FRONTMAN PRIVACY POLICY

Effective Date: January 4, 2021

Frontman Inc. (“Frontman”, “we” or “us”), the operator of the www.befrontman.com site (the “Site”), is committed to preserving the privacy of those who visit and interact with the Site. This Privacy Policy (“Policy”) describes how we may collect, use, and disclose your information when you access or use our Site. This Policy does not apply to information collected by any other website or third party that may link to or be accessible through our Site. Third parties may use tracking technologies in connection with our website. This Policy does not apply to these third-party technologies because we are not responsible for, and may not control, such third parties or their technology.

 

Please read this Policy carefully. By accessing or using the Site, you indicate that you have read, understood and agree to this Policy, and you consent to all actions taken by us with respect to your information in compliance with this Policy. If you do not want to agree to this Policy, then you must not access or use the Site.

 

We may make changes to this Policy from time to time. If we make material changes to this Policy, we will let you know by posting a prominent notice on the Site, by sending you an email, or other similar method of contacting you. The date that this Policy was last revised is identified at the top of this page. Any revised version of this Policy supersedes all previous versions.

Information We Collect About You

 

We collect your information:

• Directly from you, when you provide it to us, such as when you create an account or purchase products.
• Indirectly from you, from observing your actions on the Site.
• Automatically as you access, navigate, or use the Site. This information may include traffic data, location data, logs, usage details, IP addresses, browser and device type, and information collected through cookies, web beacons, and other tracking technologies operated by us or third parties.
• From other users, such as through our loyalty and refer-a-friend programs. If you choose to participate in our refer-a-friend program or provide information to or about someone else as part of our refer-a-friend program, we will collect information about your friend (such as a name and email address) in order to invite your friend to shop with us.
• When you access the Site through a social network, if you interact with us on social media, such as information about those interactions.
• When you interact with our advertising and applications on third-party websites and Site, if those applications or advertising include links to this Policy.

 

We may collect the following categories of personal information:

Categories of Personal Information	Specific Types of Personal Information Collected
Identifiers such as your real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.	•       name •       contact information (phone number, email address, physical address, etc.) •       account names and online identifiers •       IP addresses, operating system type and version, device identifiers, and other information collected through cookies or other passive means
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual	•       details of transactions you carry out through our Site, including financial information, such as credit/debit card information, account numbers related to your purchases, and other financial information •       records and copies of your correspondence (including email addresses), if you contact us •       purchases and usage of our Site, including how you use and interact with our Site (including information about frequency, duration, date and time, quantity, quality, and performance information related to logins, clicks, and other use information) •       other data or pieces of information that may identify you individually
Commercial information	•       products purchased, obtained, or considered and purchasing or consuming histories or tendencies
Geolocation data	•       where you are located when you are using our Site
Internet or other electronic network activity information	•       browsing history, search history, and information regarding interaction with our website and other websites, applications, or advertisements
Professional or employment-related information	•       job titles or employment roles
Inferences may be drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, abilities, and aptitudes.

 

We process and use the above information in order to fulfill our contractual obligations, when we believe we have a legitimate interest to do so consistent with applicable law, and/or when we have your consent. Our contractual obligations and legitimate interests may include:

• To provide our Site and products or information that you request from us.
• To contact you about your account, the Site, or our policies.
• To configure and maintain your account.
• To create or derive anonymous, aggregate information or data that does not identify you or any other particular individual.
• To develop, operate, maintain, improve, and enhance our Site and to train our personnel.
• To fulfill the purpose for which you provide it. For example, if you provide your personal information to purchase our products, we will use that information to process your payment and fulfill your order. We may also save your information to facilitate new purchases, Site, and maintenance.
• To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collection.
• To protect ourselves, our Site, and our customers, in the event of breach of contract, fraud, harmful, unauthorized, illegal or other types of activity.
• To contact you about goods and services that may be of interest to you and to send you our newsletter, depending on your communication preferences.
• In any other way we may describe when you provide the information, or for any other purpose upon your consent or request.

 

You may be given the opportunity to opt in to receiving text messages from Frontman directly through us or through one of our third-party service providers. Some text messages may be sent via an automated SMS platform. Your consent to receive text messages is not required in order to purchase our any goods or services, and you may revoke your consent at any time. Please refer to the text messaging opt-in request provided to you for more information.

