE US WITH ANY OF YOUR PERSONAL INFORMATION (DEFINED BELOW).

Your Personal Information

The information we collect includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you (“personal information”).

• California residents please click here for our Notice at Collection under the California Consumer Privacy Act.
• Residents of other states with consumer privacy laws (e.g., Colorado, Connecticut, Utah, and Virginia) please click here to learn more about your privacy rights.

We may collect personal information directly from users of our Services.  There may be some parts of our Services you can use without registering or directly submitting your personal information to us.  However, we may still automatically collect certain information about your use of our Services through cookies and other tracking technologies.

Information You Provide

To use some features of our Services (for example, to enter contests and sweepstakes, make a purchase, request information for purchasing a Smalls Sliders franchise, interact with our social media pages, apply for employment), you must register with us or otherwise provide us with your personal information.  We also may collect personal information that you enter through our Services or provide to us in other ways, such as, by way of example, through email or text message.  The types of personal information that we collect from you will depend on your interactions 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;
• purchase transaction information, such as information about the products you buy, billing address, method of payment, and payment details;
• location data; and
• other personal information you choose to provide to us.

Information Collected 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 advertisements, 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. 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 websites will not work. Please see our Cookie Policy for more information.

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.

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

Information About Your Location

Our Services may access and collect your geolocation information to facilitate our provision of Services, such as to provide you with information about stores near you. We also may use information about the location of the device you are using to help us understand how our Services are being used and to deliver more relevant advertising. For most mobile devices and computer systems, you are able to withdraw your permission for us to collect this information through your device or web-browser settings.

Information From Third Parties

We may collect personal information about customers, prospective franchisees, and current franchisees from our affiliated companies, franchisees, service providers, and other third parties. We also may collect information about any comments or reviews you post about us on third-party websites. When submitting information to a third party, you are subject to that third party’s terms of use and privacy policies. We may combine information about you that we already have with information we obtain from third parties. If you submit someone else’s personal information to us, you represent that you have been authorized to provide this information to us.

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;
• process your orders or purchases;
• administer your participation in our programs, events, contests and sweepstakes and other offerings;
• maintain, market and improve any Smalls Sliders loyalty or reward program;
• market and advertise our products, 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;
• assist in the assessment of your application for a Smalls Sliders franchise;
• 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 users 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 (when required).

We use information that does not identify you (including information that has been aggregated or de-identified) for any purpose and without obligation to you except as prohibited by applicable law.

How We Disclose Your Information

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

• provide you with products or services, such as when we use a payment processor or app developer;
• 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.

Any information, including personal information, that you post on any public areas of our Services, such as reviews, comments, and photos, may be available to, and searchable by, all other users. Reviews also may be publicly accessible. 

To the extent the California Consumer Privacy Act is interpreted to include ads targeted to reach people (or people similar to people) whose personal information we have collected or geographically targeted email offers activities as “sales,” we will comply with applicable law as to such activity.  California residents have certain rights set forth in “Supplement To The Privacy Policy For California Residents” below and should review that section.

In addition, we use or disclose information as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, property, life, health, privacy, safety or property of Smalls Sliders, our affiliates, you and others; and (7) to enforce our terms and conditions.

Contests, Sweepstakes And Other Promotions

We offer contests, sweepstakes and other promotions (each, a “Promotion”) jointly sponsored or offered by separate entities that may require submitting information. If you voluntarily choose to enter a Promotion, we share information as set out in the official rules that govern the Promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you agree to the official rules that govern that Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.

Social Features

Certain features of our Services may permit you to interact with social media platforms operated by unaffiliated parties (e.g., Facebook, Instagram), for example, if you “like” or “follow” us or share our content on those platforms (“Social Features”). If you choose to “like” or share content or post information using Social Features, that information may be publicly displayed, and the party operating the social media platform may receive information about you and your use of our Services. Similarly, if you interact with us through Social Features, we may have access to information about you from the social media platform. In addition, we may track when you like us, follow us, or share our content through Facebook, Instagram or other social media platforms.

Please note that if you mention Smalls Sliders, or comment about or in response to us, in your post on a social media platform, that platform may allow us to publish your post on our Services or public social media pages or otherwise use your post about us. You should review the terms, policies, and settings of these platforms to learn more about their data practices and adjust your settings accordingly.

