Best Brains, Inc. (“Best Brains,” “we,” “us,” or “our”) respects your privacy and is committed to handling personal information responsibly, transparently and in accordance with applicable privacy and data protection laws.

This Global Privacy Policy explains how we collect, use, disclose, retain and protect personal information when you:

• Visit bestbrainsfranchise.com or another website that links to this Privacy Policy
• Submit a franchise inquiry or application
• Communicate with our franchise development team
• Use our website chat, WhatsApp, email, telephone or appointment-booking features
• Attend a franchise presentation, webinar, meeting or event
• Respond to our advertisements or marketing campaigns or
• Otherwise express interest in becoming a Best Brains franchisee.

This Privacy Policy also explains the privacy rights that may be available to you based on where you live.

1. WHO WE ARE

The organization responsible for the personal information covered by this Privacy Policy is:

Best Brains, Inc.
135 E. Algonquin Road, Suite B
Arlington Heights, Illinois 60005
United States
Email: info@bestbrains.com
Franchise inquiries: franchise@bestbrains.com
Telephone: (800) 582-0360

For purposes of applicable privacy laws, Best Brains, Inc. is generally the "controller," "business," "organization," "data fiduciary," or equivalent entity responsible for determining why and how personal information is processed.

In some countries, a Best Brains affiliate, regional franchise organization, master franchisee, or authorized franchise-development representative may also act as a separate or joint controller. When this applies, additional information may be provided at the time your information is collected or transferred.

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to personal information collected in connection with Best Brains franchise recruitment and development.

It does not govern personal information collected from:

• Parents or guardians enrolling children in Best Brains programs
• Students using Best Brains educational services
• Current Best Brains franchisees through franchise-management systems
• Employees and job applicants applying for corporate employment
• Users of separate Best Brains applications or platforms that have their own privacy notices

Those activities may be governed by separate privacy policies or notices.

3. PERSONAL INFORMATION WE COLLECT

The information we collect depends on how you interact with us and how far you proceed through the franchise evaluation process.

A. Information You Provide Directly:

We may collect the following information when you submit a form, speak with us, or otherwise communicate with Best Brains:

Contact and Identity Information

• Full name
• Email address
• Telephone number
• Mailing address
• Country, state, province, city, and postal or ZIP code
• Preferred method of communication
• Language preferences

Franchise Interest Information

• The country, city, state, or province where you would like to operate a center
• Preferred franchise territory
• Timeframe for opening a business
• Whether you are interested in an individual franchise, multi-unit opportunity, area development opportunity, or master franchise opportunity
• How you learned about Best Brains
• Reasons for your interest in the Best Brains franchise system
• Other information included in your inquiry or application

Professional and Background Information

• Employment and business experience
• Educational qualifications
• Whether you are a certified teacher
• Professional licenses or certifications
• Ownership or management experience
• Résumé or professional profile information
• Military or veteran status, where voluntarily provided
• References
• Information relevant to your ability to operate a Best Brains franchise

Financial and Business Qualification Information

As you advance through the franchise evaluation process, we may request:

• Approximate available capital
• Net worth or liquidity ranges
• Financing needs
• Business ownership information
• Proposed business partners
• Corporate or legal entity information
• Investment preferences
• Other information reasonably necessary to evaluate financial qualifications

We generally do not ask you to submit bank account numbers, government identification numbers, passport details, or complete financial statements through the public website. When such information is required, we may provide a separate secure collection method and additional notice.

Communications and Meeting Information

• Emails, chat messages, and WhatsApp communications
• Notes from telephone calls, interviews, or meetings
• Questions and comments submitted to us
• Appointment and scheduling information
• Webinar participation
• Survey responses
• Marketing preferences
• Records of your communications with our franchise team

Telephone or video calls may be recorded where permitted by law. When recording is used, we will provide notice or obtain consent when required.

