Effective Date: November 6, 2017

Global Franchise Group®, LLC and its subsidiaries (collectively, “GFG” or “we”) have developed this Privacy Policy to explain why we collect particular information and how we will protect your personal privacy within our brand websites for Great American Cookies®, Pretzelmaker®, Marble Slab Creamery®, MaggieMoo’s Ice Cream & Treatery®, Hot Dog on a Stick® and Round Table Pizza®, found at Great American Cookies Website, Pretzelmaker Website, Marble Slab Website, MaggieMoo’s Website, Hot Dog on a Stick Website, and Round Table Pizza Website and Global Franchise Website (the “Sites”). This Privacy Policy is applicable both to information collected from our customers and other visitors to the Sites and to those desiring information about or submitting applications to become GFG franchisees. Specific information regarding our collection and use of franchisee applicant information is found at the end of this Privacy Policy under “GFG Franchisee Information.” This Privacy Policy is incorporated into and subject to the Terms of Use. Each time that you use the Sites, you signify that you agree to be bound by the Terms of Service and this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you must discontinue using the Sites and accessing the services (“Services”) through the Sites. This Privacy Policy is applicable only to our collection of information on the Sites and does not describe our offline data practices.

Summary Description of this Privacy Policy

• We do not sell or rent your information to third parties (other than in the unlikely event of a corporate transaction involving a sale or disposition of our company). If you purchase a product on the Site, your information will be shared with the third party franchisee of the store that you select to fulfill your order.


• If you provide us with your email address on the Sites, you will receive offers and promotions from GFG, but you may opt out of these communications at any time.


• We strive to provide visitors to the Sites with control over use of their personal information, including ability to update their account information and control their communications preferences, as well as control over any sharing over social networking media.I. INFORMATION WE COLLECTUser Provided Information. We collect personal information from you when you submit information to or register for an account on any of the Sites. You may subscribe to receive offers and other information from any particular Site by submitting your name, email address and birth month and day to that Site. In order to purchase products on a Site, you may register for an account by providing your name, address, phone number and email address, and selecting a password. From time to time we may ask you to respond to surveys or other requests for information and, we collect the information you provide. We may collect information from you when you submit queries to customer service, order products online, or participate in sweepstakes, games or other promotions offered on our Sites. We may also collect information about you through other methods, including research surveys or information we obtain from third parties, including verification services, data services, as well as public sources. We use this information to continually offer you the most value as a visitor to our Sites.Web Logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) in order to improve security, analyze trends and administer the Sites. We may track your movement within the Sites, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the internet address from which you linked to our Sites, the operating system of your computer, the unique IP address of the computer you used to access our Sites, and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness of our Sites, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.
  
  Cookies. To help make sure you receive information that is relevant to you, our Sites use data “cookies.” We use session cookies to make it easier for you to navigate our Site. A session ID cookie expires when you close your browser. We use persistent cookies to differentiate visitors to our Sites from registered users, to customize the content of certain sections of the Sites and to enable us to track and cater to the interests of users, in order to enhance their experience on the Sites. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Cookies help us learn which areas of our Sites are useful and which areas need improvement. We will not use cookies or other data capture mechanisms to collect any personally identifiable information about you. You may configure your browser to prevent cookies from being set on your computer. If you reject cookies, you may still use the Sites, but your ability to use some areas of the Sites may be limited, and you may not be able to use certain features of the Sites.
  
  Web Beacons. Our web pages and emails contain “web beacons.” Web beacons allow us to count users that have visited a web page or opened an email that contains a web beacon and collect other types of aggregate information. Using this information, we are able to measure the effectiveness of our advertising and how visitors use our Sites. This allows us to learn what pages are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see. Some of the web beacons that are in place on our Sites are used only by us, and other web beacons are from our service providers who use this data to assist us in analyzing how our Sites are used.
  
  II. HOW WE USE YOUR INFORMATION
  
  Store Locators and Product Orders. Users may submit their zip codes in order to use our Sites’ Store Locator function. This information is used to direct the user to our nearest physical location. Information you submit in order to purchase products on the Sites is used to communicate with you and carry out the actions you request on the Site. This information may be shared with the third party franchisee operating the store that you select to complete your order, in order to communicate with you and otherwise facilitate your order. Payment information, such as credit card information, is used to make payment on your order and is not stored on a permanent basis.
  
