MERLE NORMAN COSMETICS
PRIVACY POLICY

Last Update: February 27, 2024

At Merle Norman Cosmetics, Inc. (“Merle Norman”), we value our relationship with our customers and respect the privacy of our customers. This Privacy Notice (“Notice”) describes how we collect, use, and share personal information when you visit our website (“Site”) or communicate with us. This Notice does not apply to personal information collected by Merle Norman Cosmetics Studios, which are independent businesses owned and run by franchisees. If you want to know more about the privacy practices of your local Merle Norman Cosmetics Studio, please visit their Studio page or reach out to them directly.

This Notice does not apply to any third-party links contained on our Site and/ or in our marketing communications. We are not responsible for the privacy policies or practices of third-party links. You should read the privacy policy for each website that you visit.
 

Quick Links to Content

1.     INFORMATION WE COLLECT AND HOW WE USE IT

A.    Personal Information You Provide
B.    Personal Information Collected Automatically
C.    Personal Information Collected by Third Parties

2.     DE-IDENTIFIED AND AGGREGATE DATA

3.     HOW WE SHARE THE INFORMATION WE COLLECT

4.     USE OF COOKIES AND TARGETED ADVERTISING

A.    Analytics Tools.
B.    Targeted Advertising.
C.    Do Not Track Requests.

5.     MARKETING COMMUNICATIONS; OPT OUT

6.     REQUIRED NOTICES

A.    Legal Categories of Personal Information.
B.    California Rights - Shine the Light Notice.

7.     Your Privacy Rights.

A.    What to Expect When Making a Privacy Request.

8.     CHILDREN'S PRIVACY

9.     DATA SECURITY

10.    DATA TRANSFER TO THE UNITED STATES

11.     CHANGES TO OUR PRIVACY NOTICE

12.    CONTACT US

13.    Annex 1 - PRIVACY CHART

1. INFORMATION WE COLLECT AND HOW WE USE IT

We may collect personal information about you when you visit our Site or otherwise communicate with us. We collect the following types of personal information and other data from you:

A.   Personal Information You Provide

You may provide us with Personal Information directly through your interactions with us for the following activities:

• Create and Manage Your Account: When you create an account with us or use certain features of our Site available to members, we may collect your first name, last name, phone number, email and login credentials, payment card information, and billing address. We use a third party PCI DSS compliant payment processor to store your preferred payment card information.
• Marketing: When you subscribe to our mailing list, we may collect your email address, mobile phone number and communications preferences so we can offer you products and services directly to you or on behalf of our Franchisees, tell you about sales, tell you about contests and sweepstakes, contact you with promotional and related communications, send you e-mails or text messages about our products and services, offers, promotions or special events that we believe may interest you.
• Process Transactions: When you place an order for products on our Site or over the phone, we may collect your first and last name, address, city, state, ZIP code, phone number, email, payment card information and/ or other payment details, and product information.
• Customer Support or Assistance: When you contact us through email, phone or through our Contact Us Form, we may collect your first name, last name, email, phone, order number, reason for your inquiry, and any details that you provide through the course of providing you with customer support or assistance.
• Use Site Features: Some of our Site features require you to provide personal information in order to use them, such as when you use our Find a Studio or Order Status features. When you use one of these features we may collect personal information, including your city, state, ZIP code, order number, and/or order email.
• Surveys, Promotions, Reviews and User Content: When you complete a survey, participate in a promotion, submit a review, or send other content to us, we may collect personal information, including photographs, videos, name, city, state, ZIP code, survey responses, opinions, articles, and comments.
• Social Media: When you engage with us through social media, including Facebook, Twitter, YouTube, Pinterest, and Instagram.

B.   Personal Information Collected Automatically

We use cookies, web beacons and similar technologies on our Site to collect information automatically from your device(s) or browser. For more information about the use of cookies and other tracking technologies on our Site and your choices, see the Use of Cookies and Targeted Advertising section below. We collect personal information automatically for the following activities:

• Providing Services: When you visit our Site, we may collect information about your browser and device settings such as your cookie settings, or language preferences, automatically from your device or browser in order to customize your experience.
• Marketing, Advertising, Promotions: When you use our Site, we may collect your IP address, marketing identifier, or other device identifier and products you viewed automatically from your device or browser to help customize content, marketing communications, advertisements promotions we offer to you, and experiences on the Site.
• Analyzing and Improving our Products and Services: When you use our Site, we may collect your IP address, marketing identifier, or other device identifier, and analytics information about how you engage with our Site and which products you viewed.
• Security and Fraud Prevention: In order to provide our Services, including operating our Site, troubleshoot bugs, and prevent fraud, we may collect IP address and log data automatically from your device or browser.

