Is a Learningrx franchisee required to adopt policies for responding to rights requests made pursuant to applicable Privacy Laws?
Learningrx Franchise · 2025 FDDAnswer from 2025 FDD Document
on, loss, alteration, unauthorized disclosure of, or access to Customer Data in violation of applicable Privacy Laws, this Agreement or the Operations Manual.
- (f) promptly provide Franchisor with the ability to delete, access or copy Customer Data in Franchisee's possession or control;
- (g) promptly notify Franchisor of any request regarding Customer Data received by the Franchisee from a "consumer" as defined by applicable Privacy Laws;
- (h) adopt policies, procedures, and controls, including those set out in the Operations Manual, if any, that enable Franchisee to respond, and to cause its agents and employees to respond, promptly to any rights request made pursuant to applicable Privacy Laws, including any disclosure request, deletion request, or opt-out request;
- (i) adopt policies, procedures, and controls, including those set out in the Operations Manual, if any, that limit access to Customer Data to only those employees that have a need-to-know basis based on specific job function or role.
Source: Item 23 — RECEIPT (FDD pages 54–209)
What This Means (2025 FDD)
According to the 2025 Learningrx Franchise Disclosure Document, franchisees are required to adopt policies, procedures, and controls that enable them to respond promptly to rights requests made under applicable Privacy Laws. These policies should also cause the Learningrx franchisee's agents and employees to respond accordingly. These rights requests include disclosure, deletion, or opt-out requests.
Learningrx franchisees must also adopt policies, procedures, and controls that limit access to Customer Data to employees with a need-to-know based on their specific job function or role. Furthermore, franchisees must provide data privacy and security training to employees who access Customer Data or system controls. These employees will be required to adhere to data confidentiality terms that protect Customer Data, as outlined in the Franchise Agreement and the Operations Manual.
In addition to adopting and implementing these policies, Learningrx franchisees are obligated to promptly notify Learningrx of any request regarding Customer Data received from a consumer, as defined by applicable Privacy Laws. Franchisees must also provide Learningrx with the ability to delete, access, or copy Customer Data in their possession or control. These measures ensure that Learningrx and its franchisees maintain compliance with privacy regulations and protect customer information.