Effective Date: 11/4/2022

This Privacy Policy ("Policy"), describes how SmallBizPros, Inc., d/b/a PADGETT BUSINESS SERVICES^® (the "Company", or "we/us") collects, uses, and discloses the personal information that is submitted via its website www.padgettbusinessservices.com (the "Site") and otherwise through your communications with us either in writing or over the phone.

The Company has entered into franchise agreements with other independently owned and operated entities (each, a "franchisee") that allow the franchisees to use the Company's brand. Among other things, this Policy describes how the Company shares information with its franchisees. How the franchisee uses that information is described in the franchisee's own privacy policy.

The Information We Collect About You

We collect the following categories of personal information from consumers:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

We collect this information directly from you, from other entities, and through automated tools when you use our Site.

Information We Collect Directly From You. We collect the information that you give us through your use of our Contact Us page on the Site. This information includes your name, your company's name, your email address your phone number, and any other information that you may choose to submit in the message field. We also collect any other information that you may give to us through written communications or over the phone.

Information We Collect From Other Entities. If you submit information through the "Contact Us" feature on one of our franchisee's websites, we are able to access that information through our web provider's database. In addition, if you post about us on social media (e.g., LinkedIn, Facebook or Twitter), our website provider monitors those posts to help us understand our reputation in the marketplace.

Information We Collect Automatically. The Site uses automated tracking tools like cookies and web beacons to collect information about you and how you use the Site. This information includes:

• domain name;
• your IP address;
• your browser type and operating system;
• your location;
• how much time you spend on the Site;
• the web pages you look at on the Site;
• the webpage that led you to the Site.
• links you click on the Site;

How We Use Your Information

We use your information, including your personal information, for the following purposes:

Providing services. When you submit information through our Contact Us page, we use that information to respond to your inquiry and tell you about our services.

Marketing. If you have given us your contact information, we may add you to our contact lists so that we can send you marketing emails about our products and services.

Research. We use our Analytics Tools to understand how you, both individually and with others in the aggregate, use the Site. This lets us understand what parts of the Site users find more or less interesting or helpful.

Legal. We may use your information to comply with our legal obligations, including our obligation to prevent fraud and other illegal activities.

How We Share Your Information

We do not sell or rent personal information collected from or about you.

SMS opt-in or phone numbers for the purpose of the SMS are not shared with any third party or affiliate company for marketing purposes.

With others who do business with us. We may share your information with other entities that do business with us, including our franchisees and entities that provide services to us (such as our website vendor). Our franchisees may then use your information to contact you about their services.

We may also provide aggregate statistics about visitors to the Site, such as volume, traffic patterns, and related Site information to reputable third-party vendors. These statistics will not include personally identifiable information.

In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process.

To Protect Our Legal Rights. We will use your personal information when we believe it is appropriate or necessary to protect and defend our rights or property (including intellectual property) and to enforce the Terms of Use for the Site. If we are involved in litigation relating to your personal information, we may use your personal information as evidence in that litigation.

To Protect the Rights of Others. We will use and/or disclose your personal information when we believe it is necessary to investigate, prevent, or take action against activities that we believe are illegal, fraudulent, or pose a potential threat to the health or safety of others.

How We Use Tracking Tools

Cookies. We use cookies and other tracking mechanisms to collect information about how the Site is used. A cookie is a small file placed on your web browsing device. We use two types of cookies: session cookies and persistent cookies:

• Session cookies last only as long as your visit to the Site and end when you close your device or browser. We use session cookies to collect information about how you interact with the Site.

• Persistent cookies last even after you leave the Site or close your browser or device. We use persistent cookies to collect aggregate information about how multiple users interact with the Site.

Most browsers have settings that let you control or disable cookies. If you disable cookies, some portions of our Site may not function.

Analytics. We use analytics tools such as Google Analytic, to understand how you and others use our Site. These analytics tools may also use cookies and other tracking tools like web beacons or local storage objects in order to perform their services. Google allows you to prevent your information from being included in Google Analytics by downloading a browser add-on available here: https://tools.google.com/dlpage/gaoptout.

Our systems do not currently recognize browser "do not track" requests.

Advertising. While we do not use targeted web-based advertising, our franchisees may choose to do so. You should review the applicable franchisee's privacy policy to learn more about their use of web-based advertising.

Data Security

We have put in place appropriate physical, electronic, and managerial procedures to safeguard the information we collect through the Site.

Children's Privacy

Our Site is not directed at or intended to attract visitors under age 13. If we learn that a child younger than 13 has provided personal information via the Site, we will delete that information.

Choices you have regarding your personal information

By visiting our Site or submitting information through the Contact Us page, you have consented to our use of your personal information as described in this Policy. If you do not want to receive further communications from us, please contact us at webmaster@smallbizpros.com.

How You Can Access or Correct Your Personal Information

You can access the personally identifiable information that we collect about you via the Site by contacting us at webmaster@smallbizpros.com.You can correct factual errors in your personally identifiable information by sending us a request that credibly shows the error.

Links to other sites

Our Site may contain links to other sites, including those of our franchisees, the federal government, and online calculator tools. We are not responsible for the privacy practices of other sites.

Important Information for California

Residents

California residents have specific rights regarding their personal information.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

We do not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• Calling us at 1 (877) 285-5130.
• Emailing us at webmaster@smallbizpros.com.
• Using the request page on our website available here.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. For your protection, we verify your identity before complying with a request for disclosure or deletion of your personal information. As part of your request, we will ask you to provide your first and last names, your email address, your telephone number, and your company affiliation so that we can match that information to our records.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at webmaster@smallbizpros.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights under California law. However, please note that if the exercise of these rights limits our ability to process personal information (for example, in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to webmaster@smallbizpros.com.

Changes to this Policy

We may change this Policy from time to time and will include the most recent version of the Policy on this page. Please be sure to check back periodically to see the latest version of this Policy. This Policy was last updated on 11/4/2022.

Contact Us

If you have questions or concerns regarding this Policy, please contact us at webmaster@smallbizpros.com.