User Generated Content

Any content you post to our Services or public social media pages or otherwise provide to us (“User-Generated Content”) may be visible to and searchable by all users or the general public, and we may not be able to prevent such content from being used in a manner that violates this Privacy Policy, the law, or your personal privacy. For instance, third parties may have republished your User-Generated Content, or it may have been archived by search engines and others that we cannot control. We may revise such User-Generated Content, remove it, or combine your User-Generated Content with other information we have collected about you and use it as described in this Privacy Policy. All User-Generated Content is subject to our Terms and Conditions.

In addition, we may collect information from you when you contact us or when you submit a review, comment, or other content to our Services or on our social media pages. We may choose to disclose the personal testimonials of our customers, including your name, on our Services or with our affiliates, our business partners and franchisees, and our vendors. If you wish to update or delete your testimonial, you can contact us at support@smallssliders.com.

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. However, no data security measures can guarantee 100% security. We encourage you to safeguard your passwords, ID numbers, and other information you use to access our Services.

Retention of Your Personal Information

We retain personal information for as long as necessary or permitted for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply: 

• your personal information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
• your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;
• the personal information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
• we are otherwise required or permitted to keep your personal information by applicable laws or regulations.

Where personal information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

Your Choices

Updating Your Information. If you wish to update the personal information you have provided to us, you may do so by logging in to your account or by contacting us through our Contact Us form. Please note that outdated copies of information that you have updated may remain viewable in cached and archived pages for a period of time, and we may maintain records in our systems of this information as well.

Communication Preferences. You may choose how and whether to receive promotional or marketing communications from us. You may exercise your choices by following instructions available on the Online Services or in communications sent to you. For example, to unsubscribe from our email communications, follow the unsubscribe instructions contained in each of our email messages. Please note that we may continue to send transactional or account-related messages to you.

You may also receive communications from Smalls Sliders franchisees. To opt out of these communications, please refer to the unsubscribe instructions contained in those communications.

Because we plan our communications in advance, it may take up to 10 business days for your “unsubscribe” request to become effective. If you continue to receive our communications after submitting an “unsubscribe” request, please let us know by contacting us using one of the methods listed in the “Contact Us” Section so that we can investigate the situation. 

Privacy of Children

Our Services are not intended for children, and we do not knowingly collect personal information from children. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through our Services. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us through the methods provided in this Privacy Policy. If we become aware that we have collected personal information from a child, we will delete it in accordance with applicable law.

Additional Information For Franchisees

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, including, without limitation:

• franchise ownership details and history;
• financial information, including details of current assets and liabilities, annual income, investments, mortgages, insurance, ACH information, and any history of bankruptcy;
• driver’s license, state ID, social security, and passport numbers;
• criminal history (if any).

We may disclose the information provided in our franchise application with our affiliates 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 disclose it, as necessary, with our affiliated brands and vendors during the franchise application process. 

Supplement To The Privacy Policy For California Residents

As a supplement to the other information provided throughout this Privacy Policy, we provide the following additional information as a notice to consumers in California, as well as California vendors, franchisees, prospective franchisees and other business contacts.

Notice At Collection

How And Why We Collect Personal Information

Smalls Sliders may, and in the previous twelve (12) months, has collected and used the following categories of personal information about California residents: 