B. Information Collected Automatically

When you visit our website, we and our service providers may automatically collect:

• Internet Protocol (IP) address
• Browser type and version
• Device type
• Operating system
• Language and time-zone settings
• Approximate location derived from an IP address
• Pages viewed
• Links selected
• Referring website or advertisement
• Date and time of access
• Time spent on pages
• Form interactions
• Chat interactions
• Cookie and advertising identifiers
• Website performance data
• Error logs
• Other online activity information

We collect this information through cookies, pixels, tags, scripts, software development tools, server logs, and similar technologies.

C. Information Obtained From Other Sources

We may receive information about you from:

• Advertising and social-media platforms
• Franchise lead-generation websites
• Business brokers and franchise consultants
• Referral partners
• Regional Best Brains organizations or authorized representatives
• Event organizers
• Publicly available business or professional sources
• Professional networking websites
• Background, identity, or financial qualification providers, where permitted and with any required authorization
• Analytics providers
• Individuals who refer you to Best Brains

When another person provides us with your information, that person is responsible for having the authority to do so.

4. HOW WE USE PERSONAL INFORMATION

We may use personal information to:

Respond to and Manage Franchise Inquiries

• Respond to your request for information
• Contact you by email, telephone, text message, WhatsApp, or other requested methods
• Schedule consultations, presentations, and interviews
• Provide franchise information and disclosure materials
• Determine whether a desired territory may be available
• Answer questions about investment requirements and the franchise process

Evaluate Franchise Candidates

• Review your franchise application
• Evaluate your professional, business, and financial qualifications
• Assess your proposed territory and business plans
• Conduct interviews
• Verify information you provide
• Obtain references or authorized background information
• Manage internal approvals
• Decide whether to continue the franchise-development process

Administer the Franchise Development Process

• Maintain candidate records
• Prepare documents
• Coordinate with legal, financial, and franchise-development professionals
• Comply with franchise registration, disclosure, and sales requirements
• Document communications and decisions
• Prevent duplicate applications
• Manage the transition from candidate to franchisee

Communicate and Market

• Send requested franchise information
• Provide updates about Best Brains opportunities
• Invite you to webinars, discovery meetings, or events
• Send newsletters and other marketing communications where permitted
• Measure advertising performance
• Personalize advertising and website content
• Maintain opt-out and suppression records

Operate and Improve Our Website

• Provide website functions
• Maintain security
• Diagnose technical problems
• Analyze website use
• Improve content, navigation, and performance
• Prevent fraud, spam, and misuse
• Maintain records of consent and preferences
• Develop and improve our franchise recruitment processes

Protect Legal and Business Interests

• Enforce our website terms and agreements
• Protect Best Brains, our users, and other parties
• Investigate suspected fraud or unlawful conduct
• Establish, exercise, or defend legal claims
• Respond to lawful requests from government agencies
• Comply with applicable laws, regulations, and court orders
• Support a corporate transaction, reorganization, financing, merger, or sale

We will not use personal information for a materially different purpose without providing additional notice and obtaining consent where required.

5. LEGAL BASES FOR PROCESSING

Where applicable law requires us to identify a legal basis, we rely on one or more of the following:

Steps Requested Before Entering into a Contract

We process information to respond to your franchise inquiry, evaluate your application, and take steps you request before potentially entering into a franchise agreement.

Legitimate Interests

We may process information when reasonably necessary for legitimate business interests, including:

• Operating and securing our website
• Responding to inquiries
• Evaluating potential franchisees
• Developing the Best Brains franchise network
• Maintaining business records
• Preventing fraud
• Improving our services
• Protecting legal rights

We consider whether these interests are overridden by your privacy rights before relying on this basis.

Consent

We may rely on consent for:

• Optional marketing communications
• Non-essential cookies and advertising technologies
• Call recordings
• Certain background checks
• Collection of sensitive information
• Other activities for which consent is required

You may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal.

Legal Obligations

We process information when necessary to comply with laws governing franchises, financial records, taxation, sanctions, anti-fraud activities, litigation, regulatory inquiries, and other legal obligations.

Legal Claims and Substantial Public Interests

Where permitted, we may process information to establish, exercise, or defend legal claims or for other substantial public-interest reasons recognized by law.

6. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and similar technologies to operate the website and understand how it is used.

