FRANKLINWH GLOBAL PRIVACY POLICY
Last Updated: October 13, 2026
Introduction and Overview
This Privacy Policy ("Policy") describes how FranklinWH Energy Storage Inc. and its affiliates ("FranklinWH," "Company," "we," "us," or "our") collect, use, share, and protect your personal information when you:
• Purchase, install, or use a FranklinWH energy storage system (including aPower batteries, aGate inverters, and related equipment)
• Use the FranklinWH mobile application (the "App") or FleetView platform
• Visit our website at www.franklinwh.com (the "Site")
• Interact with our customer support or other services
We refer to all of the above collectively as "Services."
IMPORTANT NOTICES
Automatic Data Collection: FranklinWH energy storage systems automatically transmit operational data to our servers. This data collection occurs continuously and does not require you to use the FranklinWH App. By having a FranklinWH system installed at your property, you acknowledge that your system will transmit Energy System Data as described in this Policy.
Energy Data Sensitivity: Your energy consumption patterns can reveal sensitive information about your daily life, including when you are home, your sleep schedule, and your household activities. We treat this data with heightened care.
International Operations: FranklinWH operates globally. Your data may be accessed by FranklinWH personnel located in the United States, Singapore, China, Australia, and other countries where we operate. See Section 6 for details on international transfers.
We Do Not Sell Your Data: FranklinWH does not sell your personal data to third parties for monetary consideration. We only share your information as described in this Policy to provide our Services to you.
Regional Rights: Depending on where you live, you may have specific privacy rights under local law. Please see the jurisdiction-specific sections of this Policy (Sections 10-15) for details about your rights.
Contents
1. What Personal Information Do We Collect?
2. How Do We Use Your Information?
3. When Do We Share Your Information?
4. Cookies and Tracking Technologies
5. How Do We Protect Your Information?
6. International Data Transfers
7. Data Retention
8. Your Privacy Rights (General)
9. System Transfers and Account Changes
10. United States Privacy Rights
11. Canada Privacy Rights (PIPEDA)
12. European Economic Area and United Kingdom Privacy Rights (GDPR)
13. Japan Privacy Rights (APPI)
14. Australia Privacy Rights (Privacy Act 1988 / APPs)
15. New Zealand Privacy Rights (Privacy Act 2020)
16. Children's Privacy
17. Changes to This Policy
18. Contact Us
1. What Personal Information Do We Collect?
We collect personal information from multiple sources: directly from you, automatically from your FranklinWH system, from your Installation Partner, and from third parties such as utility companies.
1.1 Basic Personal Identifiers
Information: Name, email address, phone number, mailing address, account credentials.
Sources: Directly from you when creating a FranklinWH account; from your Installation Partner during system registration; from Third-Party Owner partners (for leased systems).
Purposes: Account creation, order fulfillment, warranty registration, customer communications, and support.
Retention: Duration of account plus 90 days after account closure.
1.2 Property & Installation Information
Information: Installation address, electrical panel configuration, utility provider, rate plan, grid interconnection details, system serial numbers, installation date, installation photos.
Sources: From you during account setup; from your Installation Partner via the FleetView platform; from your utility provider (with your consent or as part of grid services enrollment).
Purposes: System configuration, energy optimization, time-of-use rate management, grid services eligibility, regulatory compliance, and warranty support.
Retention: 7 years after system decommissioning (for warranty and regulatory compliance).
1.3 Energy System Data
Information: Battery charge/discharge cycles, state of charge, energy consumption patterns, solar production data, grid import/export, power flow data, system alerts, battery health metrics, inverter performance.
Sources: Automatically transmitted from your FranklinWH Device (aPower, aGate) to our servers via continuous telemetry. Important: This data is collected automatically from all installed systems, regardless of whether you use the FranklinWH App.
Purposes: Real-time system monitoring, energy optimization, predictive maintenance, safety alerts, warranty diagnostics, product improvement, aggregated research, and grid services participation.
Retention: 7 years (to support long-term system analytics, warranty claims, and battery degradation tracking).
Privacy Note: Your energy consumption patterns may reveal sensitive information about your daily life, including when you are home or away, your typical sleep and wake times, periods of high activity, and general household occupancy patterns. We treat this data with heightened care and do not sell it or use it for advertising purposes.
1.4 System Diagnostic Data
Information: Error codes, fault logs, firmware versions, component temperatures, communication logs, inverter diagnostics.
