For Itan, what specific information collected from customers is considered 'Customer Data'?

According to Itan's 2025 Franchise Disclosure Document, Customer Data includes any information pertaining to a Salon customer. This encompasses their name, address, contact information, and date of birth. Additionally, Customer Data includes the customer's purchase history and any information gathered through loyalty or membership programs, or for any other purpose.

For a prospective Itan franchisee, this definition is important because Itan retains exclusive ownership of all Business Data, which includes Customer Data. While franchisees are granted a license to use this data for operating their Salon in compliance with the Franchise Agreement, they must also protect all Customer Data with controls proportionate to the data's sensitivity.

Furthermore, franchisees must adhere to applicable privacy laws regarding data that, if compromised, could negatively impact Itan's image or consumer confidence. Compliance with data protection laws and any data processing and privacy policies outlined in Itan's manual is mandatory. Franchisees may also be required to sign data processing or data privacy agreements as required by Itan or by law, highlighting the importance of understanding and adhering to these data-related obligations.