Privacy policy

FranShares, Inc.

Last Updated on January 8, 2025

Your privacy is important to us. This Privacy Policy (this “Policy”) applies to services provided by FranShares, Inc. (“we,” “us,” “our” or “FranShares”), as well as our affiliates and subsidiaries, and to our website (the “Site”), mobile app and/or other platform(s) (collectively, the “Services”). It explains what information we collect from users or visitors of our Services (each, a “user,” “you” or “your”), including information that may be used to personally identify you (“Personal Information”) (e.g., your name, e-mail address, telephone number, home address) , and how we use, share, safeguard, and retain it. This Policy also outlines your rights and choices regarding your Personal Information and describes our compliance with applicable U.S. federal and state privacy laws, including the Gramm-Leach-Bliley Act (“GLBA”) and relevant state laws such as the California Consumer Privacy Act (“CCPA”), as well as other emerging state privacy regulations.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. THE TERMS OF THIS PRIVACY POLICY CREATES LEGAL OBLIGATION FOR YOU AND FOR US.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT VISIT OUR SITE OR UTILIZE OUR SERVICES

We will be the controller of your personal data provided to, collected by or for, or processed in connection with our Services. We are committed to protecting your Personal Information in accordance with applicable laws, regulations, and industry best practices. We strive to implement data protection by design and by default throughout our processes, products, and services, and to collect only the data that we need for our legitimate business purposes (data minimization).

We reserve the right, at our sole discretion, to modify and/or change this Policy, and to add new or additional terms or conditions, without notice, at any time. Such modifications and additional terms and conditions will be effective immediately and incorporated into this Policy.   It is your responsibility to check this Policy periodically for updates. Your continued use of our Services following the posting of any modifications of, or additions to, this Policy constitutes acceptance of those changes and it means that our collection, use, and/or sharing of your Personal Information is subject to the updated Policy. You are advised to periodically review the Site for any changes and/or contact your legal advisor with any questions

What Information Do We Collect?
We collect various types of information, including Personal Information, to provide and improve our Services, ensure compliance with legal requirements, and better understand your needs. We practice data minimization by only collecting the information necessary for specific purposes, and we strive to protect the confidentiality and security of all such information.

Information Provided by You:
We collect information that you knowingly give us when you create an account, contact us, or otherwise access or use our Services. This may include:

• Identifiers such as your full name, email address, residential address, citizenship, telephone number, Social Security number, driver’s license number, date of birth, employment information (including status and employer information, if applicable), and information regarding investor “accreditation” and suitability.
• Financial Information such as details of any financial transactions you participate in on the Services, including payment information (bank account numbers, credit card numbers) and transaction history.
• Business-Related Information such as your business title, business name, and number of business locations, if applicable.
• Survey Responses and Social Media Information such as responses to surveys we may ask you to complete, which help direct FranShares activities, and information from social media accounts if you choose to connect them.

Information Collected Automatically:
We automatically or passively collect certain information when you access or use our Services, including: 

• Online Activity and Usage Information such as your device type (computer or mobile device), operating system, application version, internet protocol (IP) address, click path through our website, browsing history, and interactions with features or applications on our website.
• Unique Device and Advertising Identifiers such as mobile platform advertising identifiers (e.g., Apple’s Identifier for Advertising or Google’s Android Advertising ID).
• Geolocation Data if you access our Services from a mobile device and have enabled location services.
• Use of Third-Party Platforms, such as information you provide to third-party providers and third-party platforms associated with your use of the Site or the Services.

If we associate this automatically collected data with you as an identifiable person, we will treat it as Personal Information.

How Do We Use the Information We Collect?
We use the information we collect to:

• Provide and Improve the Services and User Experience: We use your information to create, maintain, customize, and improve your user experience, tailor content, and analyze usage patterns.
• Identity Verification and Compliance: We use Personal Information to verify identity, meet legal and regulatory obligations (e.g., anti-money laundering and “Know Your Customer” protocols), and comply with applicable laws such as the GLBA.
• Processing Transactions: We use financial and Personal Information to facilitate your transactions, process payments, and provide you with related services.
• Preventing Fraud and Security Threats: We use Personal Information and usage data to detect, prevent, and address fraud, unauthorized activity, and illegal conduct.
• Marketing and Communication: We may use your contact information to send you promotional messages, newsletters, product updates, and other marketing communications, if you have not opted out.
• Retargeting and Remarketing: We may use hashed email addresses, pages you visited on our Site, and other necessary data, as well as your browsing behavior, to show you relevant advertisements on third-party websites and social media platforms. For example, if you visit our Site, we may later show you ads elsewhere online; or if you are on our email list, we may use a hashed version of your email address to serve you ads on certain social media platforms.
• Customer Support: We use your information to respond to your comments and questions and to provide assistance and service-related communications.
• Analytics and Aggregated Data: On a de-identified, aggregated basis, we analyze how you use the Services to understand traffic patterns, measure promotional effectiveness, and address technical issues.
• Legal and Regulatory Compliance: We may use your Personal Information to comply with legal, accounting, and regulatory obligations, and as otherwise required or permitted by law.