Sources: Automatically transmitted from your Device; collected during remote diagnostic sessions (with your consent); collected by your Installation Partner during service visits.
Purposes: Troubleshooting, predictive maintenance, safety monitoring, firmware updates, warranty support, and product quality improvement.
Retention: 3 years.
1.5 Device & Online Identifiers
Information: IP address, mobile advertising IDs (IDFA, AAID), MAC address, device type, operating system, browser type, app version.
Sources: Automatically collected when you use the FranklinWH App or website; from cookies and similar tracking technologies.
Purposes: Service delivery, security and fraud prevention, analytics, app functionality, and service improvement.
Retention: Short-term; routinely disposed when no longer necessary.
1.6 Location Information
Information: Installation address (precise), utility service territory, IP-derived location, mobile device GPS (if enabled).
Sources: Installation address from you or your Installation Partner; utility territory from your utility provider or derived from address; IP-based location automatically collected; mobile GPS only with your permission.
Purposes: System configuration, time-of-use optimization, weather-based forecasting, grid services eligibility, and regulatory compliance.
Retention: Installation address: 7 years. Other location data: short-term.
1.7 Communications & Support Data
Information: Emails, chat transcripts, phone call recordings (where permitted), support tickets, remote diagnostic session logs, service visit records.
Sources: Directly from you when contacting customer support; phone recordings (where permitted and with notice); remote diagnostic sessions (with your consent); from your Installation Partner regarding service visits.
Purposes: Customer support, quality assurance, training, dispute resolution, and service improvement.
Retention: 5 years.
1.8 Payment & Financial Information
Information: Credit/debit card numbers, billing address, transaction history.
Sources: Directly from you when making purchases or enrolling in paid services.
Purposes: Payment processing, refunds, fraud prevention, financial reporting.
Retention: Payment card data is processed by third-party payment processors and not stored by FranklinWH. Transaction records retained as required by law.
Note: FranklinWH does not store full payment card numbers.
1.9 Information We Do Not Knowingly Collect
We do not collect protected classifications (race, religion, sexual orientation), biometric identifiers, or education records unless you voluntarily provide them.
2. How Do We Use Your Information?
2.1 Service Delivery & System Operation
• Monitoring your system's real-time performance and status
• Optimizing energy storage, consumption, and production
• Providing alerts for system issues or safety concerns
• Enabling remote diagnostics and troubleshooting
• Processing firmware updates
2.2 Customer Support & Warranty
• Responding to your inquiries and support requests
• Diagnosing and resolving technical issues
• Fulfilling warranty obligations
• Coordinating with your Installation Partner for service
2.3 Product Improvement & Research
• Analyzing aggregated system performance data
• Identifying opportunities for product improvements
• Developing new features and services
• Conducting safety and quality research
2.4 Grid Services & Utility Programs
• Enabling participation in demand response programs
• Supporting virtual power plant operations
• Facilitating grid stabilization and renewable energy integration
• Reporting program participation to utilities
2.5 Communications & Marketing
• Sending service notifications and alerts
• Providing product updates and announcements
• Sending marketing communications (with your consent or as permitted by law)
2.6 Legal & Compliance
• Complying with applicable laws and regulations
• Responding to legal requests and court orders
• Protecting our rights and the safety of others
• Fulfilling regulatory reporting obligations
2.7 Automatic Telemetry Collection
Your FranklinWH system (aPower, aGate, and connected equipment) automatically transmits operational data to FranklinWH servers via your home internet connection. This transmission:
• Occurs continuously (typically every few seconds to minutes)
• Does not require the FranklinWH App to be installed or used
• Cannot be disabled without disconnecting your system from the internet (which may void your warranty and disable remote support features)
• Includes energy consumption, production, storage, and diagnostic data
3. When Do We Share Your Information?
3.1 Installation Partners
FranklinWH products are sold through a network of authorized Installation Partners who install, maintain, and service your system. Your Installation Partner is an independent business, not a FranklinWH employee.
Data Shared via FleetView Platform:
• Your name, email, phone number, and mailing address
• System installation address
• System configuration, equipment model, and serial numbers
• Real-time system status, performance data, and alerts
• Diagnostic data, error codes, and fault logs
• Service history and warranty status
Duration of Access: Your Installation Partner retains access to your data for as long as they are the designated service provider for your system. You may request to change your Installation Partner by contacting us.
3.2 Third-Party System Owners
Applies When: Your FranklinWH system is owned, leased, or financed through a third party (e.g., Sunrun, solar financing companies) rather than purchased outright.
