Privacy policy
Frontier Strategy Group LLC. (“FrontierView”) is committed to maintaining the confidentiality, integrity, and security of personal information about FrontierView’s current and prospective customers. Whether through a tablet, mobile device, or other means, by accessing, viewing or using FrontierView TM , FrontierView’s websites, digital newsletters, social media, mobile, other products and services, and applications owned and operated by FrontierView (collectively referred to as the “FrontierView Services”) and also through any non-digital contacts with FrontierView, you hereby consent to the collection, use and disclosure of your personally identifiable information under the terms of this Privacy Policy.
This Privacy Policy is compliant with the European Union’s General Data Protection Regulation per Regulation (EU) 2016/679 (“GDPR”), the applicable personally identifiable information protection laws of the United States and any other non-GDPR country where FrontierView conducts business (together, the “Privacy Laws”). In the event of a conflict between the GDPR and a non-GDPR country’s applicable protection laws, the Privacy Law(s) that provides the greatest level of protection will supersede and control as required under the circumstances. FrontierView will review this Privacy Policy periodically in light of changing Privacy Laws, regulatory requirements, business practices and technology. Any changes to this Privacy Policy will be posted with prominent notice at least thirty (30) days prior to the changes taking effect.
Although FrontierView takes appropriate measures to safeguard your personally identifiable information, FrontierView cannot guarantee its absolute security. As such, FrontierView recommends that you use complex passwords for your accounts with FrontierView and for accounts with third parties that you link to any of your accounts with FrontierView to further protect your PII.
If you have any questions or would like to review, change, delete your PII, object to the processing of your PII, opt-out from marketing activities, or remove your posts from FrontierView owned platforms, in addition to the other communication methods contained in this Privacy Policy, please feel free to contact FrontierView via email at [email protected] or in writing at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. FrontierView will comply with your request as soon as reasonably practicable.
1. Personally Identifiable Information.
When you use or otherwise interact with the FrontierView Services, FrontierView may gather personally identifiable information (“PII”). PII is information that identifies you as an individual or relates to an identifiable individual. Depending on the type of product or service being used, different kinds of PII can be gathered when using the FrontierView Services. PII may include, without limitation, names, postal addresses, email addresses, and telephone numbers. If you disclose any PII relating to other people when using the FrontierView Services, you represent that you have the authority to do so and permit FrontierView to use the PII in accordance with this Privacy Policy. You should not send or disclose sensitive personally identifiable information through the FrontierView Services or otherwise to FrontierView including, without limitation, social security numbers, racial or ethnic origin information, political opinions, religious or other beliefs, health information, biometrics or genetic characteristics, criminal background, or trade union membership.
2. Collection, Use or Processing of PII.
FrontierView may collect, use or otherwise process PII for various reasons including, without limitation, the following: (a) the consent you provide to FrontierView at any point of collection; (b) when you register for the FrontierView Services, FrontierView may collect PII including, without limitation, an email address and password; (c) for billing purposes, FrontierView may collect and use your name, address, telephone number, email address, credit or debit card information, or other billing information; (d) to deliver and enable the use of the FrontierView Services; (e) during performance of the FrontierView Services; (f) to fulfill your requests for additional products and services; (g) to provide functionality; (h) to arrange access to your registered account; (i) to provide you with customer service or technical service; (j) to respond to your inquiries, requests, questions, suggestions, or complaints; (i) to complete your transactions; (k) to send you with information, notices, promotions, or surveys; (l) for the legitimate interests of FrontierView, a third party, or yourself if valid reasons exist and measures are taken to protect your privacy rights; (m) to conduct business operations within FrontierView; (n) to ensure that FrontierView’s networks and information are secure; (o) to prevent fraudulent or criminal activities; or (p) to comply with applicable laws, regulations, and legal processes and obligations. FrontierView may provide PII to FrontierView’s affiliates for the purposes identified in this Privacy Policy. PII may be collected in your country and subsequently transferred to FrontierView’s headquarters in the United States, to another country where FrontierView has facilities, or to FrontierView’s service providers. The courts, governmental authorities, law enforcement agencies, regulatory agencies or security authorities of such other countries may be entitled to access your PII.
3. Analysis of Your Use of the FrontierView Services.
FrontierView may collect and store information about the computer, mobile device or other devices you use to access the FrontierView Services. Such information regarding your use of the FrontierView Services may include, without limitation, your device type, internet protocol addresses (the region or general location where your computer or device is accessing the Internet), operating system, unique device identifiers, browser type, browser language, web server logs, the name of your Internet service provider, information on the countries you track, the metrics you view and track, how your metrics are weighted, the number of links you click, the pages visited, the date and time of your visit, the average time of usage, web pages you linked, and any other information about your use of the FrontierView Services. FrontierView also may combine this information with other information FrontierView may collect about you. FrontierView may use this information optimize the FrontierView Services including, without limitation, to customize features and recommendations, improve design and functionality, and facilitate site navigation.
4. Development of New Products and Services.
FrontierView may perform statistical, demographic and marketing analyses of a user’s use of the FrontierView Services so FrontierView may analyze or predict a user’s preferences for product and services development purposes and to determine FrontierView’s promotional campaign effectiveness so FrontierView can adapt such campaigns to the needs and interests of users. FrontierView also may use this information to improve customer relationships, to support strategic business and marketing decisions, and to measure and track FrontierView’s brand health. FrontierView may engage in these activities to manage FrontierView’s contractual relationship with you, to comply with applicable laws, regulations, and legal processes and obligations, or because FrontierView has a legitimate interest in doing so.
