Contents

1. Personal Information We Collect
2. Purposes for Collection of Personal Information
3. Categories of Personal Information We Collect and Use and Related Information
4. Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
5. Automated Information Collection and Use (including Cookies)
6. Personal Information of Minors
7. Third Party Websites and Social Media Buttons
8. How We Keep Your Personal Information Secure
9. Changes to This Policy
10. US State Data Consumer Privacy Rights
11. Text Messaging

This Privacy Policy (“Privacy Policy” or “Policy”) explains how Branches Company, LLC d/b/a Footprints Floors and its corporate affiliates (“we,” or “us,” or “our”) collect personal information based on your interactions with us online and offline, including on our websites, applications, and forums (collectively the “Sites”), other online offerings, when we provide services or offer products online or offline (collectively, the “Services”). This Policy applies to our collection and use of personal information and describes rights you may have with respect to your personal information. By using our Sites and otherwise interacting with us, you agree to our use of your information consistent with this Policy.

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1. Personal Information We Collect

We collect the following categories of personal information:

• Personal identifiers: name, email address, address of the property for which service is requested or provided, your home or billing address, telephone numbers, IP address, device information
• Protected class characteristics: age, sex/gender, marital status
• Commercial and financial information: records of products or Services ordered or considered; other purchasing or consuming histories; and payment information. For franchise applicants, owners, and respective spouses, information about your assets, income, property and business ownership interests and operations, and other financial information you provide to us
• Internet or other electronic activity information: your device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements
• Geolocation informationname, email address, address of the property for which service is requested or provided, your home or billing address, telephone numbers, IP address, device information
• Geolocation information
• Educational information: education history information provided by franchisee applicants
• Professional information: job title, information about your employer and, for franchise applicants, owners, and respective spouses, employment and business ownership history and recommendations provided by references
• Audio and visual information: recordings of customer service calls for quality assurance purposes; photographs of work sites

We have collected the above categories of personal information in the 12 months prior to the date of this Privacy Policy.

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2. Purposes for Collection of Personal Information

We collect, maintain, and use your personal information for a number of purposes set forth below:

• To provide you with the information you request
• To deliver our Services.
• To contact you from time to time to provide regarding Services we are providing or to inform you about our business
• To provide customer support and improve our services
• To evaluate franchise applicants
• To deliver advertisements and marketing promotions and offers about Services we think may be of interest to you, including our Services and those of our affiliates and franchisees
• To analyze the placement and effectiveness of our advertisements and other marketing efforts
• To monitor or improve our Sites and for internal business analysis
• To invite you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us)
• To better understand your needs and interests
• To prevent fraud and activities that violate our Terms of Service or that are illegal, or to prosecute malicious actors or pursue claims
• To protect our rights and the rights and safety of our users or others
• To engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent (for those who interact with us in a commercial capacity)
• To consider or undergo a corporate sale, merger, acquisition, reorganization, dissolution, or similar event. In these cases, personal data we collect from you may be transferred to a potential or actual acquirer or successor, who may continue to use the data in the ways described in this Privacy Notice.

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3. Categories of Personal Information We Collect and Use and Related Information

When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of the word “sell” under certain state laws) or we may share them for purposes of cross-context behavioral advertising:

• Personal identifiers (including IP address) and internet or other electronic activity information, phone numbers.

These categories of personal information are sold to or shared for cross-context behavioral advertising to advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Services we provide.  We do so by allowing third parties to place cookies or other trackers on our Sites that may collect information about your online activities over time and across different websites or applications.  These parties may then use the information they collect to provide you with personalized content.  For more information about the use of cookies and trackers, see the section “Automated Information Collection” below.

We do not sell or share any of the other categories of personal information we collect for cross-context behavioral advertising.

To opt out of such sales and sharing of personal information, please contact us at [email protected].

Retention Periods

We retain the personal information we collect and use for the length of time necessary to provide our Services (including any warranty services), to comply with legal obligations, or to protect our legal rights. Sometimes, your personal data is stored in backup archives or is otherwise stored in such a way that makes it technically infeasible to delete it. In that case, then we will continue securely storing your personal data but will cease processing it and will delete it at a future available opportunity.