C.   Personal Information Collected by Third Parties

We may also collect certain personal information about you from third parties for the following business activities:

• Process Transactions: When you place an order on our Site or over the phone, we use a third-party system to process your payment, we may receive personal information about your transaction from our payment processors, such as transaction information, transaction amount, card type and/or payment method. All credit and debit card data is provided directly to our PCI-compliant third-party payment processors, which may include Apple Pay, Google Pay, BAMS, PayPal and Avalara.  If you elect to use third-party payment platforms for your purchase, you understand that your payment and purchase information is provided to such third-party platform, which we do not control.  We encourage you to review the terms and privacy policies of third-party payment platforms that you may elect to use.  We do not directly access, handle, or store your credit or debit card data.  We store your payment card’s last four digits to facilitate future orders.
• Marketing and Advertising: We use third-party cookies to help us deliver marketing and advertising content to you. To learn more, see Use of Cookies and Targeted Advertising section below.

In addition to the processing activities described above, we may use any personal information collected from you, directly or indirectly, for the following business purposes:

• Defending Legal Rights: to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect rights or interests, including in the context of anticipated or actual litigation.
• Auditing, Reporting, Governance and Internal Operations: to conduct our business, including: fulfilling our financial, tax and accounting obligations, such as audits, assessments, privacy, security, and financial controls, accounting, record keeping and legal functions; any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business; development of new products and services; administering our Services and in-store technologies,
• Improve our products and services: to maintain and improve our promotions, online services and technologies, including identifying target customers, we may use aggregate, de-identified, and/ or personal information to identify current and potential users of our online services, identify usage patterns of our services, and develop target audiences for our products and services.
• Complying with Legal Obligations: to comply with the law, our legal obligations and legal processes (such as warrants, subpoenas, court orders, and regulatory or law enforcement requests).

2. DE-IDENTIFIED AND AGGREGATE DATA

We may de-identify and aggregate data for our business purposes, including but not limited to, to improve the products and features of our Services, to maintain the security and integrity of its systems, for analytics, and other legitimate business purposes. "De-identified Data" means information that cannot reasonably be used to infer information about, or otherwise be linked to a particular data subject. Where we process De-identified Data, we commit to maintain and use the information in de-identified form and not attempt to reidentify the information, except where permitted by law. We may disclose De-identified Data to third who commit themselves to maintaining the De-identified Data in de-identified form and not attempt to re-identify the data for any business purpose.

3. HOW WE SHARE THE INFORMATION WE COLLECT

We share personal information and other information we collect for our legitimate business purposes, such as to process payments or to assist us in the operation of our business. We may disclose your personal information with the following categories of persons and entities pursuant to a business purposes:

• Franchisees and Affiliates: We may share personal information with our franchisees and affiliates to assist them in providing products and services to you. We require that those entities comply with the terms of this Privacy Notice when utilizing that personal information.
• Service Providers: We share personal information with service providers, suppliers, consultants, agents, distributors, and other partners who provide business services for us to assist us in operation of our business. For instance, we provide personal information and other information we collect to companies that provide website hosting and management services, payment processing services, marketing and public relations companies, third-party shipping companies, inventory management and post-purchase processing companies, and email service providers. The providers assist us in facilitating sales and delivery of your orders, provide functionality for our Site, help to enhance the security of the Site, improve our products and services and market to you. These third parties are not permitted to use that personal information other than to assist us in performing our business.
• Social Media Providers: When you use our Social Media features on our Site, the Site allows you to connect and share comments and reviews on your Social Media page. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media to facilitate those communications and features. Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Site and our Social Media pages any comments or content that you post on our Social Media pages. YOU AGREE TO HOLD MERLE NORMAN COSMETICS, INC., ITS AFFILIATES AND FRANCHISEES HARMLESS AND WITHOUT LIABILITY FOR THE RESULTS OF ANY AND ALL CONTENT YOU POST ON OUR SOCIAL MEDIA PAGES. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Notice. We encourage you to review those policies and terms.
• Videos; Embedded Content: The Site may contain videos and embedded content provided by Merle Norman Cosmetics or third parties, including visible content and/or feeds scripts embedded in the Site’s code. Merle Norman Cosmetics and such third parties may collect data about how you interact with such content (e.g., YouTube may collect usage data on videos embedded on the Site as described in YouTube’s Policy). By watching the videos and interacting with such content, you agree to the collection and use of such data.
• Law Enforcement, Security & Protection of Rights: We may share personal information with third parties, including law enforcement and government officials, if we believe it is needed to operate the Site or to protect our rights or the rights of others, including sharing data needed to identify, contact, or bring legal action if our contracts, terms, or policies are violated or if required by law.
• Other Third-Parties: We may share personal information in connection with certain business transactions. For example, if we undergo a change or contemplated change in control, acquisition, merger, reorganization, or asset sale, we may share, sell, or transfer your personal information with potential and actual successors. We also may share personal information with third-parties with your consent when we use or share your personal information in ways not specifically described in this Notice.