Data Shared:
• Basic identifiers and contact information
• System location and configuration
• Energy production, consumption, and storage data
• System status and performance metrics
3.3 Corporate Affiliates
FranklinWH is a global company with affiliated operations in multiple countries. Your personal information may be accessed by personnel located in:
• United States: Primary operations, customer support, engineering
• Singapore: Regional operations and support
• People's Republic of China: Product development, advanced technical support, quality assurance, R&D, and manufacturing coordination
• Australia: Regional operations and customer support
See Section 6 for details on safeguards for international transfers.
3.4 Service Providers
We engage third-party service providers to perform functions on our behalf:
• Cloud Infrastructure (AWS): Data hosting, storage, and processing
• Payment Processors: Secure payment transaction handling
• Customer Support Tools: Help desk, ticketing, and communication platforms
• Analytics Providers: Usage analysis and service improvement
• Communication Services: Email, SMS, and push notification delivery
• Security Services: Fraud detection and cybersecurity monitoring
All service providers are bound by contracts requiring them to protect your data, use it only for specified purposes, and comply with applicable privacy laws.
3.5 Utility Companies & Grid Operators
Applies When: You enroll in a grid services program, demand response program, virtual power plant, or similar utility program.
Data Shared:
• System capacity and availability
• Real-time energy production, consumption, and storage data
• Grid import/export data
• Dispatch response and program participation data
Sharing occurs only with your consent when you enroll in such programs, or as required by interconnection agreements.
3.6 Legal & Regulatory Authorities
We may disclose your information when required to:
• Comply with applicable laws, regulations, or legal processes
• Respond to lawful requests from government authorities
• Protect the rights, property, or safety of FranklinWH, our users, or others
• Enforce our Terms of Service or other agreements
• Investigate potential violations or fraud
3.7 Business Transactions
In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your personal information may be transferred to the successor entity or prospective buyer. In such events, we will require the recipient to honor this Privacy Policy or provide you with notice and an opportunity to opt out.
4. Cookies and Tracking Technologies
Our website and App use cookies, web beacons, and similar technologies to:
• Provide essential functionality (session management, security)
• Remember your preferences
• Analyze usage patterns and improve our Services
• Deliver relevant advertising (where permitted)
4.1 Types of Cookies We Use
Necessary/Essential Cookies: Required for basic site functionality. Cannot be disabled.
Functional Cookies: Remember your choices and preferences.
Analytics Cookies: Help us understand how visitors use our Services.
Advertising Cookies: Used to show relevant advertisements (where permitted by law).
4.2 Your Cookie Choices
• Adjust cookie settings in your browser
• Use our cookie preference center on our website
• For EU/UK users: Use the cookie consent banner to manage preferences
• Visit www.aboutads.info/choices to opt out of interest-based advertising
• Enable "Limit Ad Tracking" (iOS) or "Opt Out of Ads Personalization" (Android)
5. How Do We Protect Your Information?
We implement reasonable physical, electronic, and procedural safeguards designed to protect your personal information:
Technical Measures:
• Encryption of data in transit (TLS) and at rest
• Secure authentication and access controls
• Intrusion detection and prevention systems
• Regular security testing and vulnerability assessments
• Secure software development practices
Administrative Measures:
• Information security policies and procedures
• Employee background checks and training
• Incident response plans
• Vendor security assessments
Security Features Available to You:
• Multi-factor authentication for your FranklinWH Account
• Session timeout after periods of inactivity
• Email notifications for account changes
• Ability to revoke Installation Partner access
While we strive to protect your information, no security measures are perfect. We encourage you to use a strong, unique password and keep your account credentials confidential.
6. International Data Transfers
IMPORTANT NOTICE: FranklinWH is a global company with operations and affiliated entities in multiple countries. When you use our Services, your personal information may be transferred to, accessed from, and processed in countries other than your country of residence, including the People's Republic of China.