Do We Share Your Personal Information?
We do not rent, sell, or share your Personal Information with third parties except with your consent or as outlined in this Policy and permitted by applicable law. In connection with the Services, we may provide your Personal Information to:

• Partners and Affiliates: We may share your Personal Information with our broker-dealer, affiliates, Registered Investment Portals, partners and/or subsidiaries as needed to deliver the Services. They will not have independent use of it beyond what is necessary to assist us.
• Service Providers: We work with a range of third-party service providers (e.g., database administrators, cloud computing services, payment processors, identity verification services, advertising and analytics providers) who process Personal Information on our behalf. These providers must adhere to strict confidentiality and security measures. For example, we may share hashed email addresses or device identifiers with advertising platforms to assist in serving you with targeted advertising and remarketing campaigns.
• Business Partners: We may share limited information with business partners who offer complementary financial products or services, provided such sharing complies with applicable law and, where required, with your consent.
• Governmental Authorities or as Required by Law: We may share Personal Information to comply with any applicable law, regulation, legal process, or governmental request, including responding to subpoenas, court orders, and lawful requests by public authorities. We may also share Personal Information to protect our users’ rights, safety, and property, or the rights, safety, and property of others.
• Corporate Transactions: We may transfer your Personal Information as part of a merger, acquisition, reorganization, or similar transaction. We will notify you and, if required by law, request your consent before your data becomes subject to a different privacy policy.

Any third party with whom we share your Personal Information is required to provide the same or equal protection of such data as stated in this Policy.

How Do We Use Tracking Technologies?
We, or third parties we do business with, may use cookies, pixel tags, and similar tracking technologies to analyze our web page flow, customize our services, content, and advertising, measure promotional effectiveness, and promote trust and safety. We may also use these technologies to retarget and remarket our Services to you across third-party websites and platforms, including by using hashed email addresses, pages visited on our Site, or other necessary data.

You can prevent or limit cookies by adjusting your browser settings. Note that disabling cookies may adversely affect certain functionalities of our Services. By using the Services without changing your browser settings to refuse cookies, you consent to our use of these technologies as described in this Policy.

We may use web beacons to track traffic patterns and help determine how you found our Services. Our third-party advertising and analytics service providers may also use these technologies.

Examples of Third-Party Services (Non-Exhaustive):

• Google Analytics for audience measurement and analytics
• Facebook Pixel, LinkedIn Insights, Twitter Ads, and other social media advertising tools for retargeting/remarketing
• Email marketing and CRM platforms for managing communications and campaigns

We may update or change these providers over time, and this list should not be considered exhaustive.

How Do We Secure Your Personal Information?
Your account is protected by a password to help protect against unauthorized access. You are responsible for selecting a strong password and for keeping it confidential.

We employ physical, electronic, and procedural safeguards to protect your Personal Information, including:

• Encryption: We encrypt data we store and transmit data over secure connections (HTTPS).
• Access Controls: We limit access to Personal Information to authorized employees, contractors, and third parties who need it to operate or improve our Services. Strict identity verification and authentication protocols are followed.
• Regular Security Assessments: We regularly review and update our security measures, conduct vulnerability scans, and perform penetration testing.
• Employee Training: We train our personnel on data security best practices and the importance of protecting Personal Information.

While we take reasonable measures to protect your Personal Information, no security system is foolproof. If you believe your information may have been compromised, please contact us immediately at support@franshares.com.

Data Breach Notification:
In the event of a data breach, we will notify affected users as soon as reasonably possible and in compliance with applicable laws and regulations. Such notification will include the nature of the breach, the types of information involved, steps we have taken to secure the data, and measures you can take to protect yourself. We will also meet any applicable notification obligations under state or federal laws, including the GLBA, and report qualifying incidents to regulatory authorities as required.