4. USE OF COOKIES AND TARGETED ADVERTISING

When you use the Site, we may use technologies such as cookies (i.e., small pieces of data stored on your device’s hard drive by your browser), web beacons, pixel tags, and other storage technologies. In addition, third parties, including Facebook, may use those same technologies to collect or receive information from our Site and elsewhere on the Internet and use that information to provide measurement services and target ads. These cookies and other technologies collect the IP address assigned to your computer or other electronic devices, your internet service provider, device ID number, approximate geographic location, browser type, Site pages visited, websites you access before and after visiting the Site, and data related to how and when you use the Site (e.g., date and time stamps, session replay, clickstream data, and data about search terms and websites that direct you to the Site). We may combine this data with other data (including personal information) and data obtained from third parties. Cookies are generally categorized as strictly necessary, functional, performance or marketing cookies. Merle Norman Cosmetics utilizes the following categories of Cookies for use in its Services:

• Strictly Necessary – These are essential for you to browse our website and use its features.
• Functional – These allow us to remember your choices you have made in the past, such as what language you prefer.
• Performance – These are used for analytical purposes, and help us understand the ways in which you interact with us on our website so we can improve our website functions.
• Marketing – these cookies track your online activity to allow advertisers to deliver relevant content to you on other websites.

Cookies can also be categorized by duration. The Site may use session, persistent, and flash cookies (local stored objects) to collect and store data about your preferences and navigation to, from, and on our Site. Session cookies are used to complete transactions and for other purposes, such as counting visits to certain webpages. Session cookies are eliminated when you exit your browser. Persistent cookies may be stored on your computer by your browser. When you log in, persistent cookies tell us if you have visited the Site before or if you are a new visitor.

Flash cookies differ from browser cookies regarding the amount and types of data collected and how the data is stored. Cookie management tools provided by your browser will not remove and cannot manage Flash cookies. To learn about managing your Flash cookie settings, visit the Flash player settings page on Adobe’s website here.

Most browsers automatically accept cookies. You can opt out of non-essential cookies by clicking the “Cookie Settings” button in the footer of the page, but doing so may impact your use and enjoyment of the Site.

A. Analytics Tools.

We may enable and implement various analytics tools, such as Google Analytics. Google Analytics is an analytics tool which allows us to collect and process personal information and other data consisting of certain telematics about your use of the Site. Google sets and reads cookies to collect such personal information and other data and your web browser will automatically send such data. Google uses this data to provide us with reports that we use to improve the Site’s structure and content.

We may occasionally enable and implement additional add-on services to Google Analytics, such as Demographics and Interest Reporting. Demographics and Interest Reporting uses cookies to collect data about our Site traffic by tracking users across websites and across time to provide us with analytics on our user base.

To learn more about how Google uses data, visit Google's Privacy Notice and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.

The Site may use advertising networks and services offered by Social Media to deliver advertising content. Use of these services requires Social Media to implement cookies or pixel tags to deliver ads to you while you access the Site.

B. Targeted Advertising.

Advertising network services gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables the delivery of advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “targeted advertising.”

We use advertising network services that collect data about your visits to the Site and other websites across the internet. These advertising network services use such data to target personal content and advertisements to you about our products. The data collected may be associated with your personal information. The targeted advertisements may appear on the Site and on other websites and may be sent to you via email.

For example, we may use Google Ads and Facebook Pixel to serve ads on our behalf across the internet and on the Site. Google Ads and Facebook Pixel use cookies, web beacons and other storage technologies to collect data about your visits to the Site and your interaction with our products and services to provide us measurements and generate targeted advertisements to you on other websites that you visit across the internet. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site. To opt of remarketing advertising provided through Facebook, you can use the following mechanism for exercising such a choice: https://youradchoices.com/control.

To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may occasionally still see our ads.

C. Do Not Track Requests.

Your browser settings may allow you to automatically transmit an opt-out preference signal or “Do Not Track” signal to online services you visit. Our Platforms currently are not designed to respond to Do Not Track signals received from web browsers.