6.1 Countries Where Your Data May Be Processed
• United States: Primary data storage (AWS servers), customer support, engineering, and corporate operations
• Singapore: Regional operations, customer support, and business administration
• People's Republic of China: Product development, advanced technical support, quality assurance, research and development, and manufacturing coordination. Data processed in China is strictly limited in accordance with U.S. Executive Order 14117 and 28 CFR Part 202
• Australia: Regional operations, customer support
• Canada: Regional operations, customer support
• Japan: Regional operations, customer support
• European Union: Regional operations (as applicable)
6.2 Transfer Mechanisms and Safeguards
We implement the following safeguards to protect your information during international transfers:
• Standard Contractual Clauses (SCCs) approved by the European Commission and/or UK ICO
• Binding Corporate Rules where applicable
• Adequacy decisions where recognized by relevant authorities
• Encryption of data in transit and at rest
• Role-based access controls limiting data access to authorized personnel
• Regular security audits and assessments
• Contractual requirements for affiliates and service providers to protect your data
For EEA, UK, and Swiss residents: You may request a copy of the safeguards we use for international transfers by contacting us using the details in Section 18.
6.3 Your Acknowledgment
By using our Services, you acknowledge that your data may be transferred to and processed in countries that may have different data protection laws than your country of residence. Where required by applicable law, we will obtain your explicit consent before such transfers.
7. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required by law:
• Account Information: Duration of account + 90 days
• Energy System Data: 7 years (for warranty support and battery degradation tracking)
• System Diagnostic Data: 3 years
• Customer Support Records: 5 years
• Property & Installation Info: 7 years after system decommissioning
• Financial/Transaction Records: As required by law (typically 7 years)
• Device/Online Identifiers: Short-term (typically < 13 months)
After the retention period expires, we will securely delete or anonymize your data unless retention is required for legal, regulatory, or legitimate business purposes.
8. Your Privacy Rights (General)
Depending on where you live, you may have the following rights regarding your personal information:
• Right to Know/Access: Request information about what personal information we collect and how we use it
• Right to Correction: Request correction of inaccurate personal information
• Right to Deletion: Request deletion of your personal information (subject to exceptions)
• Right to Portability: Receive your personal information in a structured, machine-readable format
• Right to Object: Object to certain types of processing
• Right to Restrict: Request that we limit how we use your data
• Right to Withdraw Consent: Withdraw consent where processing is based on consent
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights
See the jurisdiction-specific sections below (Sections 10-15) for detailed information about your rights under your local law.
8.1 How to Exercise Your Rights
To exercise your privacy rights, contact us at:
Email: dataprivacy@franklinwh.com
We will verify your identity before processing your request. If we cannot verify your identity, we may ask for additional information.
8.2 Response Timeframes
We will respond to your request within the timeframe required by applicable law (typically 30-45 days). If we need additional time, we will notify you of the reason and extension period.
9. System Transfers and Account Changes
Before Selling or Transferring Your System:
If you sell or transfer your FranklinWH system to another person, please contact us at service@franklinwh.com to transfer ownership and remove your personal data from the system. This ensures the new owner can register the system under their own account and that your data is properly protected.
Failure to transfer ownership may result in the new owner having access to your historical energy data or being unable to properly register and use the system.
10. United States Privacy Rights
This section applies to residents of the United States and supplements the information in the rest of this Policy.
10.1 California (CCPA/CPRA)
If you are a California resident, you have the following rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act:
• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected
• Right to Delete: Request deletion of your personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out of Sale/Sharing: Direct us not to sell or share your personal information
• Right to Limit Use of Sensitive Personal Information: Limit use of sensitive data to specified purposes
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights
Sale and Sharing: FranklinWH does not sell personal information for monetary consideration. We may share certain online identifiers with advertising partners through cookies, which may constitute "sharing" under California law. You may opt out by clicking "Do Not Sell or Share My Personal Information" on our website.
Authorized Agents: You may designate an authorized agent to make requests on your behalf. We may require verification of the agent's authority.
10.2 Other U.S. State Privacy Laws
Residents of Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Texas, and other states with comprehensive privacy laws may have similar rights to those described above, including rights to access, correct, delete, and opt out of certain processing.
Minnesota and Oregon Residents: You have a right to request a list of third parties to whom data is disclosed in the fulfillment of your product or service. Contact us at dataprivacy@franklinwh.com to make this request.
10.3 California "Shine the Light"
Under California Civil Code Section 1798.83, California residents may request information about disclosure of personal information to third parties for direct marketing. We do not disclose personal information to third parties for their direct marketing purposes.
10.4 "Do Not Track" Signals
Our Services do not currently respond to "Do Not Track" browser signals. However, you can manage your cookie preferences through your browser settings or our cookie preference center.
11. Canada Privacy Rights (PIPEDA)
This section applies to residents of Canada and supplements the information in the rest of this Policy. We are committed to protecting your privacy in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.
