Last updated August 30, 2020, as amended August 22, 2022
- What Personal Information we receive or collect;
- How we collect Personal Information;
- How we use your Personal Information;
- How we share Personal Information we collect or receive with others, and
- Your choices and rights regarding your Personal Information.
2. Some Key Terms.
When we refer to “Personal Information” we mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Personal Information does not include de-identified or aggregated information that is not reasonably capable of being linked or associated with you.
3. What Personal Information We Receive or Collect.
Personal Information regarding you or your device that we receive or collect includes the following:
- Personal Information you provide to submit an inquiry or create an Account or to complete a franchise application, including your email address, first and last name, financial information, address, work history and other Personal Information such as your birthdate and gender.
- Your marketing preferences.
- The emails and other communications that you send us or otherwise contribute, such as customer support inquiries, posts to our customer message boards or forums and your public profile. Please be aware that information on public parts of our sites is available to others and can be read, collected or used by other Users. We are not responsible for the information you choose to make public in any of the message boards or forums.
- Information you share with us or our third parties in connection with research, surveys, newsletters, contests or promotions.
- Information from your use of the Services or websites, including: IP addresses, preferences, information about your browser, network or device (such as browser type and version, device type, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings), information about how you interact with the Services and our sites (such as date and timestamps, clicks, scrolling, browsing times, searches, transactions, referral pages, load times, and problems you may encounter, such as loading errors), location information and other usage information and statistics. We may work with third-party partners to employ technologies that permit us to recognize and contact you across multiple devices.
- Analytics data we collect, including from third party analytics tools to help us measure traffic and usage trends and demographics. We may also collect information on how you access our website, including the pages you visit, the links you click, whether you open emails you receive and what website you go to after vising our website.
- Information we get from our partners to support our marketing initiatives, improve our Services and better monitor, manage and measure our ad campaigns, such as details about when our partner shows you one of our ads on or via its advertising platform.
- Other information you submit to us directly.
- Credit and payment information.
- Personal Information from third parties, including from social media, other Users, and our marketing partners. We may also collect information about you that is publicly available, from third party websites that you may use to access our websites and information from our franchisees, affiliates and other business partners. We may combine this information with the information we collect from you directly.
4. How We Collect Personal Information.
We collect Personal Information in three main ways, as follows:
- You provide some of it directly to us (such as by submitting an inquiry or completing a franchise application).
- We record some of it automatically when you use our Services or Websites (including with technologies like cookies).
- We receive some of it from third parties (like when you have clicked on an ad to reach our website).
A. Personal Information you provide.
When you use our Services or make an inquiry regarding the Refresh Renovation franchise opportunity, we collect information from you in a number of ways. For instance, we ask you to provide your name and email address to submit an inquiry. We also maintain your marketing preferences and the emails and other communications that you send us or otherwise contribute, such as customer support inquiries or posts to our customer message boards or forums. You might also provide us with information in other ways, including by responding to surveys, submitting a form, completing an application or participating in contests or similar promotions.
Sometimes we require you to provide us with information for contractual or legal reasons. For example, we may ask you to select your jurisdiction, state and/or county when you make an inquiry to determine if, and how much, tax we need to collect from you. We will normally let you know when information is required, and the consequences of failing to provide it. If you do not provide personal information when requested, you may not be able to use our Services if that information is necessary to provide you with the Service or if we are legally required to collect it. You may also not be able to purchase a Refresh Renovation franchise.
B. Personal Information obtained from your use of our Services.
When you use our Services, we collect information about your activity on, and interaction with, the Services, such as your IP address(es), your device and browser type, the web page you visited before coming to our websites, what pages on our websites you visit and for how long, and identifiers associated with your devices. If you have given us permission through your device settings, we may collect your location information in our mobile apps.
C. Personal Information obtained from other sources.
If you use a third-party service (such as Google) to register for an Account, the third-party service may provide us with your third party service account information on your behalf, such as your name and email address (we don’t store passwords that you use to access third party services). Your privacy settings on the third-party service normally control what they share with us. Make sure you are comfortable with what they share by reviewing their privacy policies and, if necessary, modifying your privacy settings directly on the third-party service website.
5. How We Use Your Personal Information.
We and the third parties we work with may use the Personal Information we obtain about you for the following uses:
- To create and manage your Account, provide and personalize our Services, process payments and respond to your inquiries.
- To communicate with you about your transactions, your requests and inquiries regarding our Services, products, Refresh Renovation franchise opportunities, Service-related announcements, and changes to our terms and conditions, policies and/or other information.
- To provide you with Services and products requested by you, or to respond to your inquiries. In other words, so we can perform our contract with you or take steps at your request before entering into one. For example, we need your email address so that we can contact you and so that you can sign into your Account to monitor the progress of your renovation. We also use the Personal Information to provide information regarding the Refresh Renovation franchises.
- To administer surveys, sweepstakes, contests and other promotions, including adding you to email and mailing lists and permitting you to participate in surveys, contests, sweepstakes and other promotions. We also use Personal Information to determine your eligibility to participate in surveys, sweepstakes, contests and other promotions and your eligibility to purchase a Refresh Renovation franchise.
- To promote our Services and send you tailored marketing communications about our products, Services, offers, programs and promotions, our franchisees, Refresh Renovation franchise opportunities and our partners and measure the success of those campaigns, including on social media, third party sites and email campaigns. For example, we may send different marketing communications to you based on your region, state, Services we provided to you or what we think may interest you based on your Personal Information.
- To analyze your interactions with our Services and third parties’ online services so we can tailor our advertising to what we think will interest you, including on social media, third party sites and email campaigns. For example, we may send you a particular advertisement based on when we provided Services to you and what we think may interest you based on your Personal Information.
- To analyze and learn about how our Services and Websites are accessed and used, evaluate and improve our Services and websites (including by developing new products and services and managing our communications) and monitor and measure the effectiveness of our advertising and promotions. We usually do this based on anonymous, pseudonymized or aggregated information which does not focus on you individually.
- To ensure the security and integrity of our Services, business and technology.
- To manage our vendor and partner relationships.
- To enforce our Terms of Service and other legal terms and policies.
- To protect our and others’ interests, rights and property (e.g., to protect our Users from abuse, spam and fraud).
- To comply with applicable legal requirements, such as tax and other government regulations, franchise laws and industry standards, contracts, court order and law enforcement requests.
- For our internal business purposes, including research, data analysis, Service development, enhancement and improvement, audits, fraud and crime prevention, User enhancement and personalization of our Services. We also share your Personal Information with our affiliates, franchise brokers and franchisees to help us provide and improve our Services.
- To anonymize and subsequently use anonymized information.
- For third parties’ legitimate interests, such as our partners who have a legitimate interest in delivering tailored advertising to you and monitoring and measuring its effectiveness or our Users who have a legitimate interest in having their websites function properly and securely and analysing the usage of their websites so they can understand trends and improve their services.
- Other reasons that we disclose to you at the time you provide your Personal Information. When you consent to the use of your Personal Information, you can change your mind at any time.
6. How We Share Your Personal Information.
We share Personal Information in the following ways:
- We may share Personal Information with our business partners. For example, we may share your Personal Information when our Services are integrated with our business partner’s services.
- We share Personal Information with our service providers, third party vendors and consultants that perform services or functions on our behalf. For example, we may use third parties to help us provide renovation services, manage our advertisements on other websites, send marketing and other communications on our behalf, facilitate the sale of Refresh Renovation franchises or assist with data storage.
- We disclose your Personal Information if we determine that such disclosure is reasonably necessary to comply with the law, protect our or others’ rights, property or interests (such as enforcing our Terms of Service or in connection with legal claims), to collect debts owed to us, detect or prevent fraud or abuse or as otherwise required by applicable law, including franchise law. In particular, we may disclose your Personal Information in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
- We share Personal Information with third parties so they and we can provide you with tailored advertising and measure and monitor its effectiveness. For example, we may share your pseudonymized email address with a third-party social media platform on which we advertise to avoid redundant advertising.
- We may be involved in a corporate transaction, such as a reorganization, joint-venture, financing, merger, acquisition or sale of some or all of our assets. We may disclose or transfer your Personal Information in connection with such business transactions.
- We may share Personal Information with third parties with your approval or at your direction.
- We may disclose Personal Information to the public on our website or social media platform if you post feedback or user content on our services. For example, your first name and comments may be displayed on our website or social media site if you post a review of our services. We may also tag your social media account or the account of others if you engage with us on social media.
- We may also aggregate or de-identify your Personal Information in such a way so that you are not uniquely identified.
7. Your Rights and Choices over Your Personal Information.
Where applicable law requires (and subject to any relevant exceptions under applicable law), you may have the right to access, update, change or delete your Personal Information.
You can access, update, change, adjust your Account settings or delete Personal Information by contacting us at firstname.lastname@example.org to request the required changes. You can exercise your other rights (including deleting your Account with us) by contacting us at the same email address or by calling us on + 1 (850) 332-6131.
