Professional Commercial and Residential Window Cleaning in Naperville, IL. Licensed, bonded and insured. Request your free estimate today.

Owner:Shaun Demo

Serving:Naperville, Oswego, Aurora, Plainfield, IL

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Privacy Policy

Thank you for using this website, which is owned by Fish Window Cleaning Services, Inc. (“Fish”, “we”, “us”, or “our”). In this Policy, any use of the words “you,” “yours,” or similar expressions refers to users of this Site and our Services, as well as any other individuals whose information we collect and process. This Policy forms a binding agreement between you and Fish (each, a “Party”, and collectively the “Parties”).

Update Date: October 29, 2026
Table of Contents

1. Scope of This Policy

Fish is committed to the privacy of your information. This Privacy Policy (the “Policy”) is meant to help you understand the information we collect, why we collect it, and how you can manage it. The Policy applies only to our website at https://www.fishwindowcleaning.com/ (the “Site”) and any related products, services, or communications (the “Services”), including information collected from actual and potential franchisees as set forth in the Franchisee Information Section 17 below.
 
This Site may provide links to other websites operated by third parties, including in some cases our third-party vendors. Fish does not control these websites and is not responsible for their data practices. This Policy does not apply to third-party platforms or to other platforms owned by Fish, or extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after this Site, and which are not governed by this Policy. We are not responsible for the data protection or privacy policies of any other websites and accept no responsibility or liability for those policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.
 
 

2. Your Consent

Please take a few minutes to review this Policy before using the Site. By using the Site, by purchasing our Services, or by providing information to us in connection with a franchise opportunity or franchise relationship, you are acknowledging that you have read, understood, and accept this Policy. If you do not agree to be bound by this Policy, you must not access or use the Site.
 

3. This Policy is Part of Our Terms of Use

This Policy is part of the Terms of Use that govern your use of the Site and Services. A link to our Terms of Use is provided at the bottom of each page of the Site.

4. Types of Information We Collect

For you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services, this may include examples such as the following, which we have collected in the preceding twelve (12) months:
 

Information You Manually Provide

Fish collects information you manually provide when you use the Site and Services. For example, we collect the information you provide when you request a free estimate, provide us with feedback, ask us a question, enter or submit search terms or search queries, or otherwise interact with the Site and Services. Some of the information you manually provide may be personal information, such as your name and contact information. Also see Section 17 (Franchisee Information) for specific details about information we collect from potential and actual franchisees.
 

Transaction Information When You Purchase Services from Us

For example, if you make purchases with your credit card, we may use your credit card information for shipping, billing, and credit card validation purposes.
 

Information From Third-Party Social Media Platforms

You may be able to register with, log on to, or enhance your profile on the Site by choosing to automatically populate the requested data fields with information you previously provided to a third-party social media platform (such as Facebook or X). By doing this, you are asking the third-party platform to send us information, including personal information, from your profile on that platform.
 

Information from your browser or device

Fish collects information that is sent to us automatically by your web browser and device(s). This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings. The information we receive from your web browser and device may or may not be personally identifiable.
 

Information we obtain from third party sources

From time to time, we may receive personal information about you from third party sources, but only where we have received assurances from these third parties that they have either received your consent or are otherwise legally permitted or required to disclose your personal information to us. We use the information we receive from these third parties to provide Services to those third parties.
 

Login information

We collect information such as username and password, that you may use in connection with our Site and Services.
 

Information about your activity through our Site

Examples include your device information, such as your IP address, the type of device or browser you use, and your actions on the Site, including the search terms and search queries you enter or submit, the results or links you select, and related activity.
 

