Privacy Policy

01Scope and Roles

1.1Who This Policy Covers.

This Privacy Policy covers personal information that Special Strong collects: (a) directly from Franchisees who register for and use the Platform; (b) from Franchisees as they submit Client Data and other operational data; and (c) from integrated third-party services in the course of operating the Platform.

1.2Data Roles.

For Franchisee account information (your name, email, login credentials, and use of the Platform as an operator), Special Strong acts as the controller of that information.

For Client Data submitted by Franchisees (names, contact information, session records, billing data, and similar information about clients, leads, and their caregivers), Special Strong acts as the controller with respect to the operation of the Platform and the network-asset uses described in the Terms of Service and this Privacy Policy. Each Franchisee acts as a separate, independent controller with respect to its own collection of Client Data from its clients, leads, and caregivers and its use of that data in the operation of its franchise outside the Platform. Special Strong and the Franchisee are not joint controllers and do not jointly determine the purposes and means of processing; each is responsible for its own processing activities under applicable law. Ownership and control of Client Data as between Franchisee and Special Strong are governed by the Franchise Agreement and the Terms of Service.

1.3What This Policy Does Not Cover.

This Privacy Policy does not cover: (a) the privacy practices of Special Strong with respect to its franchisees or clients outside of the Platform; (b) the privacy practices of any individual Franchisee with respect to its clients (each Franchisee must maintain its own client-facing privacy notice); or (c) the privacy practices of third-party services integrated with the Platform, which are governed by those third parties’ own privacy policies.

02Information We Collect

2.1Information You Provide Directly.

When you register for and use the Platform, we collect:

• Account information: name, email address, phone number, business name, role, and password (stored in hashed form);
• Profile information: photo (if uploaded), preferred contact information, time zone, and language settings;
• Franchise information: franchise location, territory, assigned coaches, and operational settings;
• Communications: messages, support requests, and feedback you send to us.

2.2Information You Submit About Clients and Leads.

As you operate your franchise through the Platform, you submit Client Data, which may include:

• Client and caregiver names, email addresses, phone numbers, and contact details;
• Lead source, pipeline stage, and engagement history;
• Session schedules, attendance records, and outcomes;
• Membership records, payment history, and billing information (payment card data is collected and processed by Stripe; we do not store card numbers);
• Notes, tags, and annotations you add about clients;
• Documents you upload, which may include intake forms, waivers, and contracts;
• Communications you send to or receive from clients through integrated services (Gmail, Twilio SMS, inbound phone calls).

2.3Information Collected Automatically.

When you use the Platform, we automatically collect:

• Log data: IP address, browser type, operating system, referring URL, pages visited, and timestamps;
• Device information: device type, unique device identifiers, and mobile network information;
• Cookies and similar technologies: we use cookies, local storage, and similar technologies to operate the Platform, maintain your session, remember your preferences, and analyze usage. See Section 7.

2.4Information from Third Parties.

We may receive information about you and your franchise from:

• Integrated services you choose to connect: Google (Gmail, Calendar), Microsoft (Outlook), Stripe (payment processing), Twilio (telephony), and others; the data shared from these services is governed by the permissions you authorize during integration setup;
• Marketing platforms: if you run advertising integrated with the Platform, we may receive performance data from Meta, Google, and similar advertising platforms.

03How We Use Information

We use information for the following purposes:

• Provide and operate the Platform: authenticate users, deliver features, sync calendars and communications, process payments, generate reports;
• Improve and develop the Platform: analyze how the Platform is used, fix bugs, develop new features, and train internal analytics models on de-identified or aggregated data;
• Provide customer support: respond to inquiries, troubleshoot issues, and communicate updates;
• Communicate with you: send service-related notices, product updates, feature announcements, training opportunities, and other communications relating to the Platform and the Special Strong franchise network;
• Generate network analytics: produce aggregated and de-identified analytics, benchmarks, and reports for Special Strong, including the Franchise Scoreboard visible to other franchisees;
• Detect and prevent fraud, abuse, and security incidents;
• Comply with legal obligations and enforce our Terms of Service;
• Other purposes with your consent or as permitted by law.

