PERSONAL INFORMATION WE COLLECT
We collect information about you from different sources and in various ways when you use the Services, including information you provide directly, information collected automatically, third-party data sources, and information we infer or generate from other information.
Information you provide to us. Personal information you may provide to us through the Services or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, mailing address, professional title and company name, and phone number.
- Communications data based on our exchanges with you, including when you contact us through the Services, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Investor preferences data, such as information regarding which types of investment opportunities you may be interested in
- Profile data,such as the username and password that you may set to establish an online account with the Services.
- Your investment profile, such as the information such as your income, investment objectives, age, investment history, liquid assets, etc. in order to determine investment suitability.
- Your status, such as the information about legal and financial status to verify that an investor is an “accredited investor” or a “qualified purchaser”
When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain features, those features may not be available or function correctly, and/or we may not be able to provide the Services to you.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, including from public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:
- Device data,such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data suchas your interactions with our email, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Information we create or generate. We infer new information from other information we collect, including using automated means to generate information about your likely preferences or other characteristics. For example, we infer your general geographic location (such as city, state, and country) based on your IP address
Cookies and similar technologies. We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use the Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services.
You can decide whether or not to accept cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can also delete all Cookies that are already on your device. To find out about the cookie settings that are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, please refer to www.allaboutcookies.org.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Services delivery and operations. We may use your personal information to:
- provide, operate and improve the Services and our business;
- communicate with you about the Services, including by sending announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Services and our communications; and
- provide support for the Services, and respond to your requests, questions and feedback;
- to create and manage your account or other user profiles;
- To improve and develop the Services, including testing, research, analysis and product development;
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services;
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
Marketing. We and our service providers may collect and use your personal information to send you direct marketing communications. You may opt-out of our marketing communications by contacting us at firstname.lastname@example.org.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Services; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Services.
- Functionality. To enhance the performance and functionality of our Services.
- Analytics. To help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. To provide this service, Google Analytics may collect certain information about you from your computer using cookies.
HOW WE SHARE YOUR PERSONAL INFORMATION
- Service providers. Third partiesthat provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, customer research, etc.)
- Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.
- Business and marketing partners. Third partieswith whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.
- Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
- Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
- Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Frontier, our parent, our affiliates, or our subsidiaries (including, in connection with a bankruptcy or similar proceedings).
Communications preferences. You can choose whether to receive promotional communications from us by email. If you receive promotional email from us and would like to stop, you can do so by following the directions in that message or by contacting us as described below. These choices do not apply to certain informational communications and mandatory service communications.
Access, correction, and deletion. If you wish to access, correct, or delete personal information about you that we hold about you, please email us at email@example.com.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal information;
- If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
- If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your personal information after your death.
To make such requests, please email us at firstname.lastname@example.org. When we are processing data on behalf of our business customer that is the “data controller,” you should direct your request to that business. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary for the functionality and maintenance of our Services, operate our business, meet our contractual and legal obligations, protect the security of our systems and our users, or fulfill other legitimate interests.
CALIFORNIA RESIDENT RIGHTS
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us.
RETENTION OF PERSONAL DATA
We retain personal information for as long as necessary for operation of our Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different transactions, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.
OTHER SITES AND SERVICES
The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFER
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
IF YOU ARE UNDER 18 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER. WE DO NOT PERMIT CHILDREN UNDER 18 YEARS OF AGE TO REGISTER FOR AN ACCOUNT OR ACCESS OR USE THE SERVICES UNDER ANY CIRCUMSTANCES.
Effective as of February 23, 2023.