Essential Cookies

These cookies are required for functions such as:

• Website security
• Network management
• Form submission
• Session management
• Fraud prevention
• Remembering privacy selections

Essential cookies cannot always be disabled through our website.

Functional Cookies

These cookies support optional functions such as:

• Live chat
• Language or regional preferences
• Embedded media
• Appointment tools
• Enhanced website features

Analytics Cookies

These cookies help us understand:

• How visitors arrive at our website
• Which pages are visited
• How long visitors remain on the site
• Whether forms are completed
• Whether technical problems occur

Advertising Cookies and Pixels

Subject to your choices and applicable law, advertising technologies may be used to:

• Measure advertising campaigns
• Understand whether an advertisement resulted in an inquiry
• Create or use advertising audiences
• Limit repeated advertisements
• Display Best Brains advertising on other websites or platforms

Where required, non-essential cookies will not be activated until you provide consent.

You can manage non-essential technologies through the Cookie Settings or Your Privacy Choices link on our website. You may also adjust your browser settings, although browser controls may not prevent every type of tracking.

Where legally required, we recognize supported browser-based opt-out preference signals, such as the Global Privacy Control (GPC), as a request to opt out of sale, sharing, or targeted advertising for the browser and device sending the signal.

Cookie duration varies. Session cookies generally expire when the browser is closed. Persistent cookies generally remain for no longer than 24 months unless a longer period is reasonably necessary, disclosed through our cookie settings tool, and permitted by law.

7. MARKETING COMMUNICATIONS

We may contact you about the franchise opportunity you requested. These communications are part of responding to your inquiry and are not necessarily promotional marketing.

Where permitted, we may also send marketing communications about:

• Franchise opportunities
• Available territories
• Franchise events
• Webinars
• Incentive programs
• Best Brains business developments

You can unsubscribe from promotional emails by using the unsubscribe link included in the email or by contacting us.

You may request that promotional telephone calls or text messages stop by telling the representative, replying "STOP" where applicable, or contacting us.

Unsubscribing from marketing will not prevent us from sending non-promotional communications related to an active inquiry, application, legal matter, or transaction.

8. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following recipients:

Best Brains Affiliates and Regional Organizations

Information may be shared with Best Brains corporate affiliates, regional offices, master franchisees, area developers, or authorized representatives when necessary to evaluate or manage an opportunity in a particular country or territory.

Service Providers

We may use providers that support:

• Website hosting
• Cloud storage
• Customer relationship management (CRM)
• Email and text communications
• Live chat
• Telephone services
• Appointment scheduling
• Analytics
• Advertising
• Document management
• Electronic signatures
• Cybersecurity
• Information technology
• Background and qualification checks
• Professional consulting
• Legal, accounting, and franchise compliance

These providers are permitted to process personal information only for authorized purposes and subject to appropriate contractual obligations.

Professional Advisers

Information may be disclosed to attorneys, accountants, auditors, insurers, financial institutions, franchise consultants, and other professional advisers.

Advertising and Analytics Partners

Subject to applicable consent and opt-out rights, online identifiers and website activity may be disclosed to analytics, social-media, and advertising providers.

Government and Legal Recipients

We may disclose information:

• To comply with a subpoena, court order, or legal process
• To respond to a regulator or law-enforcement agency
• To comply with franchise registration and disclosure laws
• To investigate fraud or security incidents
• To protect rights, property, or safety
• When otherwise required or permitted by law

Corporate Transactions

Information may be disclosed in connection with a proposed or completed merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction. Any recipient will be required to handle information consistently with applicable law.

At Your Direction

We may disclose information when you request or authorize us to do so.

9. SALE, SHARING AND TARGETED ADVERTISING

Best Brains does not sell personal information in exchange for money.

However, our use of certain advertising cookies, pixels, or similar technologies may be considered a "sale," "sharing," or use for "targeted advertising" under some United States privacy laws, even when no money is exchanged.

Depending on our website configuration, the categories involved may include:

• Online identifiers
• IP addresses
• Device information
• Internet or electronic network activity
• Inferences about interest in a franchise opportunity

Recipients may include social-media, analytics, and digital advertising providers.

