Must a Beauty Bungalows franchisee comply with the California Consumer Privacy Act (CCPA)?
Beauty_Bungalows Franchise · 2025 FDDAnswer from 2025 FDD Document
- 11.04 Data Security and Privacy. Franchisee must comply with all applicable federal, state, and local laws, rules, and regulations regarding data security, protection, and privacy, including, without limitation and if applicable, the California Consumer Privacy Act ("CCPA"), Cal. Civ. Code § 1798.100, et seq. Franchisee must comply with any privacy policies, data protection polices, and breach response policies that Franchisor periodically may establish. Franchisee must notify Franchisor immediately regarding any actual or suspected data breach at or in connection with your Franchise or Business. Further, whenever and to the extent Franchisee operates as a "Service Provider" under the CCPA or in a similar capacity under any other applicable federal, state, or local privacy law, Franchisee represents, warrants, and covenants that:
- a. Franchisee will not sell, make available or otherwise disclose any customer's "Personal Information" (as defined in the CCPA) to any third party for valuable consideration;
- b. Franchisee will retain, use, or disclose Personal Information only for the specific purpose of performing the services specified in this Agreement, and not any commercial or noncommercial purpose other than providing the services specified in this Agreement;
- c. Franchisee will not retain, use, or disclose Personal Information outside of the direct business relationship between Franchisee and Franchisor;
- d. Franchisee will delete any Personal Information upon Franchisor's request unless Franchisee can prove that such request is subject to an exception under applicable law; and
- e. Franchisee certifies that it understands and will fully comply with the restrictions of this Section 11.04. Franchisee also acknowledges and agrees that Franchisor may modify the restrictions by written notice to Franchisee, including adding other similar privacy restrictions that may be required under other federal, state, or local privacy laws.
Source: Item 22 — CONTRACTS (FDD pages 47–48)
What This Means (2025 FDD)
According to Beauty Bungalows's 2025 Franchise Disclosure Document, franchisees must comply with all applicable federal, state, and local laws, rules, and regulations regarding data security, protection, and privacy. This includes, without limitation and if applicable, the California Consumer Privacy Act (CCPA). Franchisees must also adhere to any privacy policies, data protection policies, and breach response policies that Beauty Bungalows may establish periodically.
Furthermore, franchisees are required to notify Beauty Bungalows immediately of any actual or suspected data breach related to their franchise or business. If a franchisee operates as a "Service Provider" under the CCPA or a similar capacity under any other applicable privacy law, they must not sell or disclose any customer's "Personal Information" to third parties for valuable consideration. They can only retain, use, or disclose Personal Information for the specific purpose of performing the services outlined in the Franchise Agreement and not for any other commercial or noncommercial purpose outside of the direct business relationship between the franchisee and Beauty Bungalows.
Additionally, franchisees must delete any Personal Information upon Beauty Bungalows's request, unless they can prove that such a request is subject to an exception under applicable law. Franchisees also certify that they understand and will fully comply with these restrictions, and they acknowledge that Beauty Bungalows may modify these restrictions with written notice, including adding other similar privacy restrictions required under other federal, state, or local privacy laws. This ensures that Beauty Bungalows franchisees are aware of and compliant with current and future data privacy regulations.