11.1 Consent
We collect, use, and disclose your personal information with your knowledge and consent, except where permitted or required by law. Consent may be express or implied depending on the circumstances and the sensitivity of the information. You may withdraw consent at any time, subject to legal or contractual restrictions, by contacting us. Withdrawal of consent may affect our ability to provide Services to you.
11.2 Your Rights Under PIPEDA
• Right to Access: Request access to the personal information we hold about you
• Right to Correction: Request correction of inaccurate or incomplete information
• Right to Withdraw Consent: Withdraw your consent to collection, use, or disclosure
• Right to Complain: Lodge a complaint with the Office of the Privacy Commissioner of Canada
11.3 Cross-Border Transfers
Your personal information may be processed and stored outside of Canada, including in the United States, Singapore, and China. When we transfer your information outside Canada, we ensure appropriate safeguards are in place through contractual arrangements requiring recipients to protect your information to a standard comparable to Canadian law.
11.4 Quebec Residents (Law 25)
Quebec residents have additional rights under Quebec's Act Respecting the Protection of Personal Information in the Private Sector, including the right to data portability and the right to be informed of automated decision-making. We do not engage in automated decision-making that produces legal or similarly significant effects.
11.5 Contact and Complaints
To exercise your rights or make a complaint:
FranklinWH: dataprivacy@franklinwh.com
Office of the Privacy Commissioner of Canada: www.priv.gc.ca
12. European Economic Area and United Kingdom Privacy Rights (GDPR)
This section applies to individuals located in the European Economic Area (EEA), United Kingdom, and Switzerland, and supplements the information in the rest of this Policy. We process your personal data in accordance with the General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection.
12.1 Data Controller
FranklinWH Energy Storage Inc. is the data controller responsible for your personal data. For contact details, see Section 18.
12.2 Legal Bases for Processing
We process your personal data based on the following legal grounds:
Performance of Contract: Processing necessary to perform our contract with you, including providing the Services, system monitoring, customer support, and warranty services.
Legitimate Interests: Processing necessary for our legitimate interests, including product improvement, safety monitoring, fraud prevention, and security. We balance these interests against your rights and freedoms.
Legal Obligation: Processing necessary to comply with legal obligations, such as tax reporting, regulatory compliance, and responding to legal requests.
Consent: Processing based on your consent, such as marketing communications and certain cookies. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
12.3 Your Rights Under GDPR
You have the following rights regarding your personal data:
• Right of Access: Obtain confirmation of whether we process your data and request a copy
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure ("Right to be Forgotten"): Request deletion of your data in certain circumstances
• Right to Restriction: Request that we restrict processing of your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right Not to be Subject to Automated Decision-Making: Not be subject to decisions based solely on automated processing with legal or significant effects
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: Lodge a complaint with a supervisory authority
12.4 International Transfers
When we transfer your personal data outside the EEA, UK, or Switzerland to countries not deemed adequate by the European Commission or UK Government, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and supplementary measures to ensure an adequate level of protection. You may request a copy of the SCCs by contacting us.
12.5 Supervisory Authorities
You have the right to lodge a complaint with a supervisory authority, in particular in the EU/EEA Member State or UK where you reside, work, or where the alleged infringement occurred. Key supervisory authorities include:
• UK: Information Commissioner's Office (ICO) - ico.org.uk
• Germany: Federal Commissioner for Data Protection
• France: Commission Nationale de l'Informatique et des Libertés (CNIL)
• Netherlands: Autoriteit Persoonsgegevens
13. Japan Privacy Rights (APPI)
This section applies to individuals located in Japan and supplements the information in the rest of this Policy. We handle your personal information in accordance with the Act on the Protection of Personal Information (APPI).
13.1 Purpose of Use
We use your personal information for the purposes disclosed in Section 2 of this Policy, including:
• Providing and maintaining our Services
• System monitoring, diagnostics, and maintenance
• Customer support and warranty services
• Product improvement and development
• Marketing communications (with your consent)
• Legal compliance
13.2 Provision to Third Parties
We may provide your personal information to third parties as described in Section 3 of this Policy. Where required by APPI, we will obtain your prior consent before providing personal information to third parties, except where permitted by law (such as to service providers under our supervision or when required by law).
13.3 Cross-Border Transfer
Your personal information may be transferred to and processed in countries outside Japan, including the United States, Singapore, and China. Before transferring your personal information to a third party in a foreign country, we will: (1) obtain your consent; (2) ensure the recipient country has adequate data protection; or (3) ensure the recipient has equivalent data protection measures in place. Information about the data protection systems in recipient countries is available upon request.