Where applicable, you may opt out by selecting Your Privacy Choices, changing your cookie preferences, or using a supported Global Privacy Control (GPC) signal.

We do not knowingly sell or share the personal information of individuals under 18 years of age.

10. INTERNATIONAL DATA TRANSFERS

Best Brains is headquartered in the United States. Information collected through the website may be transferred to, accessed from, or stored in the United States and other countries where Best Brains, its regional organizations, or service providers operate.

These countries may have privacy laws that differ from those in your country.

Where required, we use appropriate safeguards for international transfers, which may include:

• Standard contractual clauses
• Data-transfer agreements
• Contractual privacy and security requirements
• Adequacy decisions
• Consent where legally appropriate
• Other transfer mechanisms recognized by applicable law

You may contact us for information about safeguards applicable to your information.

11. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including legal, regulatory, accounting, security, and dispute-resolution requirements.

Unless a longer period is required or justified, our general retention periods are:

Franchise Inquiries That Do Not Proceed

Basic inquiry and communication records may be retained for up to 24 months after the last meaningful interaction.

Franchise Applications and Candidate Evaluations

Application, interview, qualification, and decision records may be retained for up to seven years after the application is closed, withdrawn, or declined.

Successful Franchise Candidates

If you become a franchisee, relevant information will become part of the franchise relationship record and may be retained for the duration of the relationship and generally for up to seven years afterward, or longer where required by law or contract.

Marketing Information

Marketing contact information is retained until you unsubscribe, or we determine that it is no longer useful. We may retain a limited suppression record after an opt-out to ensure that your preference continues to be honored.

Website and Security Logs

General website logs are ordinarily retained for up to 12 months. Security or fraud records may be retained longer when needed to investigate an incident or protect legal rights.

Cookies

Cookie information is retained according to the duration listed in our cookie-management tool and generally for no longer than 24 months.

Recorded Calls

Where calls are recorded, recordings are generally retained for no longer than 12 months, unless needed for an active application, complaint, legal matter, or regulatory requirement.

Information may be retained longer when necessary to comply with law, preserve evidence, resolve a dispute, enforce an agreement, or protect legal rights.

When information is no longer required, we take reasonable steps to delete, destroy, or de-identify it.

12. INFORMATION SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against:

• Unauthorized access
• Accidental loss
• Misuse
• Alteration
• Improper disclosure
• Destruction

Our safeguards may include access controls, authentication, encryption, monitoring, employee confidentiality requirements, vendor reviews, secure hosting, backups, and incident-response procedures.

No website, transmission method, or information system is completely secure. You should not send highly confidential financial information, passwords, passport information, or government identification numbers through an unsecured website form or ordinary email.

13. YOUR PRIVACY RIGHTS

Privacy rights vary by jurisdiction. Depending on where you live and subject to legal exceptions, you may have the right to:

• Know whether we process your personal information
• Access personal information we hold about you
• Receive information about how your information is used
• Correct inaccurate or incomplete information
• Request deletion or erasure
• Obtain a portable copy of certain information
• Restrict certain processing
• Object to processing
• Opt out of sale, sharing, or targeted advertising
• Limit certain uses of sensitive personal information
• Withdraw consent
• Opt out of direct marketing
• Appeal a decision regarding a privacy request
• Nominate another person to exercise rights where recognized by law
• Complain to a privacy or data protection authority
• Receive equal service and treatment after exercising privacy rights

These rights are not absolute. For example, we may retain information needed to comply with franchise laws, maintain legal records, complete a requested transaction, prevent fraud, or defend legal claims.

How to Submit a Request

You may submit a request by:

• Emailing info@bestbrains.com
• Calling (800) 582-0360
• Using the privacy request or contact form made available on our website

Please write "Privacy Request" in the subject line and identify your country or state of residence.

We may need to verify your identity before completing a request. We will use information provided for verification only to process the request.

You may use an authorized agent where permitted by law. We may require proof of the agent's authority and may contact you directly to verify the request.

We will respond within the period required by applicable law. We will not discriminate against you for exercising a privacy right.