Please note that if you set your browser to disable cookies or other tracking mechanisms, then your experience using our online services may not be the same depending on the particular service. Specifically, functionality of a service may be limited, may not function properly, or may not work at all. These functionalities include, but are not limited to, settings as to screen size and appearance, logon verification, and pre-populated information.

5. MARKETING COMMUNICATIONS; OPT OUT

If you opt in to receive marketing communications from us, we may use third-party providers to deliver communications to you. You may opt out of such commercial emails by using the unsubscribe link in the email or contacting us at unsubscribe@merlenorman.com with “Unsubscribe” in the subject line. To opt out of other communications (e.g., postal marketing and telemarketing) please contact us using the information provided in the Contact Us section of this Notice. Opting out of marketing communications does not opt you out of communications about your transactions with us or your account. Please note, by unsubscribing to Merle Norman commercial communications, you will not be automatically removed from communications from any of Merle Norman’s Studios you may have also signed up with, which are independently owned and operated franchises. To opt out of communications from Studios, you must contact them directly.

6. REQUIRED NOTICES

A. Legal Categories of Personal Information.

Some laws require that we disclose the Legal Categories of Personal Information we collect in a specific way. To make this easier, we have provided a Personal Information Privacy Chart in Annex 1 of this Notice that explains the information we collect, the business purposes we use the personal information, with whom we share the personal information, and whether we sell that information and to whom. In addition, we have disclosed the Categories of personal information we have shared and sold in the past 12 months. For more information about the legal categories of personal information we collect and process, please review the chart in Annex 1.

B. California Rights - Shine the Light Notice.

California residents have the following additional rights to request: (a) a list of all third parties to whom we may have disclosed your personal information within the past year for direct marketing purposes, and (b) a description of the categories of personal information disclosed.

To make a request, please contact us using the methods in the Contact Us section below. Requests must include “California Marketing Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided e-mail address or mailing address.

7. Your Privacy Rights.

We want you to be in control of your information, so we want to explain the privacy rights and options that you may have regarding your personal information. We have defined the various rights below.

The Right to Access; Know: You may have the right to know the categories of personal information collected about you, the business purpose it is used for, and know whether your personal information is disclosed or sold and to whom. In addition, you may have the right to access the personal information we hold about you and receive a copy of your personal information.

The Right to Data Portability: You may have the right to request the transfer of your personal information to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format.

The Right to Deletion. You may have the right to request the deletion of your personal information. Note however, this right may be subject to certain limitations such as (a) exceptions permitted by applicable law and (b) verification of your identity.

The Right to Limit Use and Disclosure of Sensitive Personal Information: You may have the right to direct us to limit our use of your sensitive personal information to that use which is necessary to perform the services and which is reasonably expected by the average consumer requesting the services.

The Right to Non-Discrimination / Non-Retaliation: You may have the right not to receive discriminatory treatment because you choose to exercise your privacy rights.

The Right to Opt-Out of the Sale or Sharing: You may have the right to opt out of the Sale of your personal information. You may also have the right to request we do not Share certain types of personal information with third parties.

The Right to Opt-Out of Profiling and/or Targeted Advertising: You may have the right to opt out of the processing of your personal information for the purposes of Targeted Advertising, Cross Context Behavioral Advertising, or Profiling which is used in furtherance of decisions that produce legal or similarly significant effects. "Profiling" means any automated processing of Personal Data to evaluate, analyze, or predict aspects concerning an individual's economic situation, health, personal preferences, interest, reliability, behavior, location or movements.

The Right to Request Correction: You may have the right to request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

The Right to Appeal: You may have the right to appeal a decision we make whether or not to take action on any request to exercise one of your privacy rights.

A. What to Expect When Making a Privacy Request.

How to Exercise Your Privacy Rights.

To exercise your privacy rights, you may submit your request to us by contacting us at any of the following: Phone: +1 (800) 788-1191 Form: Your Privacy Choices.

Verification.

In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. Please include your name, email address and/ or phone number in your request. Depending on your relationship with us and the type of request you are making, we may need to ask you for additional information to match against information in our systems. This helps to ensure that we provide the correct personal information to the individual about whom the data was collected. Such additional information may include prior transaction information, last four digits of your card on file, prior order numbers, or any other information that we may already have in our systems so we can verify your identity.

Response Process.

When we receive your request to exercise your rights under applicable law: (a) we will acknowledge receipt of your request; (b) we will try to match the information you provide in making the request with information we already maintain about you; (c) if required to verify your identity, we may ask you to provide additional information, including personal information; (d) we will consider various factors when determining how to verify your identity, such as the sensitivity and value of the data, the risk of harm, the likelihood of fraud, etc.

