Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete or Revise), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • Sales/sharing of information for cross-contextual behavioral advertising, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete or Revise), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Revise

You have the right to request that we correct inaccurate personal information. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Delete or Revise), we will correct the inaccurate personal information.

Exercising Your Rights to Know, Delete or Revise

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at 866-216-2175.
• Emailing us at hfc.privacy@gohfc.com.
• Visiting our Privacy Portal

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include two or more of the following:
  • An email address that matches an email address we already have on file for you.
  • A telephone number that matches a telephone number we already have on file for you.
  • A physical address that matches a physical address we already have on file for you.
  • A form of identification such as a driver’s license.
  • If you wish to appoint an agent to make requests on your behalf, submit a power of attorney appointing your agent to make requests on your behalf to hfc.privacy@gohfc.com.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

For instructions on exercising your sale or sharing opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at hfc.privacy@gohfc.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are age 16 or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt-out”). We do not sell or share the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. Consumers who opt-in to personal information sales or sharing may opt-out of future sales or sharing at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing hfc.privacy@gohfc.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Cross-Context Behavioral Advertising Opt-Out and Opt-In Rights

You have the right to direct us to not share your personal information for cross-context behavioral advertising purposes.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

Do Not Share My Personal Information for Cross-Context Behavioral Advertising

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sharing for cross-context behavioral advertising. However, you may change your mind and opt back in to personal information sharing for cross-context behavioral advertising at any time by emailing hfc.privacy@gohfc.com.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Sensitive Personal Information Use and Disclosure Limitations

You have the right to limit the use or disclosure of your sensitive personal information to just actions necessary to:

• Perform services or provide goods that an average consumer requesting those goods or services would reasonably expect.
• Help ensure security and integrity, if that use is reasonably necessary and proportionate.
• Perform short-term, transient uses, including but not limited to non-personalized advertising shown as part of your current interaction with us, if we do not:
  • disclose the sensitive personal information to another third party; or
  • use it to build a profile about you or otherwise alter your experience outside of your current interaction with us.
• Perform services including:
  • maintaining or servicing accounts;
  • providing customer service;
  • processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or providing similar services.
• Verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us.
• Improve, upgrade or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
• To perform other actions that CPRA regulations authorize.

We do not use, or disclose to a service provider or contractor, sensitive personal information for purposes other than what the CPRA specifically allows after you exercise your limitation right.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hfc.privacy@gohfc.com or write us at:

19000 MacArthur Blvd, Suite 100

Irvine, CA 92612

Third Party Web Services

HFC Services may contain links or content from third party websites. A link or content from a third-party website does not mean we endorse that website, the accuracy of information presented, or the persons or entities associated with that website. If you visit a third-party website, you are subject to the privacy policy of the applicable third party and we are not responsible for the policies and/or practices of any third party. We encourage you to ask questions before you disclose your information to others.

Changes to Our Privacy Policy

We reserve the right to amend this privacy policy at our discretion and at any time. When we make changes to this privacy policy, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which HFC collects and uses your information described here and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 866-216-2175

Website: homefranchiseconcepts.com

Email: hfc.privacy@gohfc.com

Postal Address:

Home Franchise Concepts, LLC

Attn: Privacy Office

19000 MacArthur Blvd, Suite 100

Irvine, CA 92612

If you need to access this Policy in an alternative format due to having a disability, please contact hfc.privacy@gohfc.com or 866-216-2175.