3.1Use of AI and Automated Processing.

The Platform includes features that use artificial intelligence to generate business insights and recommendations. Currently, only aggregated and de-identified key performance indicators (such as cost per acquisition, cost per lead, and churn metrics) are transmitted to AI service providers for these features. We do not currently send client names, contact information, or health information to AI services. AI-generated outputs are informational only and must not be relied upon for medical, clinical, financial, or legal decisions, as described in Section 4.4 of the Terms of Service.

04How We Share Information

We share information in the following circumstances:

4.1Within the Special Strong Network.

We use Franchisee and Client Data to operate the Platform as part of the Special Strong franchise network, including for franchise management, network analytics, performance benchmarking, training, and franchise development purposes. Client Data is treated as a network asset of Special Strong.

4.2With Other Franchisees (Aggregated Only).

Aggregated performance metrics for your franchise (such as Net Athletes and Gross Revenue) are visible to other Special Strong franchisees through the Franchise Scoreboard. Individual client information is not shared with other franchisees.

4.3With Service Providers.

We share information with third-party service providers that help us operate the Platform, subject to contractual confidentiality and data protection obligations. Our current service providers include:

We may update this list from time to time. The current list is maintained in this Privacy Policy and we will update it before adding any new service provider that materially changes how data is processed.

4.4With Advertising Platforms (If Enabled).

If you enable advertising integrations (such as Meta Ads or Google Ads), conversion and audience data may be shared with those platforms to measure ad performance and improve targeting. Such data sharing is governed by the advertising platform’s terms and privacy policies.

4.5Legal and Safety.

We may disclose information when we believe in good faith that disclosure is necessary to: comply with applicable law, regulation, legal process, or government request; enforce our Terms of Service; protect the security and integrity of the Platform; protect the rights, property, or safety of Special Strong, Franchisees, clients, or the public; or respond to claims of illegal or harmful activity.

4.6Business Transfers.

If Special Strong is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, information may be transferred as part of the transaction. We will post a notice on the Platform of any change in ownership or use of personal information.

4.7With Your Consent.

We may share information for any other purpose with your consent.

4.8Aggregated and De-Identified Information.

We may use and disclose aggregated and de-identified information that cannot reasonably be used to identify any individual for any lawful purpose, including for product development, benchmarking, marketing, training of internal analytics and machine learning systems, research, reporting, and sale or transfer in connection with a corporate transaction.

05Data Retention

We retain personal information for as long as necessary to provide the Platform and fulfill the purposes described in this Privacy Policy, including to comply with our legal, accounting, and reporting obligations and to resolve disputes.

5.1Franchisee Account Data.

We retain your account information for the duration of your access to the Platform and for a reasonable period thereafter, generally no longer than three (3) years, except where longer retention is required by law or by a legitimate business need (such as defending against potential claims).

5.2Client Data.

Because Client Data is a Special Strong network asset, Client Data is retained by Special Strong after your franchise’s departure from the network, consistent with the Franchise Agreement and applicable law. Individual data subjects may submit privacy requests as described in Section 8.

5.3Backups and Audit Logs.

Backups are retained for up to one (1) year for operational, security, and disaster recovery purposes. Activity audit logs are retained for thirty (30) days. Backups and logs are deleted on a rolling basis according to our standard schedules.

5.4Consent and Acceptance Records.

Notwithstanding Sections 5.1 and 5.3, records evidencing your acceptance of these Terms and the Privacy Policy — including timestamp, IP address, user agent, document version, the email address used at registration, and any subsequent re-acceptance events — are retained as part of an immutable consent log for the longer of (a) seven (7) years from the date of the consent event or (b) the duration of your franchise relationship with Special Strong, plus any applicable statute-of-limitations period. This retention period is necessary to evidence the parties’ agreement and to defend against potential claims, and applies even where shorter periods would otherwise apply under Sections 5.1 or 5.3.

06Security

We maintain commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Measures include encryption in transit, role-based access controls, audit logging, and regular security reviews.

No security program is impenetrable. You play a critical role in protecting Platform data — use strong unique passwords and notify us immediately if you suspect any unauthorized access to your account.