14. UNITED STATES PRIVACY DISCLOSURES

Residents of certain U.S. states may have additional rights, including rights to access, correct, delete, or obtain a copy of personal information and to opt out of sale, sharing, targeted advertising, or certain profiling.

Where applicable, you may also appeal a denial of a privacy request by replying to our decision and stating that you wish to appeal.

California Notice

This section supplements the rest of this Privacy Policy for California residents.

During the preceding 12 months, we may have collected the following categories of personal information:

1. Identifiers, including name, postal address, email address, telephone number, IP address, and online identifiers.
2. Personal information described in California customer-record laws, including contact, employment, professional, and financial qualification information.
3. Characteristics protected under California or federal law, such as military or veteran status, where voluntarily provided.
4. Commercial information, including records of interest in a franchise, requested territory, and franchise-related interactions.
5. Internet or electronic network activity, including browsing, advertising interactions, form activity, cookie data, and website usage.
6. Geolocation information, generally consisting of approximate location derived from IP address.
7. Audio, electronic, or similar information, including telephone recordings where notice or consent is provided, emails, chats, and other communications.
8. Professional or employment-related information, including occupation, qualifications, certifications, work history, and business experience.
9. Inferences, such as inferred interest in franchise ownership or particular franchise territories.

We collect these categories from the sources described in Section 3 and use them for the purposes described in Section 4.

We may disclose these categories to the recipients described in Section 8 for business purposes.

We do not sell personal information for money. Certain disclosures of identifiers and internet activity to digital advertising partners may be considered a sale or sharing under California law. California residents may opt out through Your Privacy Choices or a supported Global Privacy Control (GPC) signal.

We do not use or disclose sensitive personal information for purposes that require a separate right to limit under California law.

California residents may request:

• The categories and specific pieces of personal information collected
• The categories of sources
• The purposes for collection, use, sale, or sharing
• The categories of third parties receiving information
• Correction
• Deletion
• A portable copy of certain information
• Opt-out of sale or sharing

California residents may also request information under California's "Shine the Light" law regarding certain disclosures for third-party direct-marketing purposes, where applicable, by contacting us.

15. EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

If you are in the European Economic Area or United Kingdom, you may have the right to:

• Access your personal data
• Correct inaccurate data
• Request erasure
• Restrict processing
• Object to processing based on legitimate interests
• Object at any time to direct marketing
• Receive certain data in a portable format
• Withdraw consent
• Request information about international-transfer safeguards
• Lodge a complaint with your local data protection authority

We will identify the applicable lawful basis for processing as described in Section 5.

We do not intend to make decisions about franchise candidates based solely on automated processing that produces legal or similarly significant effects. If this changes, we will provide any notice and rights required by law.

You may complain to the supervisory authority in the country where you live or work. UK residents may complain to the UK Information Commissioner's Office.

Where Best Brains is required to appoint an EU or UK representative, the representative's contact details will be made available through this Privacy Policy or a supplemental notice.

16. CANADA

Canadian residents may request access to, and correction of, personal information held by Best Brains, subject to applicable exceptions.

We seek meaningful consent where consent is required and limit collection, use, and disclosure to appropriate purposes.

You may withdraw consent, subject to legal and contractual restrictions and reasonable notice. Withdrawal may affect our ability to evaluate or respond to a franchise application.

Canadian residents may submit questions or complaints to our privacy contact. If a concern is not resolved, you may have the right to contact the Office of the Privacy Commissioner of Canada or the appropriate provincial privacy authority.

For Quebec residents, the person responsible for the protection of personal information at Best Brains may be contacted using the information in Section 26.

Personal information may be processed outside Canada, including in the United States, where it may be available to courts, law-enforcement agencies, or regulators under local law.

17. AUSTRALIA

Where the Australian Privacy Act and Australian Privacy Principles apply, Australian residents may:

• Request access to personal information
• Request correction of inaccurate information
• Make a complaint about our handling of personal information
• Request information about overseas disclosures

Complaints should first be submitted to us using the contact information in Section 26. We will investigate and respond within a reasonable period.