Information Collected by Cookies and Other Technologies

We may use cookies and similar technologies (e.g., web beacons, pixels, ad tags, software development kits, device identifiers, scripts, and similar tracking code) to recognize you and/or your device(s) on, off and across the Site and different Services and devices. A cookie is a small file that is placed onto your device (e.g., computer, smartphone, or other electronic device) that stores information when you visit a website. Pixels and web beacons are small graphic files or pieces of code that may be embedded in webpages, emails, advertisements, or other communications and may allow us or our service providers to receive information when you view or interact with that content, including information about your device, browser, IP address, approximate location, and activity. Similar technologies may read or place identifiers, connect activity across visits or devices, or report whether content was viewed or an advertisement was effective. However, you can control cookies through your browser settings and other tools. Depending on your jurisdiction, you can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising.
 
Fish uses cookies and related technologies on our Site to help us recognize your device as a repeat visitor and enable certain website features and functionalities. We may also use pixels, web beacons, ad tags, scripts, software development kits, and comparable technologies to measure visits, interactions, conversions, and campaign performance, to remember or associate your activity with a browser or device, and to deliver or measure advertising. These technologies may operate when you visit the Site, use the Services, open or interact with an email, or view or interact with an advertisement. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For example, we may use these technologies to:
  • collect information about your preferences and use of the Site - which pages you visit, which links you use, and how long you stay on each page;
  • support the features and functionality of the Site - for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits;
  • support security and authentication features on our Site;
  • carry out research and statistical analysis to help improve our content and Services, and to help us better understand our customers’ requirements; 
  • improve the speed and performance of our Site and Services;
  • keep track of the items stored in your shopping basket and take you through the checkout process;
  • personalize your experience when you use the Site and Services; and
  • improve our marketing efforts, including by measuring the effectiveness of emails, advertisements, and campaigns through pixels and similar technologies.
The cookies and other technologies that we place on your device may include: 
  • Essential cookies: these cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.
  • Performance cookies: these cookies collect information about how you use our Site, for example, which pages you go to most often. These cookies do not collect personally identifiable information about you. All information collected by these cookies is aggregated and anonymous and is only used to improve how our Site works.
  • Functionality cookies: these cookies allow our Site to remember the choices you make (such as your username, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites.
  • Marketing cookies: also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Those third-party cookies would be subject to the third-party service’s policies.
You can opt-out of online behavioral advertising cookies and similar technologies by using the Digital Advertising Alliance’s Consumer Choice Tool available here. Please note you may continue to receive generic or contextual ads. You may also exercise any opt-out or limitation rights available under applicable U.S. state privacy laws through the methods described in Sections 9 and 11.

Managing Cookies:

Depending on your location, you can opt-out of certain non-Essential cookies by clicking on the “Deny All” button on the cookie banner at the bottom of the Site homepage. In addition, your browser may give you the ability to control some types of cookies. If you want to customize the kinds of cookies you can control, you can change your browser settings so that certain types of cookies are not accepted. If you turn off any cookies, please be aware that you may lose some of the functionality of the Site. For more information about cookies and how to disable them please check the following resource: http://www.allaboutcookies.org/ For more information about targeted advertisements and/or to learn how to opt out of advertising cookies, please visit the below independent associations. You can visit these independent associations’ websites to opt out of all cookies served by their members. These independent websites are not sponsored by or affiliated with Fish. Browser-based opt-out preference signals, including the Global Privacy Control, may also be recognized as described in Section 10 and may apply to the browser or device from which the signal is sent, subject to applicable law.
When opting out, a cookie will be set to let advertisers know not to use your data for targeted advertising purposes. You will still see advertisements, but they will not be tailored to your interests. If you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser or mobile device from which you accessed the opt-out, unless a browser-based opt-out preference signal is recognized as applying more broadly under applicable law. If you use multiple devices or browsers, you may need to opt-out each browser or device that you use.

Consent to Use Cookies:

The first time you visit our Site, a cookie notice is displayed describing our use of cookies and linking to this Policy. As described in that notice, the cookie choices you make the first time you visit our Site will be used for your future use of the Site. Please note: By continuing to use the Site without selecting your cookie preferences, you consent to Fish using essential cookies. Non-essential cookies and comparable tracking technologies will be used only as permitted by your choices and applicable law.
 

5. How We Use Information

We will only use your personal information to provide you with information or Services you have requested, or for the purposes set out in this Policy. Generally, we use the information we collect through the Site and Services, including search terms and search queries you enter or submit and related search activity, to:
  • provide the information, products and services you request, including by responding to or using your search terms and search queries;
  • allow you to log into and access your account; 
  • process any financial transactions you make while registering for or using our Services;
  • keep your information secure such as by detecting security incidents, and to be able to verify your identity and contact information;
  • provide you with effective customer service;
  • provide you with a personalized experience when you use the Site and Services, including based on your preferences and search activity;
  • contact you with information and notices related to your use of the Site and Services;
  • alert you about product updates, special offers, updated information, and other news and services from Fish;
  • invite you to participate in surveys and provide feedback to us;
  • better understand your needs, interests, and use of the Site, including through analysis of search terms, search queries, and related activity;
  • improve the content, functionality, and usability of the Site and Services;
  • improve the Site and Services and to attract investors; and
  • improve our marketing and promotional efforts, including through the use of pixels and similar tracking technologies.
Please note that personal information does not include aggregated information from which individual identities have been removed.
 
For a description of how we use information collected from prospective, current, and former franchisees, including franchisee business information, see Section 17.

6. Data Transfers

Fish’s Site and Services are tailored for, and targeted to, users in the United States of America (“U.S.”). Because Fish is a U.S.-based company, your information may be collected and processed in the U.S. Additionally, as part of the Services offered to you through our Site, the information which we collect about you may be transferred to, and stored in, one or more countries other than where you currently reside. For example, this may occur if any of our servers or third-party service providers are located in a country other than yours. These countries may have different data protection laws that apply to personal information. However, if we transfer your information in this way, we will put in place appropriate protection to make sure your personal data remains adequately protected and is treated in line with this Policy.

7. Email Notifications

We try to keep email communications to a minimum and give you the ability to opt-out of any marketing communications we may send. For example, we may send you email relating to the Services we offer. You may also elect to receive certain marketing communications in accordance with your preferences, and from which you may opt-out at any time. You can always opt-out of receiving marketing emails or mobile device notifications from Fish (other than certain required communications, such as messages confirming orders, notifying you of any privacy policy updates, and the like) by logging into the Site and adjusting your user preferences in your account profile, or by sending us an email at privacy@fishwindowcleaning.com stating your request. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future optional notices.

8. Retention

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. For example, we may retain your data for as long as you are a customer of ours so that we may process and complete any orders you may make with us. We may also be required to hold some types of information to fulfill legal purposes. Retention of franchisee information is described in Section 17. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable.

9. Personal Information Requests for Residents of Certain U.S. States

Right to Know

Applicable U.S. state privacy laws may give you the right to request confirmation of whether we process your personal information and to access or request disclosure of the personal information we have collected about you over the past 12 months, or for another period required by applicable law. We provide this information only after we receive and validate your request. Once we receive and confirm your verifiable request, we will disclose to you:
  • The categories of personal information we collected about you;
  • The categories of personal information we have disclosed about you (if any);
  • The categories of sources for the personal information we collected about you;
  • Our business or commercial purposes for collecting that personal information;
  • The categories of third parties with whom we share that personal information; and
  • The specific pieces of personal information we collected about you, in a portable format where required by applicable law.

Right to Data Portability

You may have the right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another entity, subject to applicable law and applicable exceptions.
 

Right to Correct

You may have the right to request correction of inaccurate personal information. After we receive and validate your request, we will correct your personal information, unless an exception applies.
 

Right to Delete

You may have the right to request erasure of your personal information, subject to certain exceptions, such as when we have a legal obligation to retain the data in question. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information unless an exception applies.