07Cookies and Tracking Technologies

The Platform uses cookies and similar technologies (collectively, “Cookies”) for the following purposes:

• Essential Cookies: required for the Platform to function, including authentication, security, and load balancing;
• Functional Cookies: remember your preferences (such as language and time zone);
• Analytics Cookies: help us understand how the Platform is used so we can improve it.

The Platform is not a consumer-facing website and does not display advertising. We do not use advertising cookies on the Platform itself. Because the Platform is offered exclusively to U.S.-based business Franchisees, we do not display a cookie consent banner.

08Your Privacy Rights

8.1Franchisee Rights.

Depending on where you reside, you may have certain rights with respect to your personal information, which may include the right to: (a) access the personal information we hold about you; (b) request correction of inaccurate information; (c) request deletion of your information (subject to our retention obligations under Section 5); (d) object to or restrict certain processing; (e) portability of your information in a structured, commonly used format; and (f) withdraw consent where processing is based on consent.

To exercise these rights, contact us at [email protected]. We will respond within the timeframes required by applicable law.

8.2Client and Lead Rights — Referrals to Franchisees.

Clients, leads, and their caregivers seeking to exercise privacy rights with respect to Client Data should contact the Franchisee whose business they interact with. The Franchisee is the primary point of collection and is responsible for handling such requests in accordance with applicable law. If Special Strong receives a privacy request directly from a client, lead, or caregiver, we will refer the request to the relevant Franchisee for handling.

8.3California, Virginia, Colorado, Connecticut, and Other State Rights.

Residents of states with comprehensive privacy laws (including California, Virginia, Colorado, Connecticut, Utah, and others) may have additional rights regarding their personal information, including rights to access, correct, delete, and obtain a copy of their information; the right to opt out of certain processing for targeted advertising, sale, or profiling; and the right to appeal a denial of a privacy request. To exercise these rights, contact us as described in Section 8.1.

8.4Do Not Sell or Share.

Special Strong does not sell your personal information for monetary consideration. We do share information with service providers as described in this Privacy Policy. This Section addresses personal information only; it does not apply to aggregated or de-identified information, which Special Strong may use and disclose as described in Section 4.8. Where applicable state law treats such sharing as a “sale” or as “sharing” for targeted advertising purposes, you may opt out by contacting us as described in Section 8.1.

09Children’s Information

The Platform is intended only for use by adult Franchisees and their adult authorized users. We do not knowingly collect personal information directly from any individual under 13 years of age.

Franchisees may submit information about minor clients to the Platform in operating their franchises. Franchisees are solely responsible for obtaining all consents required from parents or legal guardians under the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and any analogous state or federal law before submitting such information. If we become aware that personal information has been collected from a child under 13 without verified parental consent in violation of COPPA or this Privacy Policy, we will take reasonable steps to delete that information.

10Health Information — Strictly Prohibited

The Platform is not a HIPAA-compliant platform and Special Strong is not, and does not offer to act as, a HIPAA Business Associate. Although Franchisees may choose to accept HSA or FSA card payments through the Platform’s Stripe integration, processing such payments does not cause Special Strong to be a HIPAA Business Associate.

If a Franchisee uploads Protected Health Information to the Platform in violation of this Section 10 and Section 3.7 of the Terms of Service, the Franchisee remains solely responsible for all consequences of that breach. Special Strong disclaims all responsibility and reserves all rights to suspend or terminate access under the Terms of Service.

11U.S. Operations Only

The Platform is operated in the United States and is intended for use only by Franchisees operating within the United States. We do not currently offer the Platform to users outside the United States and have not designed the Platform for compliance with international privacy laws such as the GDPR, UK GDPR, or PIPEDA. If you access the Platform from outside the United States, you do so in violation of these Terms and the Privacy Policy.

12Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy within the Platform and update the “Effective Date” and version number above. For material changes, we will provide additional notice (such as by email or an in-Platform banner) before the changes take effect. Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes acceptance of the changes.

13Contact Us

Questions, comments, or requests regarding this Privacy Policy or our handling of personal information should be directed to: