Legal

Privacy Policy

Your privacy is important to us. It is Wizardline Technologies, Inc.’s policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://us.thewizardline.com, and other sites we own and operate.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

This policy is effective as of 17 January 2022.

Last updated: 17 January 2022

Information We Collect

Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information.

“Voluntarily provided” information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

“Automatically collected” information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Personal Information

We may ask for personal information — for example, when you register an account or when you contact us — which may include one or more of the following:

  • Name

  • Email

  • Phone/mobile number

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

  • Register for an account

  • Use a mobile device or web browser to access our content

  • Contact us via email, social media, or on any similar technologies

  • When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our platform’s core features and services

  • to deliver products and/or services to you

  • to contact and communicate with you

  • for internal record keeping and administrative purposes

  • to comply with our legal obligations and resolve any disputes that we may have

  • for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, Our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our site to improve our site and your experience on it.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

  • a parent, subsidiary, or affiliate of our company

  • third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators

  • our employees, contractors, and/or related entities

  • our existing or potential agents or business partners

  • credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you

  • courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights

  • third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you

  • third parties to collect and process data

  • an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

  • Constant Contact

International Transfers of Personal Information

The personal information we collect is stored and/or processed in United States, or where we or our partners, affiliates, and third-party providers maintain facilities.

The countries to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

Please refer to our Cookie Policy for more information.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for California Compliance (US)

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes.

To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.

Do Not Track

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals.

We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

Cookies and Pixels

At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.

CCPA-permitted financial incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide.

Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

  • Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to your account.

For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;

  • The categories of sources from which the personal information was collected;

  • The categories of personal information about you we disclosed for a business purpose or sold;

  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;

  • The business or commercial purpose for collecting or selling the personal information; and

  • The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided in this privacy policy.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes.

To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

John Moses
privacy@thewizardline.com

Acceptable Use Policy

This acceptable use policy covers the products, services, and technologies (collectively referred to as the “Products”) provided by Wizardline Technologies, Inc. under any ongoing agreement. It’s designed to protect us, our customers, and the general Internet community from unethical, irresponsible, and illegal activity.

Wizardline Technologies, Inc. customers found engaging in activities prohibited by this acceptable use policy can be liable for service suspension and account termination. In extreme cases, we may be legally obliged to report such customers to the relevant authorities.

This policy was last reviewed on 17 January 2022.

Fair use

We provide our facilities with the assumption your use will be “business as usual”, as per our offer schedule. If your use is considered to be excessive, then additional fees may be charged, or capacity may be restricted.

We are opposed to all forms of abuse, discrimination, rights infringement, and/or any action that harms or disadvantages any group, individual, or resource. We expect our customers and, where applicable, their users (“end-users”) to likewise engage our Products with similar intent.

Customer accountability

We regard our customers as being responsible for their own actions as well as for the actions of anyone using our Products with the customer’s permission. This responsibility also applies to anyone using our Products on an unauthorized basis as a result of the customer’s failure to put in place reasonable security measures.

By accepting Products from us, our customers agree to ensure adherence to this policy on behalf of anyone using the Products as their end users. Complaints regarding the actions of customers or their end-users will be forwarded to the nominated contact for the account in question.

If a customer — or their end-user or anyone using our Products as a result of the customer — violates our acceptable use policy, we reserve the right to terminate any Products associated with the offending account or the account itself or take any remedial or preventative action we deem appropriate, without notice. To the extent permitted by law, no credit will be available for interruptions of service resulting from any violation of our acceptable use policy.

Prohibited activity

Copyright infringement and access to unauthorized material

Our Products must not be used to transmit, distribute or store any material in violation of any applicable law. This includes but isn’t limited to:

  1. any material protected by copyright, trademark, trade secret, or other intellectual property right used without proper authorization, and

  2. any material that is obscene, defamatory, constitutes an illegal threat or violates export control laws.

The customer is solely responsible for all material they input, upload, disseminate, transmit, create or publish through or on our Products, and for obtaining legal permission to use any works included in such material.

SPAM and unauthorized message activity

Our Products must not be used for the purpose of sending unsolicited bulk or commercial messages in violation of the laws and regulations applicable to your jurisdiction (“spam”). This includes but isn’t limited to sending spam, soliciting customers from spam sent from other service providers, and collecting replies to spam sent from other service providers.

Our Products must not be used for the purpose of running unconfirmed mailing lists or telephone number lists (“messaging lists”). This includes but isn’t limited to subscribing email addresses or telephone numbers to any messaging list without the permission of the email address or telephone number owner, and storing any email addresses or telephone numbers subscribed in this way. All messaging lists run on or hosted by our Products must be “confirmed opt-in”. Verification of the address or telephone number owner’s express permission must be available for the lifespan of the messaging list.