Right to Opt-Out

Applicable U.S. state privacy laws may give you or, in some cases, your authorized agent on your behalf, the right to opt out of the “selling” or “sharing” of your personal information, targeted advertising based on your personal information, or certain profiling activities that produce legal or similarly significant effects concerning you (“qualifying profiling”). We do not currently use sensitive information other than as necessary to provide our Services. If you exercise an opt-out right, we may have to subsequently inform you that you need to opt-in if the sale or sharing of your personal information is required to complete a transaction you have initiated. If opting-in is required, we will provide you with the necessary instructions.
  • If you would like to request that we do not “sell” or “share” your personal information, opt out of targeted advertising or qualifying profiling, or limit the use and disclosure of sensitive personal information if and where applicable, click our cookie banner or call (877) 707-3474. If you use the telephone number, you will be guided through a process that will allow you to submit a request. 
  • If you use an authorized agent to submit your request to opt-out, we will request that the agent provide us with proof that you have authorized them to act on your behalf and may require you and/or the agent to verify the request as permitted by applicable law. 

Non-Discrimination

We will not discriminate against you for exercising rights available to you under applicable U.S. state privacy laws, including by:
  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
The rights described in this Section are subject to applicable U.S. state privacy laws, including their exceptions and exemptions, and may vary by jurisdiction. If we decline your request, you may appeal our decision where an appeal is available under applicable law by contacting us using the methods described in Section 11 and identifying the request and the reason for the appeal. We will review the appeal and inform you in writing of the outcome within the time required by applicable law. Where applicable, you may also contact the relevant state attorney general or other regulator. Our customers are entitled to access the personal information that we hold about them. To ensure that your personal information is accurate and complete, please contact us through the email address below regarding any errors or updates affecting the personal information that we may hold.

10. Your Choices

In General. We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through the Site and Services. We strive to provide choices to you at a meaningful time and in a meaningful place. This section describes some of your other choices, such as your choice to opt out of receiving non-Essential “cookies.” 
Do Not Track Mechanisms and Opt-Out Preference Signals. Your browser may deliver a “Do-Not-Track (‘DNT’) signal” to the Site or Services. Because of the changing state of technology and indecision within the technology and marketing industries regarding the meaning of DNT signals, we do not currently guarantee that the Site or Services will respond to DNT signals. We may recognize other browser-based opt-out preference signals as described below and as required by applicable law.
We will honor the Global Privacy Control (“GPC”) and other browser-based opt-out preference signals in accordance with applicable law. Where required, a recognized signal will be treated as a request to opt out of the “sale” or “sharing” of personal information, targeted advertising, and qualifying profiling, or other processing for which that signal is legally effective. A signal may apply to the browser or device from which it is sent, and we may require additional information where permitted by applicable law to associate the signal with a specific account or request.
Previously Expressed Preferences. You may change previously expressed preferences regarding how we use information you provide on or through the Site. For example, if you have provided your contact information and receive periodic emails from us, you may decide to stop receiving those emails by clicking the “unsubscribe” link in an email’s footer. You may be able to change other preferences through an account you create on the Site. Otherwise, please contact us using the information provided below to change previously expressed preferences.
 

11. How to Manage Your Information

If you created an account on the Site or Services, you may be able to access, update or correct your information through your account settings. Otherwise, you may need our help. If you reside in a jurisdiction that provides enhanced privacy rights under applicable U.S. state privacy laws, you can request confirmation or access, correction, deletion, or portability of your personal information, or opt out of or limit certain processing, including sale, sharing, targeted advertising, or qualifying profiling, as applicable, by submitting a verifiable consumer request to us by:
  • Filling out the form here, calling (877) 707-3474, or sending an e-mail to privacy@fishwindowcleaning.com including the following information along with your request: your full name, company name (if applicable), address, e-mail address, and a phone number. If you are submitting an appeal, please identify the request and the reason for the appeal. We may request that you provide additional information if necessary to confirm your identity. This is for security purposes and is required by law in some cases. 
  • Only you or an authorized agent you authorize to act on your behalf may make a verifiable consumer request related to your personal information. We may require proof of authorization and may verify your identity, the agent’s identity, and the scope of the agent’s authority as permitted by applicable law. You may also make a verifiable consumer request on behalf of your minor child.
  • We will not charge a fee for a request or appeal unless permitted by applicable law. We will respond to all validated requests and appeals within the time required by applicable law (generally within 45 days for consumer requests, subject to any extension permitted by law). If we reasonably require an extension to respond to your request, we will notify you of any such extension within the initial response period.