CATEGORY OF PERSONAL INFORMATION	CATEGORIES OF SOURCES	PURPOSES FOR COLLECTION
Identifiers, including name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliates Our franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you To support our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees
Personal records,including name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information (including gift cards) This category includes the information described in Cal. Civ. Code § 1798.80(e).	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliates Our franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees
Characteristics of protected classifications, including gender, age, and date of birth	Directly from you Our affiliates Data analytics providers Data brokers	Communicating with you To support our contests, promotions, loyalty programs, coupons, and sweepstakes Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Customer service To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	Directly from you Automatically when you use our Services Advertising networks Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf Our affiliates Our franchisees Data brokers	Processing your purchases of or requests for products or services Communicating with you Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Customer service Marketing and advertising Tailoring our content or otherwise personalizing the Services As part of our application process for prospective franchisees Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Internet or other electronic network activity information, including browsing history, search history, and information regarding interactions with our websites, applications, or advertisements	Directly from you Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Our franchisees Vendors that help us to fulfill and deliver orders, process payments, support our promotions, contests, gift cards, loyalty programs, and sweepstakes, and provide communications, marketing or other services on our behalf	To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Marketing and advertising Tailoring our content or otherwise personalizing the Services Customer service
Geolocation data, including the location of the consumer inferred from IP address or mobile app usage	Automatically when you use our Services Advertising networks Internet service providers Data analytics providers Social networks Vendors that help us to fulfill and deliver orders, and provide communications, marketing or other services on our behalf	Processing your purchases of or requests for products or services Customer service Marketing and advertising To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity Tailoring our content or otherwise personalizing the Services
Audio, electronic, visual, thermal, olfactory, or similar information, including recorded phone calls and in-store video surveillance	Directly from you Automatically when you use our Services. For example, if you interact with us by phone or video Our franchisees	Processing your purchases of or requests for products or services Customer service To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes To help maintain the safety, security, and integrity of our Services, databases and other technology assets, as well as your account, orders, and deliveries Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity As part of our application process for prospective franchisees
Professional or employment-related information	Directly from you	As part of our application process for prospective franchisees Supporting our contests, promotions, loyalty programs, coupons, and sweepstakes Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
Inferences, including information used to create a profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, aptitudes.	Inferred from other categories of personal information we collect Data analytics providers Our affiliates	To better understand how users access and use the Services, to improve the Services, to respond to user desires and preferences, and for other research and analytical purposes Tailoring our content or otherwise personalizing the Services Marketing and advertising As part of our application process for prospective franchisees Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity

Among the categories of personal information listed above, the following categories of personal information we collect may be considered “sensitive” under some state privacy laws:

CATEGORY OF SENSITIVE PERSONAL INFORMATION	CATEGORIES OF SOURCES	PURPOSES FOR COLLECTION
Personal information that reveals a Social Security, driver’s license, state identification card, or passport number	Directly from our franchisees and prospective franchisees	As part of our application process for prospective franchisees
Personal information that reveals a consumer’s precise geolocation (location within a radius of 1,850 feet)	Through our mobile applications	Helping you find a Smalls Sliders business Improving your customer experience Marketing and advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity

In addition to the purposes described above, we may use and disclose any category of personal information or sensitive personal information we collect to comply with law, cooperate with and respond to law enforcement requests, or as otherwise required by applicable law, court order, or governmental regulations; to maintain appropriate records for internal administrative purposes; to protect our rights and interests and those of our franchisees, to resolve any disputes, to enforce this Policy or any of our other policies, to protect the rights or property of another, or to prevent harm; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our organization or its assets.

Disclosure of Personal Information. The following charts summarize how we disclose personal information. Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for advertising or disclose personal information to our affiliated brands and franchisees may be considered “sales” or “sharing” under some state privacy laws. We do not have actual knowledge that we sell or share the personal information of anyone under 16 years of age. 

The first chart below shows the categories of personal information that we share for purposes of targeted / cross-context behavioral advertising or otherwise “sell” for non-monetary consideration. The second chart describes the categories of personal information we disclose for a business or commercial purpose.

Sales and Sharing of Personal Information

CATEGORY OF PERSONAL INFORMATION	CATEGORIES OF THIRD PARTIES TO WHICH SOLD OR SHARED	PURPOSES FOR SELLING / SHARING
Identifiers	Our affiliates Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content As part of our application process for prospective franchisees
Personal records	Our affiliates Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content As part of our application process for prospective franchisees
Characteristics of protected classifications	Our affiliates Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content
Commercial information	Our affiliates Franchisees Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content
Internet or other electronic network activity information	Our affiliates Advertising partners and social media platforms	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content
Geolocation Data	Our affiliates Advertising partners and social media platform	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, ad targeting, remarketing, and customized advertising content
Professional or employment-related information	Our affiliates Franchisees	As part of our application process for prospective franchisees
Inferences	Our affiliates Franchisees	Analytics, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services for the benefit of Smalls Sliders and its affiliates and franchisees Co-marketing, targeted advertising, remarketing, and customized advertising content