We prohibit the use of email lists, telephone number lists or databases purchased from third parties intended for spam or unconfirmed messaging list purposes on our Products.

This spam and unauthorized message activity policy applies to messages sent using our Products, or to messages sent from any network by the customer or any person on the customer’s behalf, that directly or indirectly refer the recipient to a site hosted via our Products.

Unethical, exploitative, and malicious activity

Our Products must not be used for the purpose of advertising, transmitting, or otherwise making available any software, program, product, or service designed to violate this acceptable use policy, or the acceptable use policy of other service providers. This includes but isn’t limited to facilitating the means to send spam and the initiation of network sniffing, pinging, packet spoofing, flooding, mail-bombing, and denial-of-service attacks.

Our Products must not be used to access any account or electronic resource where the group or individual attempting to gain access does not own or is not authorized to access the resource (e.g. “hacking”, “cracking”, “phreaking”, etc.).

Our Products must not be used for the purpose of intentionally or recklessly introducing viruses or malicious code into our Products and systems.

Our Products must not be used for purposely engaging in activities designed to harass another group or individual. Our definition of harassment includes but is not limited to denial-of-service attacks, hate-speech, advocacy of racial or ethnic intolerance, and any activity intended to threaten, abuse, infringe upon the rights of, or discriminate against any group or individual.

Other activities considered unethical, exploitative, and malicious include:

  1. Obtaining (or attempting to obtain) services from us with the intent to avoid payment;

  2. Using our facilities to obtain (or attempt to obtain) services from another provider with the intent to avoid payment;

  3. The unauthorized access, alteration, or destruction (or any attempt thereof) of any information about our customers or end-users, by any means or device;

  4. Using our facilities to interfere with the use of our facilities and network by other customers or authorized individuals;

  5. Publishing or transmitting any content of links that incite violence, depict a violent act, depict child pornography, or threaten anyone’s health and safety;

  6. Any act or omission in violation of consumer protection laws and regulations;

  7. Any violation of a person’s privacy.

Our Products may not be used by any person or entity, which is involved with or suspected of involvement in activities or causes relating to illegal gambling; terrorism; narcotics trafficking; arms trafficking or the proliferation, development, design, manufacture, production, stockpiling, or use of nuclear, chemical or biological weapons, weapons of mass destruction, or missiles; in each case including any affiliation with others whatsoever who support the above such activities or causes.

Unauthorized use of Wizardline Technologies, Inc. property

We prohibit the impersonation of Wizardline Technologies, Inc., the representation of a significant business relationship with Wizardline Technologies, Inc., or ownership of any Wizardline Technologies, Inc. property (including our Products and brand) for the purpose of fraudulently gaining service, custom, patronage, or user trust.

About this policy

This policy outlines a non-exclusive list of activities and intent we deem unacceptable and incompatible with our brand.

We reserve the right to modify this policy at any time by publishing the revised version on our website. The revised version will be effective from the earlier of:

  • the date the customer uses our Products after we publish the revised version on our website; or

  • 30 days after we publish the revised version on our website.

European Data Privacy Policy

EU-U.S. Data Privacy Framework | UK Extension | EEA Coverage

Effective Date: July 1, 2026

1. Introduction and Scope

Wizardline Technologies, Inc. ("Wizardline," "we," "our," or "us") is a U.S.-based technology company providing PULSE data management, above-store reporting, compliance tracking, and partner connectivity services to Domino's Pizza franchise operators in the United States, Canada, and internationally.

This European Data Privacy Policy applies specifically to personal data that Wizardline receives from individuals located in the European Union (EU), the United Kingdom (UK), Gibraltar, and the European Economic Area (EEA), including Norway and Iceland. It describes how Wizardline collects, uses, shares, and protects such personal data, and explains the rights available to EU, UK, and EEA individuals under the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF.

This policy applies to two categories of personal data as defined by the DPF:

Personal Data other than Human Resources Data

Customer data, client contact data, store-level operational data, financial data, and other commercial personal data received in connection with Wizardline's franchise technology services.

Human Resources Data

Personal data about employees, past or present, of EU, UK, or EEA-based franchise operators, collected in the context of the employment relationship, including labor hours, scheduling data, payroll-related data, tip and mileage data, and other employee data that flows through Wizardline's platform to HRIS and payroll partner systems.

This policy supplements and should be read alongside Wizardline's general Privacy Notice and Consent Policy. In the event of any conflict between this policy and the DPF Principles, the DPF Principles shall govern.

2. Data Privacy Framework Certification

Wizardline Technologies, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.

Wizardline has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.

