Franco Privacy Policy

Updated on January 17, 2023

FRANCO LLC ("Company"or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://francohq.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:
·      On this Website.
·      In email, text, and other electronic messages between you and this Website.
·      Through mobile and desktop applications you download from this Website, which provide dedicated non-browser based interaction between you and this Website.
·      When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:
·      Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
·      Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy.This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Definitions

The following are definitions for some terms in this Privacy Policy:

“Content” refers to all text, images, photographs, graphics, logos, illustrations, descriptions, data, tools, features, apps, pages, and other materials provided on any of the Services, as well as the selection, assembly, arrangement, “look and feel,” and design of any of theServices.

“Personal Information” refers to any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, other contact information, a personal identification number (like a Social Security number), location data, an online identifier, and information specific to one or more elements specific to an individual’s physical,physiological, genetic, psychological, economic, cultural or social identity.

“Privacy Policy” refers to this privacy policy of the Company.“You” and “Your” refer to You the person who is reading this Privacy Policy or accessing or using any of our Services.

“User” refers to anyone who visits, uses, or accesses any of our Services, including You if You visit, use, or access any of our Services.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any (including personal) information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us,including your name, address, telephone number, email address, or any screenname or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have anyinformation from or about a child under 18, please contact us at nirav@francohq.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personalinformation.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:
·      By which you may be personally identified, such as name, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline ("personal information");
·      That is about you but individually does not identify you, such as name, telephone numbers, email addresses, postal addresses; and/or
·      About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:
·      Directly from you when you provide it to us.
·      Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses,and information collected through cookies, web beacons, and other tracking technologies. ·      From third parties, for example, our business partners.

We keep Personal Information that we collect about You for as long as You are an active User of our Services. If You become an inactive User, the Personal Information we have collected about You will be kept for a period of 24 monthsand then deleted, unless You advise otherwise. We store personal information in the US. To exercise Your rights over Your Personal Information that we collect about You,You may use the tools that we make available on the Services, or You may submit an access request by sending an email to our privacy administrator at our privacy administrator at nirav@francohq.com.

Information you Provide to Us

The information we collect on or through our Website may include:
·      Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contestor promotion sponsored by us, and when you report a problem with our Website.
·      Records and copies of your correspondence (including email addresses), if you contact us.
·      Your responses to surveys that we might ask youto complete for research purposes.
·      Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
·      Your search queries on the Website.
·      Any other types of information you provide.

You also may provide information to be published or displayed (hereinafter, "posted")on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmittedto others at your own risk. Although please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions ofother users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
·       Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
·      Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better andmore personalized service, including by enabling us to:
·      Estimate our audience size and usage patterns.
·      Store information about your preferences, allowing us to customize our Website according to your individual interests.
·      Speed up your searches.
·      Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:
·      Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
·      Web Beacons. Pages of our Website and/or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
·      Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by thesame browser settings as are used for browser cookies.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks andservers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:
·      To present our Website and its contents to you.
·      To provide you with information, products, or services that you request from us.
·      To fulfill any other purpose for which you provide it.
·      To provide you with notices about your account or subscription, including expiration and renewal notices.
·      To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
·      To notify you about changes to our Website orany products or services we offer or provide though it.
·      To allow you to participate in interactive features on our Website, if any.
·      Any other purposes.
·      In any other way we may describe when you provide the information.
·      For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form or registration form)/adjust your user preferences in your account profile.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Dislosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:
·      To our subsidiaries and affiliates.
·      To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
·      To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Franco LLC's assets, whether as a going concernor as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Franco LLC about our Website users is among the assets transferred.
·      To third parties to market their products orservices to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and useit only for the purposes for which we disclose it to them.
·      To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Website, we will transmit the contents of that email and your email address to the recipients.
·      For any other purpose disclosed by us when you provide the information.
·      With your consent.
·      Any other types of third-party disclosures.

We may also disclose your personal information:
·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
·      To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Franco LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
·      Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form or registration form). You can also always opt-out by sending us an email with your request to nirav@francohq.com.
·      Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form or registration form) or sending us an email stating your request to nirav@francohq.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
·      Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by emailing us at nirav@francohq.com.

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices.

Accessing and Correcting Your Information

You may send us an email at nirav@francohq.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

California Civil Code Section 1798.83 permits Users of our Services who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third-parties for direct marketing purposes and the names and addresses of all third-parties with which we shared Personal Information in the immediately preceding calendar year. If You are a California resident and would like to make such a request, please submit Your request in writing to us using the contact information provided below.

If You are under 18 years of age, reside in California, and have a registered account for any of our Services, California Business and Professions Code Section 22581 provides You with the right to request that were move unwanted data that You publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with Your account and a statement that You reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

In accord with, California Business and Professions Code Section 22575, we hereby disclose that we do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities overtime and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses our Services. 

To learn more about consumer privacy rights in other states and how to exercise them, visit the respective State Privacy Notices.

OR

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
·      Confirm whether we process their personal information.
·      Access and delete certain personal information.
·      Data portability.
·      Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:
·      Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
·      Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please email nirav@francohq.com. To appeal a decision regarding a consumer rights request, please email the same.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: nirav@francohq.com.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and sensitive information will be encrypted.

The safety and security of your information also depends onyou. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions, comment or register a complaint about this privacy policy and our privacy practices, contact us at:

nirav@francohq.com

Franco, LLC. operates the website at https://francohq.com. By using this website, you accept our Terms of Use and Privacy Policy.

Franco and its affiliates are an equal opportunity employer. We prohibit discrimination and harassment of any type and aims to provide equal opportunities to applicants regardless of race, gender, sex, ethnicity, religion, age, disability status, protected veteran status, or any other characteristic protected by law.

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Reach us at nirav@francohq.com for media inquiries or questions.