Disclosures for a Business or Commercial Purpose

CATEGORY OF PERSONAL INFORMATION		CATEGORIES OF RECIPIENTS	PURPOSES FOR DISCLOSURE
Personal Information
	Identifiers	Franchisees Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity As part of our application process for prospective franchisees
	Personal records	Franchisees Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity As part of our application process for prospective franchisees
	Characteristics of protected classifications	Franchisees Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
	Commercial information	Franchisees Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity As part of our application process for prospective franchisees
	Internet or other electronic network activity information	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) As part of the support we provide to franchisees Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
	Geolocation data	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
	Audio, electronic, visual, thermal, olfactory, or similar information	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
	Professional or employment-related information	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	As part of our application process for prospective franchisees Performing services on our behalf (e.g., supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, or other services on our behalf) Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity
	Inferences	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Performing services on our behalf (e.g., providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services (except for cross-context behavioral advertising) Auditing, related to ad impressions Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity As part of our application process for prospective franchisees
Sensitive Personal Information
	Personal information that reveals a Social Security, driver’s license, state identification card, or passport number	Our affiliates Service providers that we use to support our business and operations	Services performed on our behalf (e.g., providing communications, cloud hosting, and other support for our franchise relationships) Ensuring security and integrity of personal information Detecting, investigating, or protecting against malicious, deceptive, fraudulent, or illegal activity As part of our application process for prospective franchisees
	Precise geolocation	Our affiliates Service providers that we use to support our business and operations Professional advisors, external auditors, and government bodies	Processing your purchases of or requests for products or services Performing services on our behalf (e.g., fulfilling and delivering orders, processing payments, supporting our promotions, contests, gift cards, loyalty programs, and sweepstakes, and providing communications, technical, analytical, web hosting, cloud hosting and mobile application support, or other services on our behalf) Providing advertising and marketing services (except for cross-context behavioral advertising) Short-term, transient use, including, but not limited to, non-personalized advertising Auditing, related to ad impressions Ensuring security and integrity of personal information Debugging to identify and repair errors that impair existing intended functionality Detecting, investigating, or protecting against malicious, deceptive, fraudulent or illegal activity

Supplement For Residents Of Additional U.S. States With Applicable Privacy Laws

If you are a resident of a state in which a state-level privacy law is enacted (e.g., Colorado, Connecticut, Utah or Virginia), additional rights described in this supplement may apply to you as applicable law comes into effect.

Your Privacy Rights

You may have the following rights, in each case to the extent set out in applicable law:

• The right to confirm whether we process personal information about you and request access to such personal information (including, if applicable, in a portable and readily usable format).  
• The right to correct inaccuracies in certain personal information we may hold about you; and
• The right to delete personal information collected from or about you.

You may request to exercise these rights by:

• Calling us toll-free at _____________________; or
• Emailing support@smallssliders.com with a subject line of “Privacy Rights Request” and identifying in the body of the email (1) which state you reside in and (2) which privacy right(s) you would like to exercise.

If your rights request is denied, you may lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and how you may exercise them.

We do not sell personal information, but if you wish to opt out of our targeted advertising as defined under applicable law, please visit our Cookie Preference Center, located in the footer of each website we operate through which we disclose your information for targeted advertising.

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your first name, last name, email address, the amount of your last transaction and the date of your last transaction to verify your identity in response to exercising requests of the above type. We may limit our response to your exercise of the above rights as permitted under applicable law. When you submit a request to exercise your rights described above, we will use the information you provide to process your request and to maintain a record of your request and our response, as permitted under applicable law.

Under applicable law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.
If you are an authorized agent submitting a request on behalf of a consumer, please email support@smallssliders.com with a subject line of “Privacy Rights Request” and identify in the body of the email (1) which state you reside in and (2) which privacy right(s) you would like to exercise.

International Transfers

We control and operate our Services from within the United States of America. If you are accessing our Services from outside of the US, please be aware that information collected through our Services may be transferred to, processed, stored, and used in the US and other jurisdictions. Our online privacy practices are governed by the laws of the United States and Georgia, which may differ from privacy laws in your state or home country. By using our Services, you are expressly consenting to the transfer to and from, processing, usage, sharing, and storage of your information in the US and other jurisdictions as set forth in this Privacy Policy. If your data is collected in the European Union (“EU”), we will transfer your personal data subject to appropriate or suitable safeguards, such as Standard Contractual Clauses.

This English-language privacy policy is our official statement of its online privacy practices. In case of any inconsistency between this English-language privacy policy and its translation into another language, this English-language document shall control.

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 any questions about this Privacy Policy or our privacy practices, please contact us at support@smallssliders.com or by mail at 700 Central Parkway, Suite 1100, Atlanta, Georgia 30328.