U.S. Privacy Policy
Last Updated: 12/18/2024
This Privacy Policy (“Privacy Policy” or “Policy”) explains how California Closet Company, Inc. and its corporate affiliates ( “we,” or “us,” or “our”) collect personal information based on your interactions with us online and offline, including on our websites, applications, forums, blogs (collectively the “Sites”), other online offerings, when we provide services or offer products online or offline (collectively, the “Services”). This Policy applies to our collection and use of personal information and describes rights you may have with respect to your personal information. By using our Sites and otherwise interacting with us, you agree to the terms of our Terms of Use, including this Policy.
In certain instances, this Policy identifies specific practices for franchise applicants (“Franchise Applicants”) that do not apply to other consumers subject to this Policy.
This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.
Notice at Collection – Personal Information We Collect
We collect the following categories of personal information:
- Personal identifiers: name, email address, address of the property for which service is requested or provided, your home or billing address, telephone numbers, IP address, unique identifiers (i.e., click ID), other personal information that you voluntarily provide to us.
- Commercial and financial information: records of products or Services ordered or considered; appointment and project history, testimonials, photographs from your project, your reviews, other purchasing or consuming histories; and payment status.
- For Franchise Applicants, we will also collect information on assets, income, property and business ownership history, interests, and operations, other financial information that you provide to us, employment history, and recommendations provided by references you provide to us.
- Internet or other electronic activity information: your device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements, including those advertisements hosted on third-party websites.
- Professional information: job title, information about your employer ; business entity name, credentials (business license, membership in ASID or related industry, contractors’ license number).
- Audio and electronic information: recordings of customer service calls for quality assurance purposes; transcripts of SMS and chat conversations for quality assurance and training purposes and at customer request.
- Inferences drawn from Personal Information we collect
We have collected the same categories of personal information in the 12 months prior to the date of this Privacy Policy.
When you apply to purchase a franchise, we collect the following categories of personal information about franchise applicants and, in some cases, other owners and their respective spouses:
- Personal identifiers: name, email address, postal address, telephone numbers, IP address
- Financial information: information on assets, income, property and business ownership history, interests, and operations, other financial information that you provide to us
- Educational information: education history information
- Professional information: employment and business ownership history, and recommendations provided by references
Notice at Collection – Purposes for Collection of Personal Information
We collect your personal information to provide you with the information you request and our Services, including where applicable applying for a franchise. We use the information you provide us to contact you from time to time: to provide you with information about our business; for customer support; to deliver advertisements and marketing promotions and offers about products or Services we think may be of interest to you, including our Services and those of our Affiliates (as defined below); maintaining customer loyalty, and to analyze the placement and effectiveness of our advertisements and other marketing efforts.
We also use personal information to monitor or improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or that are illegal; and to protect our rights and the rights and safety of our users or others.
For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.
Notice at Collection – Categories of Personal Information We Sell or Share and Related Information
When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of the word “sell” under certain state laws) or we may share them for purposes of cross-context behavioral advertising: personal identifiers (e.g., name, email, phone number, IP address, click ID, other identifiers), internet or other electronic activity information, and commercial information such as the job status and appointment history.
These categories of personal information are sold to or shared for cross-context behavioral advertising to advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Services we provide. We do so by allowing third parties to place cookies or other trackers on our Sites that may collect information about your online activities over time and across different websites or applications. These parties may then use the information they collect to provide you with personalized content, or advertisements for our products and services. For more information about the use of cookies and trackers, see the section “Our Use of Cookies and Analytics” below.
We also sell the following categories of personal information to our Affiliates (defined below) , most of which are in the home improvement business, so they can offer their products and services to you: name, email address, physical address, commercial information such as purchasing history, customer and job status information, and referral/lead source and campaign. For purposes of this Privacy Policy, “Affiliates” means entities that are under common ownership and/or control but do not share branding with California Closets.
We do not sell or share for cross-context behavioral advertising any of the other categories of personal information we collect.
To opt out of such sales and sharing of personal information, click here:
Notice at Collection – Retention Periods
We retain the categories of personal information we collect for the length of time necessary to provide our Services (including any warranty services), to process franchise applications, and to comply with legal obligations or to protect our legal rights.
Categories of Sources From Which We Collect Personal Information
We collect personal information directly from our customers, website users and visitors, and representatives of entities with which we do or may do business, data aggregators and data brokers.
We also collect personal information from Franchisee Applicants, owners, and respective spouses, franchises, and referrals provided about Franchisee Applicants, owners, and respective spouses.
