California Business Privacy Notice

This California Business Privacy Notice applies to California residents and tells you how Franklin Sports, Inc. (“Franklin Sports,” “we” or “us”) collects, uses, shares, discloses, and retains (collectively “processes”) your personal information. We are committed to processing your personal information responsibly and in accordance with applicable laws and internal policies. For the purpose of this California specific Privacy Notice, residents include individuals whose personal information is processed within a business context (“Business Contacts”). Examples of Business Contacts include:

• individuals acting on behalf of a current, former, or prospective service provider, vendor, or other business partner
• individuals participating in our affiliate marketing or supplier programs
• individuals participating in our community outreach programs in partnership with community organizations
• media contacts, investors, government officials, social media influencers, and other third parties interacting with us

Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act.

Notice of Collection and Use of Personal Information

As a part of business-related activities, we may need to collect and use your personal information for normal business management functions, internal administration, and compliance with legal and regulatory obligations. Details below apply to current processing as well as the 12-month period prior to the date this Privacy Notice was last updated.

Categories of Personal Information Collected

We may collect the following categories of personal information about Business Contacts.

• Identifiers (e.g., email address, name, mailing address, phone number, state identification)
• Characteristics of protected classifications (e.g., age, disability, gender, military status, race)
• Commercial information (e.g., products or services purchased)
• Internet or other electronic network activity (e.g., activity while on our company network)
• Geolocation data (e.g., location from which you are interacting with us)
• Audio, electronic, or visual information (e.g., phone calls, photos, video)
• Professional or employment-related information (e.g., resume information, occupation details, education details, certifications and professional associations, social media profile, previous employment details)
• Education information (i.e., education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99))
• Inferences (e.g., preferences, characteristics, behavior)

Purposes for Collecting Personal Information

We may use personal information of Business Contacts for the purposes described below.

• Establish, manage, terminate or otherwise administer the business relationship
• Establish a business point of contact to facilitate communications
• Comply with legal requirements
• Ensure compliance with our requirements, policies, and procedures
• Detect or prevent theft or fraud, including the security of company-held information
• Conduct investigations
• Assist law enforcement and respond to legal/regulatory inquiries
• Fulfill such other business purposes as reasonably determined by us

We do not process sensitive personal information with the purpose of inferring characteristics about Business Contacts.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period required or permitted by law or for the time reasonably necessary to achieve the purposes described in this Privacy Notice or any other notice provided at the time of collection. Retention is based on several factors, including legal requirements, statutes of limitation, and business needs.

Sources of Personal Information

We may obtain personal information about Business Contacts from the following categories of sources:

• Directly from you
• Your employer
• Your device(s)
• Business contacts who provide information about you
• Our affiliates and subsidiaries
• Vendors who provide services on our behalf
• Government entities
• Social networks
• Background check services

Disclosure of Personal Information

We may disclose the following categories of personal information about Business Contacts for a business purpose to the following categories of third parties:

We may also share the information we collect with our service providers and within Franklin Sports, which includes all of our subsidiaries and affiliated companies.

In addition to the categories of third parties identified above, we may disclose personal information about Business Contacts to third parties in connection with corporate transactions.

We do not share for cross-context behavioral advertising purposes or sell personal information about Business Contacts.

California Privacy Rights

If you are a Business Contact, you the following rights:

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information or categories of personal information we have collected, used, disclosed, and sold or shared about you.
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access, correction, or deletion request for yourself or as an authorized agent, please email [email protected] or call us at 1-877-377-6787

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. You will be required to submit specific pieces of information in order for us to search our systems and determine if we have information about you. If we can locate information about you, then we will fulfill your request as required by law.

If you are an authorized agent, you will be required to submit your information as well as specific pieces of information about the individual for whom you are making a request. You will also be asked to fill out a certification form confirming your information and certifying you have the right to make a request on behalf of the individual.

Non-Discrimination: We will not discriminate against you because you exercise your rights. For example, we will not deny you business if you make an access request.

How To Contact Us

If you have any questions about this Privacy Notice or our privacy practices, please contact [email protected].

Last Update: June 6, 2023