To learn more about the Data Privacy Framework program and to view Wizardline's certification, please visit: https://www.dataprivacyframework.gov/

DPF Certificationhttps://www.dataprivacyframework.gov/
FTC JurisdictionWizardline Technologies, Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Annual Re-CertificationWizardline maintains its DPF certification through annual re-certification with the U.S. Department of Commerce.

If Wizardline determines at any time that it can no longer meet its DPF obligations, it will promptly notify the Department of Commerce and will take all reasonable steps to continue applying the DPF Principles to personal data previously received under the DPF, or will return or delete such data.

3. Personal Data We Collect and Process

Commercial and Operational Data (Non-HR)

  • Store-level operational and transaction data flowing through the PULSE point-of-sale system
  • Contact details and account credentials of franchise operator personnel
  • Financial reporting data transmitted to authorized accounting and financial service partners
  • Compliance and document management data including license, insurance, food handling, and operational document information

Human Resources and Workforce Data (HR)

  • Employee labor hours and scheduling data
  • Tip and mileage data flowing to payroll and earned wage access partners
  • Payroll-related data transmitted to HRIS and payroll management platforms at the direction of the franchise operator
  • Employee onboarding, staffing, and retention data processed through workforce management and staffing partner integrations at the direction of the franchise operator
  • Earned wage access and employee financial wellness data transmitted to authorized earned wage access platforms at the direction of the franchise operator

Note: Wizardline does not collect social security numbers, government-issued identification numbers, financial account credentials, health data, or other sensitive categories of personal data except where expressly required by a contracted partner service and with appropriate consent.

4. Purposes of Collection and Use

Wizardline collects and processes personal data solely in connection with the delivery of its PULSE data management, above-store reporting, compliance tracking, and partner connectivity services to Domino's Pizza franchise operators. Wizardline processes this data as a service provider acting on behalf of its franchise operator clients and does not use personal data for any purpose beyond those necessary to deliver contracted services, maintain platform security, and fulfill applicable legal obligations.

Personal data is not sold, rented, or shared with third parties for their independent marketing or commercial purposes.

Specific purposes include:

  • Delivering above-store reporting and operational dashboards to franchise operators via Polling Wizard
  • Managing compliance and document expiration tracking via Expiration Wizard Tracker
  • Transmitting operational, financial, and workforce data to authorized third-party partners through the Nexus partner connectivity platform, including payroll and HRIS platforms, earned wage access providers, workforce management and staffing systems, accounting and financial services providers, insurance providers, and security and operations platforms
  • Providing AI-powered operational intelligence through SmartTrainer, a Wizardline portfolio company, including camera-based quality assurance, sales forecasting, and labor optimization
  • Supporting financial reporting and audit functions for franchise operators and their accounting partners
  • Maintaining platform security, system integrity, and technical performance

Personal data will not be used for purposes materially different from those listed above without providing notice and, where required, obtaining consent from the individual or the data controller on whose behalf Wizardline acts.

5. Individual Rights

EU, UK, and EEA individuals whose personal data is processed by Wizardline have the following rights under the DPF Principles:

RightDescription
AccessRequest confirmation of whether Wizardline processes your personal data and receive a copy.
CorrectionRequest correction of inaccurate or incomplete personal data.
DeletionRequest deletion of your personal data where no longer necessary, subject to legal and contractual obligations.
Opt-OutOpt out of disclosure to third parties or for materially different purposes than originally collected.
Opt-In (Sensitive Data)Affirmative express consent required before processing sensitive personal data for new purposes or before disclosure to third parties.
RestrictionRequest restriction of processing in certain circumstances.

To exercise any of these rights, please contact: privacy@thewizardline.com

Wizardline will respond to rights requests within 30 days of receipt at no charge, except where requests are manifestly unfounded or excessive.

6. Choice and Consent

For personal data received from EU, UK, and EEA individuals under the DPF, Wizardline will:

  • Provide individuals with clear and accessible notice of the purposes for which their personal data is collected and used before or at the time of collection
  • Offer individuals a meaningful opportunity to opt out before their personal data is disclosed to a third party or used for a materially different purpose
  • Obtain affirmative express opt-in consent before processing sensitive personal data for new or different purposes or before sensitive personal data is disclosed to a third party
  • Honor any withdrawal of consent promptly and update records accordingly
  • Ensure that denial or withdrawal of consent does not affect the provision of core services unless the data use is essential for service delivery

7. Data Integrity and Retention

Wizardline will take reasonable and appropriate steps to ensure that personal data received from EU, UK, and EEA individuals is:

  • Accurate, complete, and current for its intended use
  • Relevant and limited to what is necessary for the specified purposes
  • Retained only for as long as necessary to fulfill the purposes for which it was collected, to meet contractual obligations, or as required by applicable law

Upon expiration of the applicable retention period, personal data will be securely deleted or anonymized. Wizardline maintains documented retention schedules for all categories of personal data processed under this policy.

