Confie Franchise Services, LLC is committed to protecting the privacy of Personal Data. This Privacy Notice only applies to Personal Data we collect and process about you in the business-to-business context, such as details we receive from prospective franchisors or our customers’ employees. This Privacy Notice does not apply to job applicants or our employees, contractors, or agents. Bluefire Insurance Services, LLC

Please read this Privacy Notice carefully. We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates.

To help you understand our privacy practices, we have provided the following brief overview covering what we believe are the key points:

• What Personal Data do we collect?We collect the following categories of Personal Data: identifiers; records about you; demographic information; commercial information; internet or other electronic network activity information; geolocation data; audio, electronic, visual, or other sensory information; professional or employment-related information; inferences, and sensitive personal information.
• How do we use Personal Data?We use Personal Data to provide you or your company with products or services; for our internal business purposes; for our internal research and product improvement purposes; for legal, safety, or security reasons; and for marketing.
• Do we sell Personal Data or share it for targeted advertising?We do not sell your personal information in the traditional sense, but we do make it available to third parties for cross-context behavioral advertising (which is commonly known as “targeted advertising” and also considered a sale in some jurisdictions) in order to provide you more relevant advertising.
• How long do we keep Personal Data?We retain personal information for as long as reasonably necessary to accomplish the purposes for which it was collected, unless we need to keep the data longer to comply with applicable law.

You can find more details about these answers below.

1. Sources of Personal Data

We collect Personal Data about you from the following sources:

1. You. We may collect Personal Data you provide to us directly, such as when you contact us through our websites and other online interactions and digital communications such as email (collectively, the “Digital Properties”), interact with us in person, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
2. Your company. We may collect Personal Data provided by your company or employer.
3. Tracking Technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
4. Third Parties. We may collect Personal Data from third parties, such as content providers, background-check providers, business partners, our affiliated companies and subsidiaries, data brokers, social media companies, or other parties who interact with us.
5. Publicly Available Sources. We may collect Personal Data about you from publicly available sources, such as social media, public profiles, and websites.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use and disclose the combined information for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data:

1. Identifiers, such as your name; email address; physical address; telephone number; other business contact information; and device identifiers (e.g., cookie IDs and IP address).
2. Records about you, such as signatures; the content, timing, and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties.
3. Demographic information, such as age (including birthdates) and gender.
4. Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; and other purchasing or consuming histories or tendencies.
5. Internet or other electronic network activity information, such as your browsing history; search history; preference information (including marketing and purchasing preferences); account settings (including any default preferences); and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see Section 5 (Cookies and Other Tracking Technologies).
6. Non-precise geolocation data, such as your approximate location based on your IP address.
7. Audio, electronic, visual, or other sensory information, such as call recordings and video recordings of our premises.
8. Professional or employment-related information, such as job title; organization; professional licenses, credentials, and affiliations; and other professional information.
9. Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
10. Sensitive personal information, such as an individual’s Social Security number, financial account number, racial or ethnic origin, immigration status, or citizenship status. We do not use or disclose this information for reasons other than those in California Privacy Protection Act Regulation § 7027(m).

3. How We Use Personal Data

We may use Personal Data for the following purposes:

1. To provide you or your company with products and services, such as making our Digital Properties, products, and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you or the company that you represent requests; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback and responding to requests, complaints, and inquiries); hosting informational webinars; making franchising decision; and providing similar services or otherwise facilitating your relationship with us.
2. For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management, and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
3. For our internal research and product improvement purposes, such as verifying and maintaining the quality and safety of our products and services; improving our products and services; designing new products and services; evaluating the effectiveness of our advertising and marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
4. For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing the spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
5. In connection with a corporate transaction, such as if we acquire assets of another business or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
6. For marketing, such as marketing our products or services or those of our affiliates. For example, we may use Personal Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe from our email or text message marketing via the link in the email, by responding “STOP” to the text message, or by contacting us using the information in Section 10 (Contact Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to others, including to the categories of recipients described below:

1. 1. Affiliates and subsidiaries, including parent entities; corporate affiliates; subsidiaries; business units; and other companies that share common ownership.
   2. Vendors that work on our behalf to provide products and services, such as IT providers; Internet service providers; web hosting providers; software service providers; data analytics providers; and companies that provide business support services, financial administration, and event organization.
   3. Professional consultants, such as accountants; lawyers; financial advisors; and audit firms.
   4. Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
   5. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we disclose information to comply with law or legal requirements; to enforce or apply our policies, terms, and agreements; and to protect our, our customers’, or third parties’ safety, property or rights.
   6. Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
   7. Business partners that may use Personal Data for their own purposes, such as:
      • Advertisers, ad platforms and networks, and social media platforms; and
      • Third parties whose cookies and tracking tools we use as described in our Section 5 (Cookies and Other Tracking Technologies) below.

Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.

We may also disclose your Personal Data to others with your consent, at your direction, or in connection with completing a transaction or otherwise providing you a service that you request.

5. Cookies and Other Tracking Technologies

Our Digital Properties and authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

1. 1. Types of cookies and tracking technologies we use

We and the third parties that we authorize may use the following tracking technologies:

1. 1. • Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
      • Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages.
      • Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
      • Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties.
   2. Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

1. 1. • Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties;
      • Improving performance, such as maintaining and improving the performance of our Digital Properties;
      • Analytics, such as analyzing how our websites are used. For example, we use Google Analytics to help us improve the user experience. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit google.com/policies/privacy/partners;
      • Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and
      • Security, such as preventing fraud and malicious behavior.
   2. Information collected

These tracking technologies collect data about you and your device, such as your IP address, location (both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

1. 1. Disclosures of your information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.

Some browsers have incorporated Do Not Track signals.  At this time, we do not honor Do Not Track signals.

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.

Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you or your company with the products and services requested and interact with you; maintain our business relationship with you or your company; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you or your company has terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, in order to demonstrate our business practices and contractual obligations, or to provide you with information about our products and services in case of interest.

7. Children’s Privacy

Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in Section 10 (Contact Information) below, and we will take prompt steps to delete the information.

8. External Links

Our Digital Properties may contain links to external sites or other online services that we do not control. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

9. Supplemental California Privacy Disclosures

This Section 9 applies to California residents.

1. 1. Data Subject Rights

You have certain rights regarding your Personal Data:

1. 1. • Right to Know. You have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you.
      • Right to Delete. You may have the right to request that we delete Personal Data that we have collected about you.
      • Right to Correct. You have the right to request that we correct inaccurate Personal Data that we maintain about you.
      • Right to Opt Out of Sales and Sharing for Targeted Advertising. You have the right to opt out of the sale or sharing of your Personal Data for targeted advertising.

California residents may exercise the Right to Know, the Right to Delete, and the Right to Correct via our webform available at privacychoices.confie.com or by calling us at 877‑214‑0149.

California residents may exercise the Right to Opt Out of Sales and Sharing for Targeted Advertising by visiting the Consent Management Platform.

To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

We will not discriminate against you for exercising your privacy rights.

Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if we need such information.

Authorized Agents: Authorized agents may exercise rights on behalf of an individual by submitting a request via our webform available at privacychoices.confie.com or by calling us at 877‑214‑0149 and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of the individual by providing signed permission from the individual. We may also require you to verify your own identity directly with us or to directly confirm with us that the individual provided the authorized agent permission to submit the request.

1. 1. Additional Data Processing Disclosures

In addition to the disclosures above, this section provides supplemental information about how we process Personal Data.

Disclosure of Personal Data

We disclose Personal Data to our Service Providers so that they can provide services for us. In the last 12 months, we have provided our Service Providers all the categories of Personal Data that we collect, as described in Section 2 (Types of Personal Data We Collect). They cannot use that information for their own purpose.

Additionally, we may disclose Personal Data to third parties or allow them to directly collect that data from our Digital Properties, as described in Section 4 (How We Disclose Personal Data). Although we have not “sold” Personal Data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a sale or sharing for targeted advertising, as those terms are defined under applicable laws.

In the last 12 months, we sold or shared for targeted advertising the following categories of Personal Data: identifiers; records about you; demographic information; commercial information; Internet or other electronic network activity; geolocation data; audio, electronic, visual, or other sensory information; and inferences. We sold or shared for targeted advertising that information to (1) advertisers, ad platforms and networks, and social media platforms; and (2) third parties whose cookies and tracking tools we use as described in Section 5.

10. Contact Information

If you have questions regarding this Privacy Notice, please contact us at: 877‑214‑0149.