12. Steps We Take to Safeguard Your Information

We take the security of your personal information seriously and follow industry-standard practices to protect the data we collect and process. We maintain commercially reasonable administrative, physical, and technological measures to safeguard and secure the personal information that Fish collects, including franchisee tax returns, financial records, and other franchisee business information described in Section 17. Access to personal information will be restricted to our authorized personnel who require the information to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.
Remember, the safety and security of your information also depends on you. Where you have chosen, or where we have given you a username and password for access to certain parts of the Site or Services, you are responsible for keeping your login credentials confidential. No method of transmission over the internet or electronic storage is completely secure, so Fish cannot guarantee its absolute security.

13. How We Disclose Information

Fish does not sell or rent any of your personal information for monetary consideration, and we do not share your personal information publicly without your consent. However, we may disclose your information to certain trusted third-party services to help us provide, improve, promote, or protect our Services. Some disclosures through cookies, pixels, social media tools, advertising technologies, or similar technologies may be considered a “sale,” “sharing,” or processing for targeted advertising under applicable U.S. state privacy laws, even if no money changes hands. You may exercise applicable opt-out rights as described in Sections 9–11. Disclosures of franchisee information are described in Section 17. Examples of our disclosures are as follows.
 

With Third–Party Vendors

. Fish shares information with third-party vendors who act on our behalf. For example, we may use third-party vendors to design and operate the Site; to store our data; to conduct surveys; to process your payments; or to help us with our employee recruiting and promotional efforts. These third-party vendors may need information about you to perform their obligations. Whenever we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information to at least the same standards we do.

With our Franchisees and their Employees

. Fish may share information collected through the Site and Services with the owner of any one of our locations that you have used or in which you have expressed interest. These franchisees are permitted to share your information with their employees for the purposes of operating their business and to use your information for their own marketing purposes and in a manner otherwise consistent with this Policy. While we require our franchisees to adhere to the principles and practices outlined in this Policy when handling personal information, each franchisee operates as an independent business. As such, we do not control and are not responsible for the privacy practices of our franchisees. We obligate our franchisees, through contractual agreements, to use personal information only for the purposes permitted under this Policy and applicable law. See Section 17 (Franchisee Information) for specific details about information we collect from potential and actual franchisees.
 

With Third-Party Social Media Platforms

. We may provide functionality on the Site that allows you to automatically post information to a third-party social media platform (such as Facebook, X, or Pinterest). If you choose to take advantage of this functionality, people with access to your profile on the third-party platform will be able to see your post. Thus, you should have no expectation of privacy in those actions. Further, if you choose to link your profile on the Site with an account on a third-party social media platform, we may share the information in your profile with that third-party platform. We may also use third-party social media platforms to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by our partner company with a user on their platform. Although we do not provide any personal information to these platform vendors, they may gain insights about individuals who respond to the ads we serve. These activities may involve cookies, pixels, or similar technologies and may constitute targeted advertising or “sharing” under applicable U.S. state privacy laws. You may opt out as described in Sections 9–11.
 

In Aggregate or De-Identified Form

. We use information collected through the Site and Services to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share information with third parties about how particular individuals use the Site, but only on a de-identified basis (“De-Identified Data”). De-Identified Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively.
 

With Other, Carefully Selected Business Partners

. From time to time, we may share your information with selected third parties for their own marketing purposes. For example, we may partner with third parties to sponsor contests or other promotions, and we may share with these third parties the information you submit to us to participate in the contest or take advantage of the promotion. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law. Such disclosures may constitute “sharing,” targeted advertising, or a “sale” under applicable U.S. state privacy laws, and you may exercise any applicable opt-out rights through the methods described in Sections 9 and 11.
 

