Privacy Policy – California

Privacy Policy – California (Updated April 2, 2022)

Vanguard Cleaning Systems, Inc. (“VCS, Inc.” or “we,” “us”, or “our”) respects your privacy. This Privacy Policy governs our website located at vanguardcleaningcalifornia.com (our “Site”). It is important for you to understand what information is collected about you during your visit and what VCS, Inc. does with that information, as well as how we safeguard it. By accessing our Site or voluntarily completing information request forms, you accept our Privacy Policy and consent to its terms.

Background

VCS, Inc. is in the business of franchising. It licenses independently owned and operated companies called Vanguard Cleaning Systems® Area Franchisees in the United States to use the Vanguard Cleaning Systems® trademark and franchise system in specific geographical areas (“Regions”) in the United States. Area Franchisees sub-license the Vanguard Cleaning Systems® trademark and franchise system to independently owned and operated janitorial services companies in their Regions by granting them a Vanguard Cleaning Systems® janitorial franchise (“Unit Franchisees”). As part of their support services to their Unit Franchisees, Vanguard Cleaning Systems® Area Franchisees source commercial cleaning accounts. Unit Franchisees’ businesses provide commercial cleaning services to those accounts. The Site also routes requests for Unit Franchise information to applicable Area Franchisees in California, directs Canadian users to our Canadian website for all purposes and directs users outside of California to our U.S. website for all purposes. Our website provides marketing assistance to Area Franchisees and their Unit Franchisees in California. Area Franchisees and Unit Franchisees are independent third parties. This privacy policy does not apply to the privacy practices of any Area Franchisee or Unit Franchisee.

Questions

If you would like to ask questions or provide comments regarding this Privacy Policy, request that we not contact you in the future, or request that we correct, modify or delete any of your Personal Information, you may do so by sending us an e-mail at privacy@vanguardcleaningcalifornia.com or by writing to us at Vanguard Cleaning Systems, Inc., Attn: Privacy, 655 Mariners Island Blvd., Suite 303, San Mateo, CA 94404. We will notify any applicable Area Franchisee of your requests. However, we do not control the Area Franchisees and shall have no liability for their fulfillment of, or any failure to fulfill, your request.

We will not disclose Personal Information (as defined below) to third parties outside of the Vanguard Cleaning Systems® franchise system for their direct marketing purposes without your consent. If, after providing consent, you want to opt out of having your Personal Information disclosed to third parties for their direct marketing purposes, please let us know by sending us an e-mail at privacy@vanguardcleaningcalifornia.com or by writing to us at Vanguard Cleaning Systems, Inc., Attn: Privacy, 655 Mariners Island Blvd., Suite 303, San Mateo, CA 94404. Please be sure to include your full name, e-mail address and mailing address and specifically state that you do not want your personal information shared with third parties for their direct marketing purposes.

Information You Choose to Submit

We collect information from visitors to the Site by permitting direct communication via forms, which ask specific questions, and e-mail. Some of the information that you are asked to submit on a voluntary basis is personally identifiable (that is, information that can be uniquely identified with you, such as your name, address, e-mail address, phone number, etc.) (“Personal Information”).

Information We Automatically Collect

We collect and store certain non-personally identifiable information concerning your use of this Site that is provided to us by your browser or through third-party software applications (“Non-Personal Information”). Examples of this Non-Personal Information include estimated general demographic and location data, referring/exit pages and URL’s, platform types, the device from which you connected to our site when you visited the site and site usage data, such as information regarding the pages you have visited.

Cookies

We may use a technology called “cookies‚” and similar technologies. A cookie is a small file that is downloaded to your computer or device that identifies you as a unique user. We use cookies to let us know where you are located so that we can improve the quality of our Service and make the Service more effective for you. If you choose to do so, you can configure your browser to delete existing cookies or disable cookies altogether. However, certain features of the Service may not work or work as well if you delete or disable cookies.

Certain of our “Service Providers” (as defined below) may use cookies or similar technologies in connection with the services they perform on behalf of the Vanguard Cleaning Systems® franchise system. For example, Service Providers may gather information from users of the Site to enable the remarketing feature in Google ads using cookies and/or device identifiers. This feature allows certain Area Franchisees’ Service Providers to reach users who previously visited the Site and serve them Vanguard Cleaning Systems® ads on sites across the internet. You can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. Alternatively, visitors to our site may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using their device’s settings.

We do not control any advertising content created by third party vendors engaged by our Area Franchisees and have no liability for the same. Additionally, Area Franchisees may use third party vendors to track calls to Area Franchisee phone numbers appearing on their advertising. In that case, the calls may be monitored and recorded for quality assurance, and data regarding the calls, including possibly phone numbers and caller identities, may be shared with the Area Franchisees, their third party vendor and possibly other of their service providers. We do not have access to any such recordings or data and are not responsible in any manner for these activities conducted by Area Franchisees and their vendors and service providers.

