Privacy Policy

IBA Conversions, LLC (“Company”, “we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites, applications, products, and services that link to this policy (our “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

  • Through the Services.
  • In communications, including email, text, chat, and other electronic messages, between you and the Services.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) that does not link to this policy; or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time. Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

  • Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
  • Lawfully obtained, truthful information that is a matter of public concern.
  • Deidentified or aggregated consumer information.

Personal Information Categories Chart

The chart below identifies which categories of personal information we collected from our consumers within the last 12 months.

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“California Customer Records”).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law (“Protected Classes”).

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision making, military and veteran status, or genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Activity on our websites, mobile apps, or other digital systems, such as internet browsing history, search history, system usage, electronic communications with us, postings on our social media sites.

YES

G. Geolocation data.

Physical location or movements, such as the time and physical location related to use of our internet website, application, or device, and GPS location data from mobile devices of consumers who visit our websites or use our mobile apps.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information, including customer service call monitoring and store video surveillance.

NO

I. Professional or employment-related information.

Current or past job history.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (“FERPA Information”).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

L. Sensitive personal information.

Further identified in the chart below.

NO

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer.

The chart below identifies which sensitive personal information categories, if any, we have collected from consumers to infer characteristics about them in the last 12 months.

Sensitive Personal Information Category

Collected to Infer Characteristics?

L.1. Government identifiers, such as your Social Security number (SSN), driver’s license, state identification card, or passport number.

NO

L.2. Complete account access credentials, such as usernames, account logins, account numbers, or card numbers combined with required access/security code or password.

NO

L.3. Precise geolocation, such as physical store visits or physical locations when visiting websites or using mobile apps.

NO

L.4. Racial or ethnic origin.

NO

L.5. Citizenship or immigration status.

NO

L.6. Religious or philosophical beliefs.

NO

L.7. Union membership.

NO

L.8. Mail, email, or text messages not directed to the Company.

NO

L.9. Genetic data.

NO

L.10. Neural Data, such as information generated by measuring a consumer’s central or peripheral nervous system’s activity that is not inferred from nonneural information.

NO

L.11. Unique identifying biometric information.

NO

L.12. Health information.

NO

L.13. Sex life or sexual orientation information.

NO

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you, such as from the forms or other information you provide to the Company.
  • Indirectly from you, such as from your interactions with the Company’s websites, mobile applications, store visits, reward program participation, customer service programs, or, membership program participation.
  • Video and other similar surveillance systems, such as automated license plate readers.

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

  • A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
  • Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling under applicable laws, you may opt out of their use depending on where you live. Please note that some features of the Services may be unavailable as a result. You may also request to have your personal data deleted; however, doing so will permanently close your account.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information we collect to advance the Company’s business and commercial purposes, specifically to:

  • Develop, offer, and provide you with our products and services.
  • Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or to comply with legal requirements.
  • Fulfil the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
  • Improve our products or services, marketing, or customer relationships and experiences.
  • Notify you about changes to our products or services.
  • Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
  • Protect our Company, employees, or operations.
  • Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
  • Manage your consumer relationship with us, including for:
    • online account creation, maintenance, and security;
    • reaching you, when needed, about your account; and
  • Perform data analytics and benchmarking
  • Administer and maintain the Company’s systems and operations, including for safety purposes.
  • Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
  • Comply with all applicable laws and regulations.
  • Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
  • Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

  • Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect.
  • Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
  • Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
  • Ensuring physical safety.
  • Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
    • disclose the sensitive personal information to another third party; or
    • use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
  • Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
  • Activities required to:
    • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
    • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
  • Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes. For more on your right to limit these additional sensitive personal information use purposes, see Your Rights and Choices.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to third parties for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section and in the table below, such as to engage third parties to support our business functions.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The list below identifies the categories of personal information that we have disclosed in the last 12 months for business or commercial purposes.

LIST OF CATEGORIES FROM CHART ABOVE DISCLOSED IN THE LAST 12 MONTHS

Selling or Sharing Personal Information

We do not sell your personal information, including sensitive personal information, to third parties, but have not sold it in the preceding 12 months. We do not share your personal information with third parties for cross-context behavioral advertising purposes and have not shared your personal information in the preceding 12 months.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). Our response will cover the 12-month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may make exercise your right to know twice within in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

  • The categories of:
    • personal information we collected about you; and
    • Sources from which we collected your personal information.
  • The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
  • If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
    • disclosed for a business purpose to each category of persons; and
    • sold or shared to each category of third parties.
  • When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct.

Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit”). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes, we do not currently provide this consumer right/Once we receive your valid request, we will limit the use and disclosure of your sensitive personal information to the Permitted SPI Purposes. For more on exercising this right, see How to Exercise Your Rights.

For more on the Permitted SPI Purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”)

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

If you are a resident of California, to exercise the right to know, data portability, delete, opt-out, limit, or correct described above, please submit a verifiable request to us by either:

  • Call us at (832) 356-3330.
  • Emailing us at info@britebrotherscarwash.com
  • Visit us at www.britebrotherscarwash.com

You or your authorized agent may only submit a request to know, including for data portability, twice within a 12-month period. Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, Correct, Limit, or Opt-Out

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact us at info@britebrotherscarwash.com

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Services do not respond to Do Not Track signals. Some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy’s effective date and post the updated policy on our website to provide you with the updated policy.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: (415)378-7378

Website: www.britebrotherscarwash.com

Email: info@britebrothercarwash.com

Postal Address:

IBC Conversions, LLC

 

 

Attn: Alexander Ivanov

12610 Tomball Pkwy, Houston, Texas, 77086

If you need to access this Privacy Policy in an alternative format due to a disability, please contact info@britebrotherscarwash.com or info@britebrotherscarwash.com.

Last Updated on: July 11, 2025