As Part of a Business Transfer

. Your information may be transferred to a successor organization if, for example, we transfer the ownership or operation of the Site and Services to another organization if we merge with or are acquired by another organization, or if we liquidate our assets.
 

To Comply With Laws and Protection of Our Rights and the Rights of Others

. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law or orders. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of others.
 

As Described in a Privacy Notice or Click-Through Agreement

. We reserve the right to disclose your information as described in any privacy notice posted on the Site, or as described in any click-through agreement to which you have agreed.
We also reserve the right to disclose personal information (including sensitive personal information) when it is reasonably necessary to conduct our business, protect Fish’s legal rights and property, and to comply with the law or orders. We process sensitive personal information only as permitted by applicable law and, where required, after obtaining consent or (if applicable) providing an opportunity to limit its use or disclosure. Otherwise, except as described in Section 17, your personal information is not shared with any individual or other organization.

SMS consent and phone numbers provided for SMS purposes will not be shared with any third parties or affiliates for marketing purposes. If you are receiving SMS communications from us, you may reply STOP at any time to opt out of further messages. If you reply HELP, you will receive a message with additional assistance and a link directing you to our Privacy Policy for more information about how your data is handled.

14. Children Under the Age of Sixteen

We are proud of the Site and we strive to ensure that it doesn’t offend people of any age. However, the Site is not intended for children or minors under the age of sixteen (16) years without the permission of a parent or guardian. Fish does not knowingly solicit or collect any personal information from anyone under 16 years of age, and children under 16 are not permitted to register for or use our Site or Services, including by subscribing to receive information from Fish. If you believe that a child has submitted personal information on or through the Site without the consent and supervision of a parent or guardian, please contact us using the information provided below so that we can take appropriate action. If we become aware that a child under the age of 16 has provided us with personal information, we will delete it.

15. This Policy May Change

We are continually improving and adding to the features and functionality of the Site and Services. As a result of these changes (or changes in the law), we may need to update or revise this Policy from time to time. If we do, we’ll let you know about any material changes, either by notifying you on the Site or by sending you an email. Any updates to this Policy will not apply retroactively. Your continued use of the Site or Services after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy.

16. Contact Us

If you have any questions regarding this Policy, or if you are not completely satisfied with this Policy or its application by us, please contact us at:
Fish Window Cleaning Services, Inc. 
217 Chesterfield Towne Centre
Chesterfield, Missouri 63005
Telephone: 636-530-7334
If you have an applicable disability, you may also contact us at the above email address to request access to this Policy in an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken to address your concern or implement the suggestion.

17. Franchisee Information

This section of the Policy applies to all personal information that Fish collects, receives, or processes in connection with franchise development, franchise sales, franchise application activities and management of the franchise relationship. The individuals covered by this section include: (a) prospective franchisees who inquire about or express interest in a Fish franchise opportunity; (b) individuals who submit a formal franchise application or complete a franchise qualification process; (c) representatives, agents, officers, directors, partners, members, or other principals of prospective franchisee entities whose personal information is provided to Fish; and (d) current and former franchisees, and the owners, guarantors, officers, directors, partners, members, managers, and other principals and representatives of current and former franchisee entities. For purposes of this section, “you” and “your” refer to these covered individuals. This section also describes the business information Fish collects from franchisee entities during the franchise relationship, as described under “Franchisee Business Information Collected During the Franchise Relationship” below.
 
This section supplements, and should be read in conjunction with, the Fish general Policy terms above. To the extent there is a conflict between this section and the general Policy regarding franchisee information, this section controls.
 