Use or Disclosure of Sensitive Personal Information
We do not use or disclose Sensitive Personal Information to create profiles about individuals or for any purposes other than providing our Services.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information that we disclosed for a business purpose in the 12 months prior to the date of this Policy. Please note that if you are a Franchise Applicant there is a specific second portion of the chart applicable to you:
| Categories of Consumers’ Personal Information | Categories of Entities to Which We Disclosed Personal Information for Business Purposes |
|---|---|
| Personal identifiers: name, email address, address of the property for which service is requested or provided, home or billing address, telephone numbers, IP address, referring site click ID or other marker identifying Consumer as a visitor from a specific referring website or advertising partner. | Service providers that process payments, verify customer, potential customer, and site visitor information, manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products and Services and those of our Affiliates, to generate future customer leads, provide analytics information, provide legal and accounting services, and host conferencing services. Subcontractors that perform specialized components of the Services we offer. |
| Commercial information: records of products or Services purchased, ordered, returned, or considered; other purchasing or consuming histories;, payment information. | Service providers that manage customer information and provide customer service (including through our call center), facilitate scheduling, facilitate email communications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our products or Services and those of our Affiliates, provide analytics information, and provide legal and accounting services. |
| Internet or other electronic network activity information: device and browser type, browsing and search history on our Sites, records of design consultation appointments, customer status and job status, including items purchased and purchase price, and information regarding interaction with our Sites and our advertisements, including referring website and referring advertiser click IDs. | Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, assist with the advertisement and marketing of our products and Services and those of our Affiliates, and provide analytics information. |
| Professional information: job title, information about your employer; business entity name, credentials (business license, membership in ASID or related industry, contractors’ license number) | Service providers that manage business contact information. |
| Professional information: job title, information about your employer, franchisee applicants’ employment and business ownership history, and recommendations provided by references. | Service providers that manage business contact information and process franchisee applications,. Franchises. |
| Audio and electronic information: recordings of customer service calls for quality assurance purposes; transcripts of SMS and chats on our Sites for quality assurance and training purposes, and at customer request. | Service providers that manage customer information and provide customer service (including through our call center); operate, manage, record and store SMS and chat services. |
Franchise Applicants: The following chart describes the categories of personal information of Franchise Applicants that we disclosed for a business purpose in the 12 months prior to the date of this Policy.
| Categories of Personal Information of Franchise Applicants | Categories of Entities to Which We Disclosed Franchise Applicant Personal Information for Business Purposes |
|---|---|
| Personal identifiers: name, email address, home address, telephone numbers, IP address, | Service providers that verify Franchise Applicants, manage Franchise Applicant information, facilitate email communications, process franchise applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our franchise to generate future Franchise Applicant leads, provide analytics information, provide legal and accounting services, and host conferencing services. Subcontractors that perform specialized components of the Services we offer. Franchises. |
| Financial information: For Franchise Applicants, owners and their respective spouses, information about applicants’, owners’, and respective spouses’ assets, income, property and business ownership interests and operations, and other financial information provided. | Service providers that manage Franchise Applicant information and facilitate scheduling, facilitate email communications, process franchise applications, provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our franchise, provide analytics information, and provide legal and accounting services. Franchises |
| Internet or other electronic network activity information: device and browser type, browsing and search history on our Sites, and information regarding interaction with our Sites and our advertisements, including referring websites. | Service providers that provide security services and cloud-based data storage, host our Sites and assist with other IT-related functions, advertise and market our franchise, and provide analytics information |
| Professional information: employment and business ownership history, and recommendations provided by references. | Service providers that manage business contact information and process franchise applications. Franchises. |
| Educational information: education history information provided by Franchise Applicants. | Service providers that manage business contact information and process franchise applications. Franchises. |
| Audio and electronic information: recordings of customer service calls for quality assurance purposes; email, chat, SMS communications and, where applicable, transcripts of such communications, all with Franchise Applicants, owners, and respective spouses. | Service providers that manage Franchise Applicant information; operate, manage, record and store SMS and chat services. Franchises. |
Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information for the following purposes: to provide our Services; manage customer, supplier and vendor accounts and relationships; process payments; verify customers’ identities; fulfill orders and transactions; assist with and engage in advertising and marketing of our Services and those of our Affiliates; operate our IT systems and secure our systems; prevent fraud and other illegal activities; obtain professional advice about legal and accounting matters.
Evaluate and manage Franchise Applicants, owners, and their respective spouses.
Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities as well as to our parent company in some instances. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may share or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.
Our Use of Cookies and Analytics
We and our service providers may use cookies, pixel tags, web beacons, click IDs, URL parameters, and other similar tracking technologies (“tracking technologies”) to automatically collect information through the Services. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Sites and Services. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as making it possible for you to save your preferences and help us understand how you interact with our Site.
We also allow third parties, including Microsoft, Google, Meta, and other social media platforms, such as Tik Tok and Pinterest, to use tracking technologies on our Sites for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our Sites. Some of these third parties use the tracking technologies to collect information about how you interact with other websites and advertisements across the Internet in order to provide advertising that is tailored to your interests and which may appear on our Sites or on other third-party websites or platforms.