Categories of Sources From Which We Collect Personal Information

We collect personal information directly from the following sources:

• From you directly, in customer and prospective customer interactions
• Representatives of entities with which we do or may do business, including our franchisees.
• We also collect personal information from franchisee applicants, owners, and their respective spouses, and the references provided by franchisee applicants, owners, and their respective spouses.
• Digital advertising networks and other marketing and advertising partners

Use or Disclosure of Sensitive Personal Information

We do not collect, use, or disclose Sensitive Personal Information, nor do we create profiles about individuals or for any purposes other than providing our Services.

Disclosure of Personal Information for Business Purposes in the Past 12 Months

The following chart describes the categories of personal information that we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:

Categories of Consumers’ Personal Information	Categories of Third Parties to Which We Disclosed Personal Information for Business Purposes
Personal identifiers: name, email address, address of the property for which service is requested or provided, home or billing address, telephone numbers, customer number, account password, IP address	Service providers that process payments, verify customer information, manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, process franchisee applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and Services and those of our affiliates, provide analytics information, provide legal and accounting services. Subcontractors that perform specialized components of the Services we offer. Franchises (if disclosed by Franchisor) or Franchisor (if disclosed by Franchisee).
Commercial information: records of products or Services purchased, ordered, returned, or considered; other purchasing or consuming histories; payment information.  For franchise applicants, owners and their respective spouses, information about applicants’, owners’, and respective spouses’ assets, income, property and business ownership interests and operations, and other financial information provided	Service providers that manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, process franchisee applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products or Services and those of our affiliates, provide analytics information, and provide legal and accounting services. Franchises (if disclosed by Franchisor) or Franchisor (if disclosed by Franchisee).
Internet or other electronic network activity information: device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements.	Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and Services and those of our affiliates, and provide analytics information.
Geolocation data	Service providers that advertise, market, and provide analytics information regarding our services.
Professional information: job title, information about your employer, franchisee applicants’ employment and business ownership history, and recommendations provided by references.	Service providers that manage business contact information and process franchisee applications. Franchises (if disclosed by Franchisor) or Franchisor (if disclosed by Franchisee).
Educational information: education history information provided by franchisee applicants.	Service providers that manage business contact information and process franchisee applications.
Audio and visual information: recordings of customer service calls for quality assurance purposes. Before and after photographs of completed worksites.	Service providers that manage customer information and provide customer service (including through our call center). Franchises (if disclosed by Franchisor) or Franchisor (if disclosed by Franchisee).

Business Purposes for Such Disclosures

We disclosed the aforementioned categories of personal information for the following purposes:

• to provide our Services;
• manage customer, supplier and vendor accounts and relationships;
• process payments;
• verify customers’ identities;
• engage in customer transactions;
• engage in advertising and marketing of our Services and those of our affiliates;
• operate our IT systems and secure our systems;
• prevent fraud and other illegal activities;
• obtain professional advice about legal and accounting matters;
• evaluate and manage franchise applicants and owners.

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4. Additional Information About How We May Disclose Personal Information and Purposes for Disclosures

We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.

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5. Automated Information Collection and Use (including Cookies)

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

• (a) Cookies . A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined as either session cookies, which do not stay on your device after you close your browser, or persistent cookies, which remain on your device until you delete them or they expire, and we may use either (or both) types. If you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality. We may use the following categories of cookies on our Website.
  • (1) Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested cannot be provided.
  • (2) Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
  • (3) Functionality Cookies. These cookies remember the choices you make such as your preferred language and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
  • (4) Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks. These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.

• (b) Google Analytics . The Website sends aggregated non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at  https://policies.google.com/technologies/partner-sites.
• (c) Facebook Pixel . With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display our Facebook ads only to Facebook users who have shown an interest in our website or who have specific characteristics (e. g. interests in certain topics or products determined by the websites visited) that we submit to Facebook. With the help of the Facebook pixel, we also want to make sure that our Facebook ads are in line with the potential interest of users and do not have a nuisance effect. Using the Facebook pixel, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad. Facebook's processing of the data is governed by Facebooks Data Usage Policy. Accordingly, general instructions on how to display Facebook ads is located in the Facebook Data Usage policy https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, please visit: https://www.facebook.com/business/help/742478679120153?id=1205376682832142
• (d) Web Beacons . A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.
• (e) Embedded Web Links . Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
• (f) Tech Embedded with Third-party Websites and Services . We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not currently respond to or honor the DNT signal.

You can opt-out of online behavioral advertising.

• Some advertising networks we may use for these purposes may be members of the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). Please visit the websites below to learn more about interest-based advertising and to opt out of receiving personalized advertising or content from participating third-party advertising companies:
  • Digital Advertising Alliance The Digital Advertising Alliance also offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising.
  • Network Advertising Initiative
• Please note that if you opt out, you may still receive online advertising from us, but it will not be tailored to your interests based on online behavioral information about you. To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use, so you must opt out of each web browser on each computer you use. Once you opt-out, if you delete your browser’s saved cookies, you will need to opt out again.

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6. Personal Information of Minors

Our products and Services are not directed to minors under the age of 18 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors.

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7. Third Party Websites and Social Media Buttons

Our Sites may contain links to third party websites, including social media buttons that link to social media platforms. This Policy does not govern how those third parties or social media platforms collect or use personal information and we do not endorse or have control over their practices.  The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.

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8. How We Keep Your Personal Information Secure 

We implement and maintain security measures designed to protect your personal information, tailored to the nature of the personal information that we collect, use, retain, transfer or otherwise process.  However, there is no perfect security.  While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. However, data security incidents and breaches can occur due to factors that cannot reasonably be prevented. 

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9. Changes to This Policy 

We will review and update this Policy from time to time.  If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via email or a notice on our website.

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10. US State Data Consumer Privacy Rights

Laws in certain US states give residents of those states specific rights with respect to the personal information collected about them.  If you are a resident of certain states, you may have the following rights with respect to your personal information:

Your Right To Know About Personal Information We Collect

Depending on the state in which you reside, you may request the following information with respect to the personal information that we’ve collected about you in the 12 months prior to our receipt of your request:

• Specific pieces of personal information we have collected about you from you;
• Specific pieces of personal information we have collected about you from other sources;
• Categories of personal information we have collected about you;
• Categories of sources from which such personal information was collected;
• Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
• Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling your personal information.

Your Right to Request Deletion of Personal Information We Have Collected From You

Upon your request and subject to exceptions in the law, we will delete the personal information we have collected from you (this right may be limited to data we collected directly from you).

Your Right to Request to Correct Personal Information We Hold About You

You may have the right to request that we correct personal information we hold that you believe is not accurate.  We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect.  We may ask that you provide documentation regarding your request to correct to assist us in evaluating it.

Your Right to Ask Us Not to Sell or Share Personal Information We Have Collected About You

With respect to those categories of personal information that we sell to third parties or share with third parties for the purposes of cross-context behavioral advertising, you may have the right to opt out of such sales and sharing. One way you may opt out is by turning off cookies in your browser settings; please see the section on “Our Use of Cookies and Analytics,” above. Alternatively you may contact us at [email protected] for more information.

Opt-out Preference Signals

An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests.  The signal can be set on certain browsers or through opt-out plug-in tools.

Our Commitment to Honoring Your Rights

If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly.  If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others. In other words, we will not discriminate against any consumer for exercising their rights under any applicable privacy law.

Verification of Identity

We may ask you for certain personal information and attempt to match those to information that we maintain about you. If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request.  If required or if consistent with our policies and applicable law, we will notify you to explain the basis of the denial.

Authorized Agents

You may designate an agent to submit requests on your behalf.  If you would like to designate an agent to act on your behalf, we may request your agent to comply with our verification policy which we will provide on request. To submit a request as an authorized agent, please contact us at [email protected] for more information. Please note that requests made pursuant to a valid power of attorney will be processed in accordance with applicable law pertaining to powers of attorney.

Exercising Your Rights and How We Will Respond

To exercise your rights to know, delete or correct, or to opt out, contact us at 303.550.0837 or email us at [email protected]. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.  If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can direct us not to process your personal information for purposes of targeted advertising by contacting us at [email protected].

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.  In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation as to why.

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11. Text Messaging

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following the instructions provided in our communications to you.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

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Contact Us.

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

BRANCHES COMPANY, LLC d/b/a Footprints Floors
Attn: Legal
9600 E Arapahoe Road, Ste. 285
Greenwood Village, CO 80112
[email protected]