If you are not satisfied with our response, you may be entitled to complain to the Office of the Australian Information Commissioner.

We take reasonable steps to ensure that overseas recipients handle personal information consistently with applicable Australian privacy requirements where those requirements apply.

18. INDIA

Where India's Digital Personal Data Protection Act and related rules apply and are in force, individuals in India may have rights to:

• Obtain information about the processing of personal data
• Request correction, completion, or updating
• Request erasure where retention is no longer legally necessary
• Withdraw consent
• Use our grievance-redressal process
• Nominate another individual to exercise rights in the event of death or incapacity
• Complain to the competent data protection authority

You are responsible for providing information that is accurate, complete, and not misleading and for not impersonating another person.

Requests and grievances may be submitted using the contact information in Section 26.

19. UNITED ARAB EMIRATES

Where the United Arab Emirates Personal Data Protection Law or another applicable UAE data-protection framework applies, you may have rights to:

• Obtain information about processing
• Access personal data
• Correct inaccurate information
• Request deletion in applicable circumstances
• Restrict or object to certain processing
• Request transfer of certain data
• Withdraw consent
• Complain to the applicable UAE data authority

Different rules may apply in the Dubai International Financial Centre (DIFC) or Abu Dhabi Global Market (ADGM).

20. SAUDI ARABIA

Where Saudi Arabia's Personal Data Protection Law (PDPL) applies, individuals may have rights to:

• Be informed about the legal basis and purpose of collection
• Access personal data
• Obtain a clear copy of personal data
• Request correction, completion, or updating
• Request destruction when permitted
• Withdraw consent where processing is based on consent
• Submit a complaint to the competent Saudi authority

Personal data relating to Saudi Arabia will be transferred outside the Kingdom only where permitted and subject to required safeguards.

21. OTHER COUNTRIES

Residents of other countries may have additional privacy rights under local law. Best Brains will honor legally valid requests to the extent required by the law applicable to the particular processing activity.

A franchise opportunity may be administered by a local or regional Best Brains organization. When that occurs, you may receive a country-specific or regional supplemental notice.

22. CHILDREN'S PRIVACY

This franchise recruitment website is intended for adults interested in business ownership and is not directed to children.

We do not knowingly collect personal information through this website from individuals under 18 years of age. If we learn that a child has submitted personal information, we will take reasonable steps to delete it.

23. THIRD-PARTY WEBSITES AND SERVICES

Our website may link to or integrate with services operated by third parties, including:

• WhatsApp
• Social-media platforms
• Live-chat providers
• Video platforms
• Appointment-scheduling services
• Map services
• Franchise lead-generation websites

These services may collect information independently and are governed by their own privacy policies. Best Brains is not responsible for the privacy practices of third parties acting independently from us.

Information you post publicly on a social-media platform may be visible to other users.

24. AUTOMATED PROCESSING AND ARTIFICIAL INTELLIGENCE

We may use tools that assist with:

• Organizing inquiries
• Identifying duplicate records
• Transcribing communications
• Summarizing communications
• Routing leads
• Supporting franchise-candidate evaluation

We do not intend to reject or approve franchise candidates solely through an automated process without meaningful human involvement.

Where a tool makes or materially contributes to a decision that produces legal or similarly significant effects, we will provide any notice, explanation, access, or opt-out rights required by applicable law.

25. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes in:

• Our information practices
• Website functions
• Service providers
• Franchise operations
• Privacy laws
• Regulatory guidance

The updated version will be posted on this website with a revised "Last Updated" date.

When changes materially affect how we use previously collected personal information, we will provide additional notice and obtain consent where required.

26. CONTACT US

Questions, complaints, and privacy requests may be directed to:

Privacy Officer
Best Brains, Inc.
135 E. Algonquin Road, Suite B
Arlington Heights, Illinois 60005
United States

Email: info@bestbrains.com
Telephone: (800) 582-0360

Please include "Privacy Request" or "Privacy Complaint" in the subject line and identify your country or state of residence.

We will acknowledge and investigate privacy complaints and will respond in accordance with applicable law.