What is the Bath Tune Up franchisee's liability for violations of Privacy Law?

According to Bath Tune Up's 2025 Franchise Disclosure Document, the franchisee is solely liable for any violations of Privacy Law that arise from their failure to comply with the provisions outlined in the franchise agreement. This means that if a franchisee fails to adhere to local, state, or federal data privacy and security laws or regulations, they will be held responsible for any resulting legal consequences. Privacy Law is defined as any local, state, or federal data privacy or data security law or regulation. Privacy Information includes any data that can identify or is linked to a specific consumer or household.

The FDD emphasizes that neither the franchisee nor Bath Tune Up is allowed to sell Privacy Information. The franchisee is permitted to access, use, or process Privacy Information only to fulfill their obligations under the franchise agreement and in compliance with Privacy Law. This highlights the importance of franchisees understanding and adhering to all applicable privacy laws to protect consumer data and avoid potential legal repercussions.

To ensure compliance, Bath Tune Up may request information from the franchisee to establish their adherence to privacy obligations and applicable Privacy Laws. Franchisees must also provide reasonable assistance to Bath Tune Up in responding to requests made under applicable Privacy Law by individuals who are the subject of any of the Privacy Information, if Bath Tune Up does not have the ability to address these requests directly. This demonstrates the shared responsibility in maintaining data privacy and security within the Bath Tune Up franchise system.