What does City Wide consider as 'personal information' under California law?
City_Wide Franchise · 2025 FDDAnswer from 2025 FDD Document
"Because you collect information from customers, it may contain personal information of individuals which is protected by law. You are also responsible for complying with all applicable current and future federal, state and local laws, regulations and requirements, including the California Consumer Privacy Act (as applicable), pertaining to the collection, protection, use, sale, disposal and maintenance of such personal information. Personal information includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, potential consumer, individual or household, as such term may be further defined or amended by applicable federal, state and local laws, regulations and requirements. You may also be required to comply with opt-in requirements on your website."
Source: Item 22 — CONTRACTS (FDD page 65)
What This Means (2025 FDD)
According to City Wide's 2025 Franchise Disclosure Document, 'Personal Information' includes data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, potential consumer, individual, or household. This definition aligns with the California Consumer Privacy Act and other applicable federal, state, and local statutes, regulations, ordinances, and requirements.
This definition of personal information is relevant to City Wide franchisees because they collect information from customers, which may contain personal information protected by law. Franchisees are responsible for complying with all current and future federal, state, and local laws, regulations, and requirements, including the California Consumer Privacy Act, pertaining to the collection, protection, use, sale, disposal, and maintenance of such personal information. Franchisees may also be required to comply with opt-in requirements on their website.
City Wide franchisees must adhere to data protection, collection, maintenance, and usage requirements for Customer Data as outlined in the Operating Manual and the Franchise Agreement. This includes implementing all policies, procedures, and controls that City Wide establishes. Franchisees are also obligated to assist and cooperate with City Wide to ensure compliance with applicable Privacy Laws and to promptly notify City Wide of any Security Incidents they become aware of or discover.
In the event of a Cyber Event, City Wide reserves the right to manage the response, including investigation, containment, resolution, and communications. Franchisees are required to reimburse City Wide for out-of-pocket costs and expenses incurred in responding to and remedying any Cyber Event if it is determined to have been caused solely by the franchisee or directly related to their franchised business operations. Franchisees must also seek advice from their own legal and security consultants to ensure they operate the franchised business in full compliance with data security safeguards.