 

Disclosure of Your Information

 

We do not sell or rent your personal information to third parties for any purposes, including marketing, but we may provide your information to third parties that may market their products or Site to you if you have consented to or not opted out of these disclosures.

 

We may disclose personal information that you provide to us or that that we collect from you:

• To our affiliates or other related entities and subsidiaries.
• To our contractors, service providers, and other third parties that we use to support our business and who are bound by contractual obligations to protect your information and only use it for limited purposes associated with our Site.
  • We employ service providers to perform tasks on our behalf and to assist us in providing the Sites, such as hosting services, payment processors, and shipping carriers.
  • Please note that in order to process your payment and ship your order, we must provide your personal information to our payment processors and shipping carriers. These shipping vendors and payment processors will have an independent relationship with you so that they can address any issues with a shipment or payment, as applicable. Please refer to the privacy policy of the applicable shipping vendor or payment processor to learn more about their privacy practices.
• To enforce or apply our service terms and other agreements, including for billing and collection purposes.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, or if we believe disclosure is necessary or appropriate to protect the rights, property, or our safety or the safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us from our website users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information, or with your consent.

 

We may disclose anonymous, aggregate information about you, other users of our Site, or our other customers without restriction as long as that information does not identify any particular individual.

 

Automatic Collection of Your Information Through Cookies and Other Technologies

 

We use a number of methods and technologies for automatically collecting data and information, which may include:

• Cookies (or browser cookies). A “cookie” is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by adjusting your browser settings. However, if you disable cookies, you may not be able to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
• Web Beacons. Certain parts of our Site may contain small electronic files known as “web beacons” (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to track certain types of data, for example, to count users who have visited those websites, and for other related Site statistics (for example, recording the traffic data of certain Site and verifying system and server integrity).

 

Analytics and Advertising

 

We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in mobile applications. They may use cookies, web beacons, and other technologies to collect information about your use of the Site and other websites and applications, including your IP address, device identifier, browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Frontman and others to, among other things, analyze and track data, determine the popularity of content, deliver advertising and content targeted to your interests on our Site and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for interest-based advertising purposes, please visit www.aboutads.info/choices. European users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance.

We may also work with third parties to serve ads to you as part of a customized campaign on third-party service providers (such as Facebook or Google). As part of these ad campaigns, we or third-party service providers may convert information about you, such as your email address, into a unique value that can be matched with a user account on these service providers to allow us to learn about your interests and to serve you advertising that is customized to your interests. Note that the third‑party service providers may offer you choices about whether you see these types of customized ads. Any data collected by such third-party service providers will be used in accordance with the privacy policy of such third-party provider.

You can opt out of personalized ads, including remarketing or you view, add, and remove the topics that are used to show personalized ads across the Google Display Network through Google Ad Settings. You can also review various guidelines for advertisers, publishers, ad networks, and other groups involved in online advertising from https://www.networkadvertising.org/ and https://www.iab.com/.

We will store your personal information in our electronic records, or in those of our third-party service providers or contractors, on our servers or the servers of our third-party service providers or contractors. We retain your personal information for different periods of time depending on the type and nature of the data and the purpose for which we have it. We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention is required or permitted by law.

 

Children Under the Age of 13

 

Our Site is not intended for children under 13 years of age. We do not knowingly collect information from children under the age of 13, and we will not intentionally collect or maintain information about anyone under 13. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will use all reasonable efforts to delete such information.

 

Controlling Your Information

 

There are various ways that you can control your information:

• You may review, update, or modify your account information, including profile, contact, payment and shipping information, at any time by logging into your Frontman account.
• You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
• You may unsubscribe from our newsletter and promotional emails at any time by following the instructions included in those emails. If you opt out of receiving such communications, note that we may continue to send you non-promotional emails (such as order confirmation emails or emails about changes to our legal terms).
• If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by contacting us and changing your browser cookie settings.
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However, some third parties may provide you with ways to choose not to have your information collected or used in this way.
• If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To do so, please send us a request using the contact information listed at the end of this Policy.
• Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to hey@befrontman.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

 