8. Security

Wizardline applies reasonable and appropriate technical and organizational security measures to protect EU, UK, and EEA personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

Technical and Organizational Measures

  • Encryption of personal data in transit (HTTPS) and at rest
  • Role-based access controls ensuring personal data is accessible only to authorized personnel
  • Multi-factor authentication for systems processing personal data
  • Regular vulnerability scanning and penetration testing
  • Audit logging of all access to personal data with automated anomaly detection
  • Vendor security assessments prior to onboarding any third-party data processor

Wizardline uses Drata to automate compliance monitoring and evidence collection for its SOC 2 and ISO 27001 frameworks, providing continuous verification of security controls.

In the event of a personal data breach affecting EU, UK, or EEA individuals, Wizardline will comply with applicable breach notification requirements under the DPF Principles and any applicable EU, UK, or EEA law.

9. Onward Transfers to Third Parties

Wizardline operates a partner connectivity platform (Nexus) that transfers PULSE data to authorized third-party partners on behalf of franchise operators. Current partner categories include accounting and financial services, insurance, earned wage access, HR and workforce management, staffing and retention, security and operations, and payments. Specific partner integrations vary by market and are made available at the direction of the franchise operator. All partner integrations are subject to the transfer mechanisms described in this section regardless of the specific platform or vendor involved.

Where Wizardline transfers EU, UK, or EEA personal data to a third-party agent or service provider, Wizardline will ensure that one of the following transfer mechanisms is in place before any transfer occurs:

MechanismDescription
DPF Co-CertificationThe recipient has certified to the DPF Principles for the same category of data.
Written AgreementA written agreement requiring the recipient to provide at least the same level of privacy protection as the DPF Principles.
Standard Contractual ClausesSCCs approved by the European Commission or equivalent mechanisms approved by the UK Secretary of State.
Binding Corporate RulesBCRs approved by the relevant data protection authority.

Wizardline maintains a record of all onward transfer agreements for EU, UK, and EEA personal data, retained for the duration of the vendor relationship and for a minimum of three years following termination.

Wizardline remains liable under the DPF Principles if a third-party agent processes EU, UK, or EEA personal data in a manner inconsistent with the DPF Principles, unless Wizardline can demonstrate it is not responsible for the event giving rise to the damage. If Wizardline becomes aware of such inconsistency, it will take reasonable and appropriate steps to prevent or stop such processing, up to and including termination of the vendor relationship.

10. Human Resources Data

Where Wizardline receives HR Data from EU, UK, or EEA-based franchise operators in connection with the employment relationship, Wizardline will:

  • Process such data only for the purposes for which it was transmitted by the franchise operator and in accordance with the instructions of the franchise operator as data controller
  • Comply with the DPF Supplemental Principles on Human Resources Data
  • Cooperate with and comply with the advice of EU data protection authorities (DPAs) and the UK Information Commissioner's Office (ICO) with respect to unresolved HR Data complaints
  • Apply the same security, access control, and onward transfer requirements described in this policy to HR Data

Franchise operators transmitting HR Data to Wizardline are responsible for ensuring that their employees have been informed of the transfer and that a lawful basis for processing exists under applicable EU, UK, or EEA law.

11. Government Access

Wizardline may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Wizardline will disclose personal data to government authorities only to the extent required by law and will seek to minimize such disclosures consistent with applicable legal requirements.

12. Recourse, Complaints, and Dispute Resolution

Wizardline is committed to resolving complaints about our handling of EU, UK, and EEA personal data. The following four-step process is available to all EU, UK, and EEA individuals:

  1. Contact Wizardline Directly. Contact Wizardline's privacy team at privacy@thewizardline.com. Wizardline will acknowledge receipt within 5 business days and respond substantively within 30 days.
  2. BBB National Programs DPF Dispute Resolution. If your complaint is not resolved to your satisfaction, you may file a complaint with BBB National Programs at no cost: https://bbbprograms.org/programs/all-programs/dpf-consumers
  3. EU Data Protection Authorities. For HR Data complaints, EU and UK individuals may contact their local data protection authority (DPA) directly. A list of EU DPAs is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. For the UK Information Commissioner's Office (ICO), please visit https://ico.org.uk/make-a-complaint/. Wizardline commits to cooperate with and comply with the advice of the relevant DPA or ICO.
  4. Binding Arbitration. As a last resort, EU and UK individuals may invoke binding arbitration through the DPF Arbitration Panel for residual claims not resolved through the above mechanisms, at no cost to the individual. See https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction for more information on this process.

13. Contact Information

Privacy ContactShawn Brunelle, CEO
Emailprivacy@thewizardline.com
Mailing AddressWizardline Technologies, Inc., PO Box 9, Hampton Falls, NH 03844, United States