13.4 Your Rights Under APPI
• Right to Request Disclosure: Request disclosure of your personal information and its purpose of use
• Right to Request Correction: Request correction, addition, or deletion of inaccurate information
• Right to Request Cessation: Request cessation of use or deletion if information was obtained improperly or used beyond disclosed purposes
• Right to Request Cessation of Provision: Request that we stop providing your information to third parties
13.5 Contact and Complaints
To exercise your rights or make a complaint:
FranklinWH: dataprivacy@franklinwh.com
Personal Information Protection Commission: www.ppc.go.jp
14. Australia Privacy Rights (Privacy Act 1988 / APPs)
This section applies to individuals located in Australia and supplements the information in the rest of this Policy. We are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
14.1 Collection of Sensitive Information
We collect sensitive information only with your express consent and when it is reasonably necessary for our functions or activities. We will not use or disclose your sensitive information for any purpose other than the primary purpose for which it was collected, unless you have consented or it is required or permitted by law.
14.2 Cross-Border Disclosure
We may disclose your personal information to overseas recipients located in:
• United States
• Singapore
• People's Republic of China
• New Zealand
In accordance with APP 8, we conduct thorough assessments of cross-border transfers and implement appropriate safeguards including:
• Contractual clauses requiring recipients to adhere to data protection standards equivalent to the APPs
• Encryption of data in transit and at rest
• Regular audits of data recipients
• Access controls to ensure only authorized personnel can access your data
14.3 Your Rights Under the Privacy Act
• Right to Access: Request access to the personal information we hold about you
• Right to Correction: Request correction of inaccurate, out-of-date, incomplete, irrelevant, or misleading information
• Right to Complain: Lodge a complaint with the Office of the Australian Information Commissioner (OAIC)
14.4 Notifiable Data Breaches
In the event of an eligible data breach that is likely to result in serious harm to you, we will notify you and the OAIC as required under the Notifiable Data Breaches scheme.
14.5 Direct Marketing
We will only use your personal information for direct marketing purposes where you have consented or where it is otherwise permitted by law. You may opt out of direct marketing at any time by contacting us or using the unsubscribe link in our communications.
14.6 Contact and Complaints
FranklinWH: dataprivacy@franklinwh.com
OAIC: www.oaic.gov.au
15. New Zealand Privacy Rights (Privacy Act 2020)
This section applies to individuals located in New Zealand and supplements the information in the rest of this Policy. We handle your personal information in accordance with the Privacy Act 2020 and the Information Privacy Principles (IPPs).
15.1 Collection and Use
We collect personal information directly from you where possible. We will inform you of the purpose of collection, the intended recipients, and your rights of access and correction. We will only use your information for the purposes for which it was collected or a directly related purpose.
15.2 Cross-Border Disclosure
Before disclosing your personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient will protect your information in a way that is comparable to the protections under the Privacy Act 2020, or that one of the exceptions under the Act applies (such as your authorization, or that the recipient is subject to comparable privacy laws).
15.3 Your Rights Under the Privacy Act 2020
• Right to Access: Request access to your personal information
• Right to Correction: Request correction of your personal information
• Right to Complain: Lodge a complaint with the Office of the Privacy Commissioner
15.4 Notifiable Privacy Breaches
If we experience a privacy breach that poses a risk of serious harm to you, we will notify you and the Privacy Commissioner as soon as practicable as required under the Privacy Act 2020.
15.5 Contact and Complaints
FranklinWH: dataprivacy@franklinwh.com
Office of the Privacy Commissioner: www.privacy.org.nz
16. Children's Privacy
Our Services are not directed to individuals under the age of 16 (or the applicable age of consent in your jurisdiction), and we do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately at dataprivacy@franklinwh.com, and we will take steps to delete the information.
17. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will notify you by:
• Posting the updated Policy on our website with a new "Last Updated" date
• Sending you an email notification (if you have an account)
• Displaying a notice in the FranklinWH App
We encourage you to review this Policy periodically. Your continued use of the Services after changes are posted constitutes your acceptance of the updated Policy.
18. Contact Us
If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about our data practices, please contact us:
FranklinWH Data Protection Office
Email: dataprivacy@franklinwh.com
Address: 1731 Technology Dr., Suite 530, San Jose, CA 95110, USA
Phone: +1 888-851-3188
For general customer support inquiries, please contact: service@franklinwh.com