  Service Providers. We may use third party service providers to help us operate our business and the Sites or administer activities on our behalf, such as sending emails, processing orders, order fulfillment and sweepstake administration. We may share your information with these third parties for those limited purposes. These third parties are required to maintain the confidentiality of information they receive from us and are restricted from using the information for any purposes other than those authorized by us.
  
  Other Uses: We collect and use personal information in the specific ways listed above, and generally to improve our Sites and services to you, as well as to meet our legal obligations. We also use personal information you provide to verify your identity, to collect upon unpaid accounts, to handle and settle inquiries or disputes. We may use your personal information to contact you about the services on our Sites for which you have expressed an interest, for example, if you have contacted customer service or made an inquiry. We may contact you to determine your satisfaction with ordering products through our web site via e-mail or phone.
  
  Communications. We may send you service-related announcements and emails from time to time. We may also use your information to send you updates and communications about our products and services. To opt-out of our email programs, you can click “unsubscribe” on the bottom of any of our e-mails. To opt-out of emails you may receive on one of our Facebook applications, you may (i) Update your Facebook Application Settings by visiting Facebook Apps, finding the application name, clicking “Edit Settings” and then unchecking “Receive updates to my Facebook contact email address” or (ii) Click the opt-out link in the body of the email.
  
  Sweepstakes and Contests. On occasion, we offer sweepstakes, contests and other promotions. By participating in a promotion, you submit to that promotion’s terms and conditions including providing us with permission, if required, to share your personally identifiable information with any state’s filing requirements for winners of prize promotions.
  
  Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Service, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat.
  
  Sale or Transfer of Business or Assets. In the event that we, or any of our subsidiaries or businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information of our visitors may be one of the assets sold or merged in connection with that transaction. Information about our visitors may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding. In such transactions, personal information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.
  
  III. CHOICE AND OPT OUT
  
  You can choose not to receive promotional messages in the future by either following the “unsubscribe” instructions located near the bottom of each email, or by emailing us at privacy@gfgmanagement.com or sending postal mail to the following address:
  
  Global Franchise Group, LLC
  5555 Glenridge Connector Suite 850
  Atlanta, GA 30342
  
  Please note, changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personally identifiable information removed from our database. We will endeavor to comply with your request as soon as reasonably possible. Note that despite any request for removal of or change to personally identifiable information, we may need to retain certain information for recordkeeping purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. Finally, we are not responsible for informing third parties (including without limitation our third party service providers or strategic partners) with whom we have already shared your personally identifiable information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
  
  IV. ACCESS TO YOUR INFORMATION
  
  If you are a registered user on any of our Sites, you can update your information at any time. To do this, just log in under “My Account” on the relevant Site and update your personal information as needed. You may also contact us to correct or modify the information you provide through the Sites. If for any reason you are concerned that the personal information you provided to us is not correct and you cannot change it by accessing your account, or should you wish to have your email address removed from our mailing list or contact information changed, please contact us at privacy@gfgmanagement.com. We will be happy to review, update or remove information as appropriate. We may still retain your information in our files however, to resolve disputes, enforce our Terms of Use, and due to technical and legal requirements and constraints related to the security, integrity and operation of our Sites.
  
  V. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
  
  Links to other sites. The Sites may contain links to other sites that are not operated by GFG. GFG IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF SUCH OTHER WEBSITES, INCLUDING WEBSITES OPERATED BY INDEPENDENT OR AFFILIATED FRANCHISEES. We provide such links only as a convenience and the inclusion of a link on the Sites does not imply endorsement of the linked site by GFG. If you provide any personally identifiable information through any such third party website, your transaction will occur on such third party’s website and the personally identifiable information you provide will be collected by and controlled by the privacy policy of that third party and is not subject to this Privacy Policy. We recommend that you check the privacy policies of these sites to determine how your personal information will be utilized by the proprietors of those third party sites.
  