We also use third party web analytics tools, including Google Analytics that track and report on traffic to our Site to help us improve our Site and better understand our Site users. Refer to the Google Analytics website (https://support.google.com/analytics/answer/6004245) for information on their privacy practices and use of cookies.

Do Not Track

The Site does not respond to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information about an individual consumer’s online activities over time. Visit www.donottrack.us to find out more about “do not track.”

How We Use Information

We use visitors’ Personal Information and Non-Personal Information for lead evaluation purposes, to administer and improve the Site, to provide customer services, and to notify you of updates or changes to the Site.

How We Share Information

Area Franchisees. At your request (for example, when you are interested in receiving services or have inquiries regarding becoming a Franchisee), we may share Personal Information and Non-Personal Information with the applicable Area Franchise business according to geographic information you provide, such as your California zip code. The applicable Area Franchise company may use Personal Information to contact you or send you further information consistent with your request and for future marketing/communication purposes. When you make such a request, you consent to our sharing of your Personal Information for these purposes. Area Franchisees must represent to us that they (i) implement and maintain reasonable security procedures and practices appropriate to the nature of the information they receive in order to protect such information from unauthorized access, destruction, use, modification or disclosure, and (ii) comply with all applicable data protection and privacy laws. However, we do not control the Area Franchisees and shall have no liability for their maintenance and use of your information.

Service Providers. We may sometimes use other businesses (“Service Providers”) to perform certain services for us, e.g., such as hosting and maintenance, interactive digital marketing, and data storage and management services. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your information from unauthorized access, destruction, use, modification or disclosure. However, we do not control the Service Providers and shall have no liability for any failure by them to maintain and use appropriate security procedures and practices.

Non-Personal Information. We may disclose aggregate Non-Personal Information in our discretion and describe the users of the Site to our existing or potential business partners, or other third parties. Such aggregate data will not involve the disclosure of Personal Information nor personally identify you or any other users of the Site.

Other Authorized Disclosures. Notwithstanding anything in this Privacy Policy to the contrary, you understand and agree that we may access, preserve and disclose any information we have collected about you or that you have submitted: (a) in response to subpoenas, court orders or legal process, or to establish, protect or exercise our legal rights or defend against legal claims; (b) to protect the rights and property of VCS, Inc., its affiliates, Area Franchisees, or the public; (c) if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, fraud, copyright violations, trademark violations or other violations of the personal or intellectual property rights of others or situations involving potential threats to the safety of any person; or (d) if VCS, Inc. is acquired by or merged with another entity or in connection with a sale of our assets.

Links to Other Sites

This Site may contain links to or from other websites, some of which may employ cookies. We have no access to or control over any such cookies. Please be aware that VCS, Inc. is not responsible for the privacy practices of other websites. This Privacy Policy applies only to the information collected on this Site. VCS, Inc. encourages you to read the privacy policies of other websites you link to from our Site or otherwise visit.

Consent

You should review this privacy policy carefully because if you do not agree with our practices, your ultimate choice is not to use this site. Remember, by using any part of this Site, you accept and agree to VCS, Inc.’s privacy practices. If we update this privacy policy, your continued use of this Site (following the posting of the revised policy) means that you accept and agree to the terms of the revised privacy policy.

How We Protect Your Personal Information

We take precautions to protect your Personal Information. We use standard security procedures and practices appropriate to the nature of the information (including encryption of transmitted Personal Information) in an effort to protect information from unauthorized access, destruction, use, modification or disclosure. We also require our Service Providers to represent that they implement and maintain reasonable security procedures and practices appropriate to the nature of the information we share with them. No data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect Personal Information, we cannot and do not guarantee or warrant the security of any information you transmit to or from the Site, and you do so at your own risk.

Data Processing in the United States

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using our Site, you agree that the collection, use, transfer and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.

Notification of Changes

We may revise this Privacy Policy from time to time. If VCS, Inc. decides to change its Privacy Policy, the revised policy will be posted here. We will place a prominent notice on our Site if our policy has changed in any significant way. As VCS, Inc. may make changes at any time without notifying you, it is recommended that you periodically consult this Privacy Policy. Please note that our rights to use any information collected will be based on the privacy policy in effect at the time the information is used.

Children’s Privacy Online

This Site is not intended for children under the age of 13. We will not knowingly collect information from our Site visitors in this age group. VCS, Inc. encourages parents to talk to their children about their use of the Internet and the information they disclose online. If we become aware that we have inadvertently received personally identifiable information from a user under the age of 13, we will delete such information from our records.

Privacy Policy updated April 2, 2022.