Categories of Personal Information Collected and Sources

In the course of franchise development, franchise sales, and management of the franchise relationship, Fish may collect the following categories of personal information, which may constitute “personal data” as that term is defined under applicable state privacy laws:
 
Identifiers and Contact Information. Full legal name, mailing address, email address, telephone number, date of birth, Social Security number or taxpayer identification number, driver’s license or state identification number, and citizenship or immigration status. These identifiers may be used to determine whether an individual can be readily identified, directly or indirectly, for the purposes of franchise qualification.
 
Financial and Business Information. Net worth statements, personal and business tax returns, bank and brokerage account statements, credit history, proof of liquid capital, sources of funding, and prior business ownership or franchise experience. This information is collected to evaluate the financial qualifications of prospective franchisees and their ability to meet the investment requirements disclosed in the FDD.
 
Professional and Employment Information. Current and prior employment history, professional references, educational background, and professional licenses or certifications. Where a prospective franchisee is an entity such as a corporation, partnership, limited liability company, association, joint venture, or other legal or commercial entity, Fish may collect information about the entity’s principals, officers, and owners.
 
Litigation and Regulatory History. Information regarding pending or prior civil, criminal, or administrative proceedings, including bankruptcies, that are required to be disclosed by the franchisor or the prospective franchisee under the FTC Franchise Rule.
 
Background Check and Due Diligence Information. Information obtained through third-party background investigation providers, including criminal history, civil litigation records, credit reports, and public records searches, where authorized by the prospective franchisee.
 
Communications and Correspondence. Records of communications between the prospective franchisee and Fish’s franchise development team, including emails, call logs, meeting notes, questionnaire responses, and webinar or seminar attendance records.
 
Sources of Personal Information. Fish collects personal information directly from prospective franchisees (e.g., through franchise inquiry forms, applications, interviews, and correspondence), from third-party sources (e.g., background check providers, credit reporting agencies, and references), and from publicly available records.
 

Purposes of Collection and Use

Fish collects and uses personal information in the franchise development and management of the relationship for the following purposes:
 
Franchise Evaluation and Qualification. To assess whether a prospective franchisee meets Fish’s financial, experiential, and operational criteria for franchise ownership, including evaluation of the individual’s or entity’s suitability as a franchisee.
 
FDD Disclosure Compliance. To fulfill Fish’s obligations under Federal and applicable state franchise registration and disclosure laws, including the preparation and delivery of the FDD and any state-specific addenda.
 
Regulatory Compliance. To comply with federal, state, and local laws, regulations, and regulatory requirements governing the offer and sale of franchises, including franchise registration, filing, and exemption requirements.
 
Pre-Sale Due Diligence. To conduct background investigations, verify financial representations, and confirm the accuracy of information provided by prospective franchisees in their applications and supporting documentation.
 
Communications and Relationship Management. To respond to inquiries, schedule meetings, provide information about the franchise opportunity, and manage the franchise sales process.
 
Recordkeeping. To maintain records as required by law, including records of FDD delivery, receipts, and related franchise sales documentation.
 

Franchisee Business Information Collected During the Franchise Relationship

After a franchise agreement is signed, and for as long as the franchise relationship continues, Fish may collect information from franchisees and franchisee entities in the ordinary course of business, including through required computer and software systems. This information is collected under the franchise agreement, the operations manual, and other agreements between Fish and the franchisee. Much of it is information about the franchised business rather than about an individual. However, some of it may identify, or be linked to, individual owners, guarantors, employees, or customers, and when it does, we treat it as personal information under this Policy. The types of franchisee business information we may collect include:
 
Tax Returns and Financial Records. Federal, state, and local business tax returns and related schedules; profit and loss statements, balance sheets, and other financial statements (whether reviewed, audited, or unaudited); general ledgers; gross sales and revenue reports; royalty, advertising fund, and other fee reports; sales and use tax filings; payroll summaries; bank statements; loan and financing documents; and other books and records of the franchised business. Where a franchisee is an individual or a pass-through entity, or where an owner has given a personal guaranty, these records may include personal tax and financial information of the franchisee’s owners or guarantors.
 
Operational and Performance Data. Sales, job, and transaction data; customer lists and customer service records; scheduling, pricing, and estimate data; key performance indicators and benchmarking data; marketing and advertising activity; information about employees and staffing levels; vehicle, equipment, and inventory information; and other data generated through point-of-sale, customer relationship management, scheduling, accounting, and other systems franchisees are required to use.
 
Compliance and Legal Records. Certificates of insurance; business licenses and permits; entity formation, ownership, and good-standing documents; information about transfers of ownership interests; results of inspections, audits, and field visits; training and certification records; records of complaints, claims, and incidents; and information about any litigation, government proceedings, or regulatory matters involving the franchised business or its owners.
 
How We Use Franchisee Business Information. Fish uses franchisee business information to: calculate, invoice, and verify royalties, advertising fund contributions, and other fees; conduct audits and confirm the accuracy of reported sales; monitor compliance with the franchise agreement, the operations manual, and brand standards; provide training, field support, and business coaching; benchmarking; evaluate the financial health and performance of individual franchised businesses and the franchise system as a whole; review requests for renewals, transfers, additional territories, and financing; assist in franchise sales; prepare the FDD and meet other franchise registration and disclosure requirements; develop and improve products, services, marketing programs, and systems; enforce our agreements and protect our legal rights; and comply with applicable laws, regulations, and legal process.
 
How We Disclose Franchisee Business Information. Fish does not sell or share franchisee business information. We may disclose it to: (a) our accountants, auditors, attorneys, lenders, insurers, and other professional advisers; (b) third-party vendors that host, process, or analyze data on our behalf, including providers of the computer systems franchisees are required to use, subject to confidentiality obligations; (c) our affiliates; (d) franchisor-approved lenders or financing sources, but only at the franchisee’s request or with the franchisee’s consent; (e) a prospective buyer of a franchised business, with the franchisee’s consent, as part of a proposed transfer; (f) franchise regulators and government authorities as required by law, including in FDD filings; (g) in connection with a merger, acquisition, or other business transfer as described in Section 13; and (h) as needed to enforce our agreements, respond to legal process, or protect our rights or the rights of others. We also may disclose benchmarking and other information to other franchisees and such information may be identifiable or may be aggregated.
 
Retention of Franchisee Business Information. Fish keeps franchisee business information for the term of the franchise agreement and for as long afterward as needed to complete audits, resolve disputes, enforce post-termination obligations, meet FDD and franchise recordkeeping requirements, and comply with tax and other legal retention periods. When the information is no longer needed for these purposes, we will securely destroy it or de-identify it. Tax returns and financial records are protected by the security measures described in Section 12, and access to them is limited to personnel and service providers who need them for the purposes described above.
 

Disclosure of Existing Franchisee Contact Information to Prospective Franchisees

Under the FTC Franchise Rule, Fish must disclose certain information about its existing and former franchisees, including the names, addresses, and telephone numbers of current franchisees and franchisees who have left the system within the preceding fiscal year. This disclosure is made to prospective franchisees as part of the FDD delivery process as required by applicable law.

Fish discloses the contact information of existing and former franchisees to prospective franchisees solely for the purpose of enabling prospective franchisees to contact existing and former franchisees as part of their own due diligence investigation of the franchise opportunity, as contemplated by the FTC Franchise Rule. Fish does not authorize the use of such contact information for any other purpose, including marketing, solicitation, or resale.
 

Rights Under the CCPA and Comparable State Privacy Laws

Depending on your state of residence, you may have certain rights set forth in Section 9 above regarding your personal information. The applicability of these rights to prospective franchisees, franchisees, and their principals may depend on whether the individual is acting in a personal or commercial capacity under the relevant statute, as certain state privacy laws exclude individuals acting in a commercial or employment context from the definition of “consumer.” These rights generally do not apply to information about a franchisee entity, and they may be limited where Fish must retain records under the franchise agreement or applicable law.
 

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