Requesting Access, Control, or Changes to Your Information

You can request to access, correct, delete or export any personal information that you have provided to us by contacting us using the contact information at the end of this Policy, or if you have established an account with us, you can review and modify your information through your account. We will promptly review all such requests in accordance with applicable laws. It is important that you let us know as soon as possible if you believe that any personal information that we have about you is incorrect, or is, has been, or might be used inappropriately, so we can take commercially reasonable steps to correct, delete, or restrict the use of such information, as appropriate. Please note that we cannot delete your personal information without also deleting your user account. If we are processing your personal information based on your consent (as indicated at the time of collection), you have the right to withdraw your consent. If you exercise this right, you may need to provide express consent on a case-by-case basis each time the use or disclosure of your information is necessary for you to utilize our Site.

There are some circumstances where we will not be able to fulfill your request, for example, if regulatory obligations, legal matters, or certain operational or technical constraints prevent us from doing so. We will not accommodate a request to change information if we believe the change would cause the information to be incorrect or violate any law or legal requirement. Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any rights concerning your personal information. We encourage you to first reach out to us in accordance with the contact information set forth below so we have an opportunity to address your concerns directly before you do so.

Rights under CCPA

 

If you reside in California, the California Consumer Privacy Act of 2018 (“CCPA”) provides you with specific rights regarding your personal information, set forth below:

 

Access to Specific Information and Data Portability Rights	You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: •    The categories of personal information we collected about you. •    The categories of sources for the personal information we collected about you. •    Our business purpose for collecting that personal information and the disclosures we have made for a business purpose, identifying the personal information categories that each category of recipient obtained. •    The categories of third parties with whom we share that personal information. •    The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Rights	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. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Response Timing and Format	We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (for a maximum total of 90 days), we will inform you of the reason and extension period in writing.   Any disclosures we provide will only cover the 12-month period preceding the receipt of a verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 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 consumer request unless the request 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. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
Personal Information Sales Opt-Out and Opt-In Rights	We do not sell the personal information of consumers.
Non-Discrimination	We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: •    Deny you goods or Site. •    Charge you different prices or rates for goods or Site, including through granting discounts or other benefits or imposing penalties. •    Provide you a different level or quality of goods or Site, including denial of goods or Site. •    Suggest that you may receive a different price or rate for goods or Site or a different level or quality of goods or Site.
Exercising Access, Data Portability, and Deletion Rights	To exercise the access, data portability, and deletion rights described in this section, please submit a verifiable consumer request to us: •    By submitting a request through the Site •    By email: hey@befrontman.com   Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.   You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: •    Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. •    Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.   We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.   Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the personal information requested.   We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Reasons We May Deny Your Request	•    We may deny your deletion request if retaining the information is necessary for us or our service providers to: •    Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. •    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. •    Debug products to identify and repair errors that impair existing intended functionality. •    Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law. •    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). •    Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. •    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. •    Comply with a legal obligation. •    Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

 

Transfer of Information to the United States; Rights under the General Data Protection Regulation (“GDPR”)

Our website is operated in the United States. The privacy and data protection laws in the United States differ from those of other countries. If you are located outside of the United States, please be aware that the information that we collect will be transferred to and processed, stored, and used in the United States, and that by using our sites and applications, you consent to such transfers and processing.

 

If you are a resident of the European Economic Area, the GDPR provides you with specific rights regarding your personal information. Depending on where you are located and the applicable privacy laws that apply to our use or processing of your personal information, you have the right to access personal data we hold about you and to ask that your personal data be corrected, updated, or deleted. You may also have the right to withdraw your consent to processing and object to, or request that we restrict, certain processing.

 

Data Protection and Security

You are responsible for the safety and security of your information, including taking steps to actively protect your information, such as keeping your login credentials confidential and restricting access to your account. We strive to use commercially reasonable and appropriate technical and organizational security means to protect your information, but we cannot guarantee its security. Any transmission of personal information through the Site is at your own risk, and we are not responsible for the circumvention of any privacy settings, or technical or security measures.

Contact Us

If you have a questions or requests in connection with this Policy or our information collection practices, please contact us:

By Mail: Frontman Inc. 1207 Sidney St, Saint Louis MO 63104

Text us: (213) 214-1242

Email us: hey@befrontman.com