We will only use personal information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request, and let you know why.

When We Will Respond. We will try to respond to your request for access or deletion within 45 days. If we require additional time, we will inform you of the reason and extension period.

Requests by Authorized Agents. You may only make a request to exercise your rights on behalf of yourself. You also have a right to submit requests to exercise your rights through an authorized agent. If you choose to use an authorized agent, we may require that the authorized agent provide proof that you gave the agent signed permission to submit the request. We may also require you to verify your own identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request.

8. CHILDREN’S PRIVACY

We are committed to protecting children’s privacy. The Site is not directed at children under 13 years of age. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request or solicit Personal Information from anyone under the age of thirteen (13) nor will we knowingly allow anyone under the age of thirteen (13) to create an account with us. If a parent or legal guardian learns their child provided us with personal information without his or her consent, please contact us. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services.

9. DATA SECURITY

We use commercially reasonable technical and organizational measures to help secure all data against loss, misuse, and alteration. While we cannot guarantee it, we use industry-standard protections to help safeguard against such occurrences. If a breach of our systems occurs, we will notify you of the breach only if, and, as required under applicable law. YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR A MOBILE DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

10. DATA TRANSFER TO THE UNITED STATES

This Site is operated and maintained by Merle Norman Cosmetics from the United States and is intended solely for a United States audience. If you access the Site from outside the United States, please be aware that personal information will be transferred to, stored in, and processed in the United States. U.S. data protection and related laws may not be as comprehensive as those from where you access the Site. Certain Site features may not be available to individuals located outside of the United States.

11. CHANGES TO OUR PRIVACY NOTICE

We may modify this Notice at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you.

12. CONTACT US

If you have questions or concerns regarding this Notice, contact us using our Contact Us Form , by phone or by mail at:

Merle Norman Cosmetics, Inc.
9130 Bellanca Avenue
Los Angeles, California 90045
+1 (800)788-1191

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13. Annex 1 – PRIVACY CHART

Category	Sources	Purposes for Collection and Use	Sharing with Third Parties for a Business Purpose
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Directly from you Automatically from your Device From third parties	Create and Manage Your Account Marketing Process Transactions Customer Support Operate the Site Surveys and Promotions Analytics Security and Fraud Prevention Defending Legal Rights Internal Operations Improve Products and Services Comply with Law	Franchisees and Affiliates Service Providers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, marital status, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Directly from you	Create and Manage Your Account Marketing Process Transactions Customer Support Operate the Site Surveys and Promotions Analytics Security and Fraud Prevention Defending Legal Rights Internal Operations Improve Products and Services Comply with Law	Franchisees and Affiliates Service Providers
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Not Collected	N/A	N/A
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Directly from you	Marketing Analytics Customer Support Process Transactions Defending Legal Rights Internal Operations Improve Products and Services Comply with Law	Franchisees and Affiliates Service Providers
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, DNA data, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Not Collected	N/A	N/A
F. Internet or other similar network activity. Browsing history, search history, information on an employee's interaction with a website, application, or advertisement.	Not Collected	N/A	N/A
G. Geolocation data. Data that can identify a consumer's physical location or movements.	Automatically from your device Third Parties	Create and Manage Account Marketing Process Transactions Customer Support Operate the Site Surveys and Promotions Analytics Security and Fraud Prevention Defending Legal Rights Internal Operations Improve Products and Services Comply with Law	Franchisees and Affiliates Service Providers
H. Sensory data. Audio, electronic, visual, olfactory, or similar information.	Not Collected	N/A	N/A
I. Professional or employment-related information. Current or past job history or performance evaluations.	Not Collected	N/A	N/A
J. Education information as defined by the Family Education Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99). Information that is not publicly available maintained by an education agency or institution related directly to a student.	Not Collected	N/A	N/A
K. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Not Collected	N/A	N/A
L. Sensitive personal information. Personal information that reveals a consumer's: Social Security number, driver's license number, state identification card number, or passport number; a consumer's account log-in, financial account, debit card, or credit card number in combination with any security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer's mail, email, and text messages (not business related); genetic data; biometric data used to uniquely identify a consumer; health data; or data related to sex life or sexual orientation.	Not Collected	N/A	N/A

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

In addition to the purposes described in this notice, we may use Personal Information listed below for business purposes.

Category A: Identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Category D: Commercial information.
Category G: Geolocation data.

No Sales of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.