EmbroidMe
PRIVACY POLICY
JULY 2002

EmbroidMe places a high value on the relationship with its franchisees. A great deal of information about each franchise is collected by EmbroidMe during the course of the relationship between each franchisee and EmbroidMe. This Policy describes EmbroidMe’s information practices and privacy policies regarding information provided by franchisees, and collected during the course of the relationship.

1. Business & Commercial Relationship.

The relationship between EmbroidMe and a franchisee is a business and commercial relationship. Information collected by EmbroidMe from a franchisee and its principal owners, including information relating to the finances of any guarantors of the franchisee’s obligations, is collected solely for the purpose of establishing a business and commercial relationship under the terms of the franchise agreement and related to financing documents, if any. At no time does EmbroidMe intend or seek to extend credit for personal, family or household purposes. Accordingly, franchisees and individuals who are guarantors of the obligations of franchisees are not “consumers” within the meaning of Federal legislation and applicable regulations.

2. Information Collected by EmbroidMe

In the ordinary course of business, EmbroidMe collects, retains and uses information about franchisees and individual guarantors. The franchise application submitted at the time the franchisee applies for the grant of a franchise requests information about the franchisee and each guarantor. This information includes a personal balance sheet, with details on assets and liabilities, as well as historical income information about individuals. The application form and related submissions are maintained in EmbroidMe’s files, in confidence. This information is not disclosed or used except for the purpose of verifying that the information submitted is correct, and to enforce any obligation undertaken by the franchisee and any guarantor in favor of EmbroidMe or any affiliate.

EmbroidMe may solicit additional information from parties named as financial references, which may include financial institutions. In the ordinary course of business, we collect, retain and use information about franchisees to serve their financial needs, to administer their accounts, to keep franchisees informed about products and services that may be of interest, and to administer the franchise agreements and provide our services thereunder. Some of this information may be published. We may collect information from other sources, particularly from persons a franchisee lists on its franchise application.

3. Franchisee Name, Address and Telephone Number

It is no secret that all of the businesses in the EmbroidMe system are operated independently by franchisees. Under the rules of the Federal Trade Commission, franchisors are required to disclose the name, address and telephone number of each franchisee. Accordingly, EmbroidMe considers this information to be public information.

4. Security Information

We have implemented commercially reasonable security measures to prevent unauthorized access to non-public, personal information. There is no assurance that these security measures are absolute. We will continue to upgrade our security procedures as commercially appropriate.

5. Sharing of Information

We may share the name, address and telephone number of each franchisee and principal contact with our affiliates for the purpose of offering products and services that we believe may be of interest. We may also provide information to vendors and other parties we believe have offers of goods and services that may be of value to franchisees.

6. Inquiries from Potential Purchasers

We will share activity information about a franchised business with the potential purchaser of the business upon receipt of a written request to share the information or authorization to release the information, from the existing franchisee. We may request that the prospective purchaser send us a copy of the financial information received from the franchisee. We may use the information we receive to perform an audit of the relevant books and records.

7. Legal Matters

EmbroidMe must respond to legal process such as subpoenas, discovery requests, grand jury subpoenas, police and law enforcement investigations, and other official governmental inquiries that involve production or publication of the records relating to a franchise. We may also disclose information in the context of civil litigation, in which we seek to enforce a Franchise Agreement, or defend against claims from a franchisee or a third party that we have not acted properly with regard to the franchisee or the third party. We will not move to quash, suppress, or obtain a protective order for or in any such action except in our sole discretion. We have no obligation to inform any franchisee that a private party in civil litigation or any governmental agency has inquired about or received copies of its franchise records.

8. Franchise Recruitment Advertising and Inquiries

Persons who provide us with information in response to franchise recruitment advertising should expect that we will use that information to evaluate the prospect for selling a franchise to the provider. EmbroidMe will disclose the information to persons within EmbroidMe who may need to know the information to perform certain tasks associated with evaluation of the information and assessment of the market in which the proposed sign center will be located. EmbroidMe may place a cookie on the browser of persons visiting the web site interested in a EmbroidMe franchise, and may obtain other data about each web site visitor from other sources.