Your Choices Regarding Information

Changing or Deleting Your Personal Data:
You may review, update, correct, or delete Personal Information that you have provided by contacting us at support@franshares.com or, in certain instances, by accessing your user account. We may verify your identity before making changes to or deleting Personal Information. If you completely delete all of your Personal Information, your user account will be deactivated. If you cancel your account, we will delete or anonymize your Personal Information as soon as reasonably practical, consistent with legal, regulatory, contractual, and operational requirements.

Data Retention:
We retain your Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected, and as required by applicable legal, regulatory, contractual, or operational obligations. We periodically review our data retention practices to ensure they remain appropriate and aligned with our obligations. Once the data is no longer needed, we dispose of it securely. We may retain anonymized or aggregated data indefinitely for research and analytical purposes.

Download or Access Personal Information:
You can request a copy of your Personal Information, including a machine-readable copy, by emailing us at support@franshares.com. We will respond as required by applicable law.

Opting Out of Email Communications and Targeted Advertising:
If you no longer wish to receive marketing or promotional emails, you can opt out by following the unsubscribe instructions in those emails or by contacting us at support@franshares.com. Even after opting out of marketing communications, we may still send you service-related notices.

For targeted advertising, you may limit the use of certain identifiers (such as cookies or advertising IDs) by adjusting your device and browser settings, using industry opt-out tools described above, or contacting us at support@franshares.com for more information.

Links to Third-Party Websites
Our Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of these third-party websites. They have their own terms of use and privacy policies. By using our Services, you acknowledge that we are not liable for any damage or loss related to your use of these external sites.

How We Respond to Do Not Track Signals
We do not currently alter our practices in response to “Do Not Track” signals. While some of the tracking we do is essential to provide and improve our Services, we do understand users may want to limit certain types of tracking. You can manage cookies and similar technologies through your browser settings and industry opt-out tools described in this Policy. Please note that limiting tracking may affect some functionality of our Services.

Third-Party Direct Marketing
We do not share your Personal Information with third parties for their direct marketing purposes without your consent.

A Note to Users Outside the United States
FranShares is based in the United States and our Services are primarily intended for U.S. residents. If you access or use our Services from outside the United States, please be aware that your Personal Information may be transferred to and processed in the United States or other countries where we or our service providers operate. These countries may have data protection rules that differ from those of your country.

If we collect or process your Personal Information from regions that impose data protection obligations (such as the European Union), we will rely on appropriate legal bases, implement suitable safeguards (such as Standard Contractual Clauses or other recognized transfer mechanisms), and comply with any additional applicable requirements for international data transfers, in accordance with industry best practices.

Children
We do not knowingly collect or solicit Personal Information from children under the age of 18. If you are a parent or guardian who believes your child has provided us with Personal Information without your consent, please contact us at support@franshares.com. We will promptly delete such information.

Notice to California Residents – Your California Privacy Rights
California residents have certain rights regarding their Personal Information under the California Consumer Privacy Act (CCPA), as may be amended by the California Privacy Rights Act (CPRA). If you are a California resident, you have the right to:

• Know what Personal Information we collect, use, disclose, and sell.
• Access a copy of your Personal Information.
• Request deletion of your Personal Information, subject to certain exceptions.
• Opt out of the sale or sharing of your Personal Information, if applicable.
• Not be discriminated against for exercising these rights.

To exercise your rights, please contact us at support@franshares.com with “California Privacy Rights” in the subject line. We will verify your request as required by law before making any changes. You may also designate an authorized agent to make requests on your behalf.

Your Other State Privacy Rights
Residents of certain other states (including but not limited to Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia) may have additional privacy rights under their respective state laws, which may include rights similar to those afforded to California residents. If you reside in a state with applicable privacy legislation and would like to exercise your rights, please contact us at support@franshares.com.

We are committed to complying with all applicable state privacy laws and will adjust our practices and this Policy as new privacy laws come into effect.

Contact Information
If you have any questions or concerns about this Policy, or if you wish to exercise your data privacy rights, please contact us at:

FranShares, Inc.
405 W Superior Street, #93
Chicago, IL 60654
Email: support@franshares.com

Updates to This Policy
We may update this Policy from time to time to reflect changes in our Services, practices, or legal requirements. We will notify you of any material updates by posting a prominent notice on our website or by emailing you. Changes will take effect immediately upon posting or as otherwise stated in the notice. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.