5. Administrative Purposes.
FrontierView and FrontierView’s service providers use the information FrontierView has about you for the following administrative purposes: (a) for auditing purposes, to verify that FrontierView’s internal processes function as intended and comply with legal, regulatory and contractual requirements; (b) for fraud and security monitoring purposes including, without limitation, detecting and preventing cyberattacks; or (c) to monitor your satisfaction with the FrontierView Services or FrontierView’s Customer Service and Information Technology Departments.
6. Acquisition, Merger, Sale or Other Disposition.
FrontierView may have a legitimate interest in disclosing or transferring PII to a third party in the event of any acquisition, merger, sale, or other disposition of all or any portion of FrontierView’s business, assets or stock. Such third parties may include an acquiring entity and its representatives and advisors.
7. Sharing PII with Service Providers.
FrontierView will not sell, rent, swap or authorize any third party to use your email address, provided, however, that FrontierView may contract with service providers to provide services on FrontierView’s behalf. These services may be for payment and billing processing, information technology, security services, and other forms of legitimate business. In the course of performing such services, FrontierView’s service providers may access PII subject to applicable laws, regulations, and legal processes and obligations.
8. Tracking Technologies.
FrontierView and its service providers may use cookies, pixel tags, web beacons, scripts and other technologies to track certain information about you or your use of the FrontierView Services (together, “Tracking Technologies”). These Tracking Technologies allow the support, operation, and use of the FrontierView Services. Access to certain areas of FrontierView’s websites, including www.app.frontierview.com, may not be allowed if your computer does not accept Tracking Technologies. Some advertisements, promotions, and other marketing tools included in the FrontierView Services may be delivered or served by third party providers, which may collect information about your use of the FrontierView Services. FrontierView does not have access to, nor control over, these service providers’ use of Tracking Technologies or how they may be used. Your access to FrontierView’s websites should not be affected if you do not accept Tracking Technologies served by these third parties.
9. Non-Personally Identifiable Information Collected.
Other information that does not specifically identify you and is not personally identifiable information may be collected and used by FrontierView. FrontierView may use and disclose this non-personally identifiable information for any purpose. If FrontierView combines non-personally identifiable information with PII, FrontierView will treat the combined information as PII.
10. Aggregating and/or Anonymizing PII.
FrontierView monitors users’ activity and preferences and may compile aggregate data concerning the broad interests represented within its user base. In such cases, FrontierView will aggregate and/or anonymize any PII so that it will no longer be PII. FrontierView may use and disclose aggregated or anonymize information for any purpose. If FrontierView combines aggregated or anonymize information with PII, FrontierView will treat the combined information as PII.
11. Opt-Out from Marketing Activities.
If, at any time, you prefer not to receive marketing email, telephone, or any other solicitations originated by FrontierView and wish to opt-out, please either (a) for marketing email solicitation, please follow the “unsubscribe” instructions located near the bottom of each email or (b) for marketing email, telephone or any other solicitations, please send an “unsubscribe” directive to FrontierView at [email protected]. FrontierView also may be reached via mail at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. Please include your account number and phone number in the body of your email or letter, and place “Opt-Out” in the subject line. It is important to note that this opt-out request does not prohibit FrontierView from sending you important administrative disclosures for non-marketing purposes. FrontierView will comply with your request as soon as reasonably practicable.
12. Your California Privacy Rights.
Under the California “Shine The Light” law, California residents may opt-out of FrontierView’s disclosure of PII to third parties for direct marketing purposes. If, at any time, you wish to opt-out, please contact FrontierView via email at [email protected] or in writing at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. Please include your account number and phone number in the body of your email or letter, and place “Opt-Out” in the subject line. It is important to note that this opt-out request does not prohibit FrontierView from sending you important administrative disclosures for non-marketing purposes. FrontierView will comply with your request as soon as reasonably practicable.
13. Public Activities.
FrontierView may offer you opportunities to engage in public activities. Public activities are any actions designed to be visible to other users, including comments, recommendations, reader reviews, ratings and other similar communications whereby any submitted PII may be read, collected and used by others publicly. FrontierView is not responsible for your submission of PII during your public activities. FrontierView has no responsibility to publish, take down, remove or edit any of your public activities or submissions except if required by applicable laws, regulations, and legal processes and obligations. Any information you disclose during your public activities will be covered by the privacy policy maintained by the receiving party on its platform and not this Privacy Policy.
14. PII Retention.
FrontierView may retain PII for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable laws, regulations, and legal processes and obligations, or because FrontierView has a legitimate interest. The criteria used to determine FrontierView’s retention periods include: (a) the length of time FrontierView has an ongoing relationship with you and provide the FrontierView Services to you; (b) whether there is a legal obligation to which FrontierView is subject; or (c) whether retention is advisable in light of FrontierView’s legal position.
15. Legal and Regulatory Compliance.
FrontierView may access, preserve and disclose PII if FrontierView is required to do so by law or FrontierView has a good faith belief that such action is necessary to (a) comply with applicable laws, regulations, and legal processes and obligations; (b) cooperate with courts, governmental authorities, law enforcement agencies, regulatory agencies or security authorities; (c) protect the personal safety or property of FrontierView’s users or the public; or (d) protect and defend FrontierView’s rights and property including, without limitation, protecting against any misuse or unauthorized use of the FrontierView Services.