  Security. The Sites have reasonable security measures in place to protect the loss, misuse and alteration of the information under our control. When you submit sensitive information via our Sites, such as credit card or other financial information, that information is subject to secure sockets layer (SSL) encryption technology. However, no data transmission over the Internet can be guaranteed as 100% secure. As a result, while we strive to protect your personal information during transmission, we cannot ensure or warrant the security of any information you transmit to us or receive from us. We urge you to take steps to keep your personal information safe (including your account password), log out of your account after use, and close your web browser.
  
  A Note to International Users. By consenting to this Privacy Policy, you confirm that your command and knowledge of English is sufficient to understand the terms and conditions set forth herein. You agree that by using the Sites, your personal data will be transferred to our servers located in the United States in connection with the purposes stated in this Privacy Policy. You understand that the laws with respect to the protection of personal data in the United States may not be as stringent as those in your home jurisdiction and the Sites may not comply with foreign law, so if you do not agree with this, please do not use the Sites.
  
  California Privacy Rights. If you are a California resident, you may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write to us at the address above in “Contacting Us”.
  
  Children’s Privacy. The Sites are not directed or intended for children under 13 years of age. We do not knowingly collect personal information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide personal information on the Sites. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user’s personal information from our systems. If you are the parent or guardian of a child whom you believe has disclosed personal information to us, please contact us at privacy@gfgmanagement.com so that we may delete and remove such child’s information from our systems.
  
  Changes to the Privacy Policy. We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on the Sites, with the “Effective Date” posted at the top of the Policy. We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal information, you will know because the Effective Date of the Privacy Policy will change. If we are going to use any personal information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By using our Sites or our services after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the privacy policy in effect when the information was obtained from you.
  
  Disputes. If you choose to visit the Sites your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use including limitations on damages, arbitration of disputes, and application of the laws of the State of Georgia.
  
  Contacting Us. If you have any questions about this Privacy Policy, or the practices of the Sites, please visit our Contact Page or write to us at:
  
  Global Franchise Group, LLC
  5555 Glenridge Connector Suite 850
  Atlanta, GA 30342
  Phone: (770) 514-4500
  
  VI. GFG FRANCHISEE INFORMATION
  
  Visitors to the Sites who may be interested in receiving information on becoming a franchisee of any of our brands may visit the “Franchise Info” portion of our Sites, which directs the visitor to the Global Franchise Website (“Franchisee Site”).
  
  Information We Collect. Visitors to the Franchisee Site may request franchise information in addition that available on the Franchisee Site by completing the Express Request Form found under “Request Franchise Information” for each brand. The Express Request Form requires the name, address, email address, and phone number of interested parties, along with information relevant to franchise opportunities such as net worth, available investment amount and preferred location.
  
  Site visitors desiring to apply for a GFG franchise may complete the Franchise Application located on the Franchisee Site. This application by necessity requires the submission of a considerable amount of personal information, including personal financial information, including without limitation: name, address, email, birthdate, Social Security Number, spouse’s name, birthdate and Social Security Number, financial asset descriptions and amounts, information regarding citizenship or resident alien status, employment history, criminal record, and information relative to credit history such as past or current bankruptcy or litigation.
  
  How We Use Your Information. The information you submit on the Franchise Application is provided under Secure Socket Layer (SSL) encryption. We may also collect information about you from third party public and private sources, including those that you consent to as part of the Franchise Application (namely, reference checks, credit reports, criminal and other investigative reports). As enhanced by these sources, the personal information you provide is used internally by GFG to assess your fitness to obtain a GFG franchise and to communicate with you throughout the process. In the process of acting upon an application, we may disclose to an employment or other reference provided by you or described in your employment history that you have made an application for a franchise. The information provided as part of the Franchise Application will not be sold or shared with third parties, and will be held and protected as stated generally in this Privacy Policy for all personally identifiable information collected by us.
  
  Should you desire to withdraw an application for a GFG franchise, amend your prior application, or have your personal information deleted from our systems, please contact us as noted above under “Contact Us,” and we will act upon your request as appropriate. Please note, however, that in certain circumstance we may still retain your information in our files in order to resolve disputes, enforce our Terms of Use, or due to technical and legal requirements involving our information systems and operations.
  
  (c) 2017 Global Franchise Group, LLC