You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
We use Google Analytics to evaluate the use of our Sites. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a Site, what pages they visit when they do so, and what other websites they visited prior to visiting our Site. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.
Personal Information of Minors
Our products and Services are not directed to minors under the age of 18 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals. We observe the Global Privacy Control signal.
Third Party Websites
Our Sites may contain links to third party websites. This Policy does not govern how those third parties collect or use personal information, and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Changes to This Policy
We will review and update this Policy from time to time. If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via email or a notice on our website.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at 800‑225‑2567.
US State Data Privacy Rights
Consumer Rights Under Comprehensive US State Data Privacy Laws
We may be subject to state privacy laws in California, Nebraska, Texas, and Virginia. These laws give state residents various rights with respect to many types of personal information we collect about them, with some exceptions. The rights provided under these laws are similar in many respects, with some differences from state to state. We list below the rights that may be applicable to our business under these laws:
Right to Know: The right to confirm whether or not we are processing a resident’s personal information and to access such data. Laws in some states provide the right to know more detailed information.
- For California Residents Only: California’s privacy law gives residents the right to request the following additional information collected since January 1, 2022: Categories of personal information we have collected about them; categories of sources from which such personal information was collected; categories of personal information that the business sold or disclosed for a business purpose about the consumer; categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling your personal information.
- Right to Access / Copy: The right to access or request a copy of the personal information we have collected from the resident, subject to certain exceptions.
- Right to Delete: The right to request deletion of their personal information that we have collected from or about the resident and to have such information deleted, subject to certain exceptions.
- Right to Correct: The right to request that we correct inaccuracies in the resident’s personal information, taking into account the nature of personal data and purposes of processing such information.
- Rights to Opt Out: Various rights to request that we stop using the resident’s personal information for one or more of the following purposes:
- Sale of Personal Information: The right to request that we stop selling f their personal information, consistent with the definition of “sale” in each law.
- Targeted Advertising: The right to request that we stop processing their personal information for targeted advertising, subject to exceptions in some state laws. This is not a right that is specified under the California data privacy law.
- Sharing for Cross-Context Behavioral Advertising: California’s law provides the right to request that we stop sharing personal information for cross-context behavioral advertising.
For California Residents Only: Please note, California’s law is the only law that applies to all state residents, irrespective of the context in which they interact with us (e.g., a customer, a business contact, a vendor). Laws in other states apply only to people when acting in an individual or household context.
For California Residents Only – California Shine the Light
To the extent we provide personal information to third parties for direct marketing purposes, we allow California residents to direct us to opt out of such disclosures by exercising their right to opt out of the sale of their personal information. To exercise this right, click here.
Exercising Your Rights
We will respond to requests from residents of states with data privacy laws that apply to us and will do so with respect to the rights that are provided under the requestor’s state law as of the effective date of that law. The laws in some states listed above may not be in effect as of the date of this Privacy Policy.
To exercise rights to know, access/copy, delete, correct, or know third parties to whom personal information is disclosed, contact us at 1-833-973-0699 or click here. We will provide a substantive response to these requests within 45 days of the date on which we receive your request. If we require additional information or time to process your requests, we will contact you.
To exercise opt-out rights, submit your request here.
Opt-out Preference Signals
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.
We recognize the Global Privacy Control signal for California residents based on IP address and do so at the browser level and, therefore, it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).
We will respond to opt-out requests and requests to limit the use of sensitive information as soon as feasibly possible, but no later than 15 business days after receipt of your request. If we require additional information or time to process your requests, we will contact you.
Exercising Your Rights Using Authorized Agents
Agents may submit opt-out requests on behalf of individuals under some state data privacy laws. California residents can designate an agent to submit all other types of requests. If the agent submits an opt-out request on your behalf, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the opt-out request on your behalf. Agents can submit opt-out requests here.
If you are a California resident and you use an agent to submit other types of requests, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. You will also be required to verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request. Agents can submit requests on behalf of California residents (other than opt-out requests) by contacting us at privacyrequests@calclosets.com.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with state law pertaining to powers of attorney.
Verification of Requests
When you exercise rights other than opt-out rights, we will take steps to verify your identity. We will ask you for at least two pieces of personal information, depending on the nature of the request, and attempt to match those to information that we maintain or collect about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
When We Do Not Act on a Request – Appeal Process
In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.
Additionally, under some state laws, you have the right to appeal our decision by contacting us within 30 days after your receipt of our decision. We will provide additional details about how to appeal in our response to you.
Non-Discrimination
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.
Contact Us
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at privacyrequests@calclosets.com or 833-973‑0699.