Does Belocal have the obligation to create Data Protection and Security Policies?
Belocal Franchise · 2025 FDDAnswer from 2025 FDD Document
Franchisee shall comply with, or, as applicable, adopt policies consistent with the then-current version of Franchisor's data protection and security policies as may be described in the Franchise Brand Standards Manual ("Data Protection and Security Policies"). Such policies may govern how Franchised Business Data and Personal Information contained in such data shall be collected, used, store, processed, shared, or destroyed. Franchisor has the right, but not the obligation, to create such Data Protection and Security Policies. Franchisee acknowledges that Franchisor may supplement, modify, or amend the Data Protection and Security Policies from time to time in its sole discretion, and that Franchisee shall comply with such modifications or amendments within thirty (30) days of notice from Franchisor. Franchisor may require Franchisee to institute a data privacy policy for its Franchised Business. Franchisee shall not publish, disseminate, implement, revise, or rescind any data privacy policy without Franchisor's prior written consent.
Source: Item 22 — CONTRACTS (FDD page 71)
What This Means (2025 FDD)
According to Belocal's 2025 Franchise Disclosure Document, Belocal does not have the obligation to create Data Protection and Security Policies. However, Belocal has the right, but not the obligation, to create such Data Protection and Security Policies.
If Belocal creates these policies, they may govern how Franchised Business Data and Personal Information contained in such data shall be collected, used, stored, processed, shared, or destroyed. Belocal may also supplement, modify, or amend the Data Protection and Security Policies from time to time in its sole discretion.
Belocal may require the franchisee to institute a data privacy policy for its Franchised Business, and the franchisee shall not publish, disseminate, implement, revise, or rescind any data privacy policy without Belocal's prior written consent. Franchisees must comply with the then-current version of Belocal's data protection and security policies as described in the Franchise Brand Standards Manual.