You can also stop receiving marketing and promotional communications from us by changing your preferences in your Account or by following the unsubscribe instruction in such communications. However, you may not opt out of Service-related communications.
Please note that, for technical reasons, there is likely to be a delay in updating, changing, or deleting your Personal Information or adjusting your Account settings. We also will retain Personal Information in order to comply with the law, protect our and others’ rights, maintain warranties, resolve disputes or enforce our legal terms or policies, to the extent permitted under applicable law.
You may have the right to restrict or object to the processing of your Personal Information or to exercise a right to data portability under applicable law. You also may have the right to lodge a complaint with a competent supervisory authority, subject to applicable law. If you are subject to EU data protection laws, we suggest you lodge any such complaints with our lead supervisory authority:
Renovations Franchise UK Limited
Re: Privacy Compliance Officer
Level 1, Devonshire House
One Mayfair Place
London, W1J 8AJ
Additionally, if we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time, free of charge. When you do so, this will not affect the lawfulness of the processing of your Personal Information before your consent withdrawal.
8. How We Protect Your Personal Information.
While no service is completely secure, we have an IT team dedicated to keeping Personal Information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of the Personal Information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.
9. How We Retain Your Personal Information.
How long we keep your Personal Information varies depending on the nature of the information and why we need it. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to an agreement or other matter, whether the Personal Information has been aggregated or pseudonymized, and other relevant criteria. For example, the period we keep your email address is connected to how long your Account is active.
In providing the Services, we collect and maintain aggregated, anonymized or de-personalized information which we may retain indefinitely.
10. Data Transfers.
Personal Information that you submit through the Services or inquiry regarding the purchase of a Refresh Renovation franchise may be transferred to countries other than where you live, such as, for example, to our servers in New Zealand. We also store Personal Information locally on the devices you use to access the Services or access for information regarding the Refresh Renovation franchise.
Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We rely upon a number of means to transfer Personal Information which are subject to the European General Data Protection Regulation (“GDPR”) in accordance with Chapter V of the GDPR. These include:
- Transferring, in accordance with Article 45 of the GDPR, Personal Information to companies that have certified their compliance with the EU-U.S. or Swiss-U.S privacy shield frameworks.
- We may, in accordance with Article 46 of the GDPR, transfer Personal Information to recipients that have entered into the European Commission approved contract for the transfer of personal data outside the European Economic Area.
- We may, in accordance with Articles 45 and 46 of the GDPR, transfer Personal Information to recipients that are in a country the European Commission or a European data protection supervisory authority has confirmed, by decision, offers an adequate level of data protection, pursuant to an approved certification mechanism or code of conduct, together with binding enforcement commitments from the recipient to apply the appropriate safeguards, including as regards data subjects’ rights, or to processors which have committed to comply with binding corporate rules.
11. Region-Specific Disclosures.
We may be required by law to provide different or additional disclosures relating to the use and processing of your Personal Information based on where you are located. Additional disclosures that may be applicable to you include:
- If you are a resident of the state of California, United States, please click here for additional California specific privacy disclosures.
- If you are a resident of Nevada, United States, please click here for additional Nevada specific privacy disclosures
12. Children’s Personal Information.
We do not direct our Services or websites to children. We do not intend to (knowingly or unknowingly) collect or solicit Personal Information from children under the age of 13. If you are under the age of 13, please do not use, provide us with your Personal Information. If a child under the age of 13 provides Personal Information, we encourage the child’s parent or guardian to contact us so we may remove the Personal Information from our system. If we learn that a child under the age of 13 has provided us with Personal Information, we will promptly delete the child’s Personal Information.
14. How to Contact Us.
If you are a resident of or have your principal place of business outside of the U.S., please email us at email@example.com or write to us at:
Renovation Franchise Ltd.
Attention: Legal - Privacy
Level 1, 287 Parnell Road
Last Updated August 30, 2020.
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- We partner with third party publishers, advertising networks and service providers to manage our ads on other websites. Our third-party partners may set cookies on your device or browser to gather information about your activities on websites you visit, in order to provide you with Refresh Renovations ads. For example, if you visit Refresh Renovations and also use a social media platform, you may see a Refresh Renovations ad in your social media newsfeed or timeline.
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- We use device identifiers to track, analyze and improve the performance of the Services and our ads.
You can set your browser to not accept cookies, but this may limit your ability to use the Services. You can also opt-out of receiving interest-based ads from certain ad networks here (or if located in the European Union, here).
4. Do Not Track.
We do not process or respond to “Do Not Track” signals from your browser or other mechanisms that enable consumer choice regarding the collection of personal information about one’s online activities over time and across third-party websites or online services.