Privacy Policy
Last Updated: October 12, 2021
Overview
FrontLobby Financial Inc., doing business as FrontLobby (“FrontLobby“) is committed to protecting your privacy. This Privacy Policy (“Policy“) describes to you our practices for collecting, using, maintaining, protecting, and disclosing the Personal Information (as defined below) we collect from users of our website, located at frontlobby.com, app.frontlobby.com, and any subdomains (“Site“) and the services made available through the Site (“Services“). Additional policies and a description of the services are provided in the Site’s Terms of Use and Terms of Service which also define usage and restrictions of our Services.
This Policy applies to the information we collect: on the Site; in email, SMS, and other electronic messages between you and the Site; when you interact with our advertising and applications on third party websites and services, if those applications and advertising include links to this Policy. This Privacy Policy does not apply to information collected by: (i) us offline or through any other means, including on any other website operated by FrontLobby or any third party (including our affiliates and subsidiaries); or (ii) any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from the Site.
This Policy applies to all visitors, users, and others who visit and use the Site (“consumers” or “you”). This Policy complies with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
The CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements which we also exempt as applicable.
User Consent
Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Site. By accessing or using the Site, you agree to this Policy.
Changes to Our Privacy Policy
We reserve the right to amend this privacy Policy from time to time to comply with applicable laws or to conform to our current business practices. When we make changes to this privacy Policy, we will post the updated Policy on the Site and update the Last Updated date. Your continued use of the Site following the posting of changes is deemed to be acceptance of such changes, so please check the Policy periodically for updates.
Data Security
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and encrypted using SSL technology. For more detailed information please see our Security Policy, located in the footer of the Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Information We Collect
We collect 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, household, or device (“Personal Information“). Personal Information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA). The information collected subject to the aforementioned statutes are handled in accordance with the applicable statute.
In particular, through the Site, we have collected the following categories of Personal Information from consumers within the last twelve (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)).
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.
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, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
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.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
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)).
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
Through the Site, we obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from you when you provide it to us. For example, from forms you complete or products and services you sign up for.
- Indirectly from you, from observing your actions on the Site. We automatically collect the information as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies. For example, from observing your actions on the Site.
- From third parties, for example, our users and partners.
Information You Provide to Us
The information we collect on or through the Site may include:
- Information that you provide by filling in forms on the Site. This includes information provided at the time of registering to use the Site, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with the Site.
- Records and copies of your correspondence (including email addresses) if you contact us.
- Bank statements, payment records, lease agreements, and proof of identity.
You also may provide information to be published or displayed (hereinafter, “posted“) or transmitted to other users of the Site or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve the Site and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Site.
The technologies we use for this automatic data collection may include:
- Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the 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 the Site.
- Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit FrontLobby, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Information Obtained from Third Parties
If you provide us Personal Information about third parties, or if third parties give us your information, we will only use that information for the specific reason for which it was provided to us. This includes information from credit bureaus, financial institutions, or other sources used to enhance use of our Services.
Use of Personal Information
In general, Personal Information is used in the following ways:
- To provide the Services.
- To personalize and better tailor the features, performance and support of the Services.
- To send administrative notifications, including security or support and maintenance advisories.
- To respond to inquiries or other requests.
- To send you promotional/marketing information, newsletters, surveys, offers or other information.
- To provide you with opportunities and functionality that we think would be of particular interest to you.
- To improve the quality of the Site and the Services.
- To analyze, benchmark and conduct research on, user data and user interactions with the Services.
- To conduct market research, planning, troubleshooting, planning problems, detecting and protecting against error, fraud, or other criminal activity.
- To solicit your feedback.
We may use, sell or disclose the Personal Information we collect for one or more of the following business purposes:
- To fulfill or meet the reason the information was provided.
- To provide, support, personalize, and develop the Site, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through the Site, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of the Site, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve the Site, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
- To evaluate or conduct 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 about the Site users/consumers is among the assets transferred.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
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.
Disclosure of Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- 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 FrontLobby’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by FrontLobby about the Site users is among the assets transferred.
- To third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FrontLobby, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may share Personal Information by disclosing it to a third party for a business purpose or sell Personal Information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-In and Opt-Out Rights). We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We share your personal information with the following categories of third parties:
- Service providers.
- Data aggregators.
- Customer Relationship Management (CRM) platforms.
In the preceding twelve (12) months, FrontLobby has disclosed the following categories of Personal Information for a business purpose:
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
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.
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, veteran or military status, genetic information (including familial genetic information).
YES
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
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.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
YES
G. Geolocation data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information.
Current or past job history or performance evaluations.
NO
J. Non-public education 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
Reselling Personal Information
The CCPA prohibits a third party from reselling Personal Information unless you have received explicit notice and an opportunity to opt-out of further sales.
Choices About How We Use and Disclose Your Information; Your Rights and Choices
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Under CCPA, California residents have specific rights regarding their Personal Information. The section below describes a California resident’s CCPA rights and explains how to exercise those rights and applies to all users of the Site.
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 (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), 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 or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you.
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
o sales, identifying the Personal Information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the Personal Information categories that each category of recipient received.
Deletion Request 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 (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 their 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 that information that are compatible with the context in which you provided it.
We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a verifiable request by emailing us at support@staging.dev.frontlobby.com.
Only you or a person authorized to act on your behalf may make a request.
You may only submit a request to know twice within a 12-month period. Your request to know or delete 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.
You do not need to create an account with us to make a request.
We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make the request.
For instructions on exercising your sale opt-out rights, see Personal Information Sales Opt-In and Opt-Out Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days of receiving it. If you do not receive confirmation within the 10-days, please contact support@staging.dev.frontlobby.com.
We endeavor to substantively respond to a verifiable consumer request within forty-five (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.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your 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 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.
Personal Information Sales Opt-In and Opt-Out Rights
If you are age 16 or older, you have the right to direct a company to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age. Under CCPA, generally if consumers opt-in to Personal Information sales, they may opt-out of future sales at any time.
Children Under the Age of 16
The Site is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to or on the Site. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Site or register on the Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without affirmative opt-in from a child between 13 and 16, or verification of parental consent for a child under age 13, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@staging.dev.frontlobby.com. California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see Personal Information Sales Opt-In and Opt-Out Rights for more information.
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 services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to support@staging.dev.frontlobby.com.
Correcting and Updating Your Personal Information
To review and update your Personal Information to ensure it is accurate, contact us by email at support@staging.dev.frontlobby.com.
Contact Information
FrontLobby welcomes your comments, questions or requests regarding this Privacy Policy. Please contact our Privacy Officer by email at support@staging.dev.frontlobby.com or by mail at:
Attn: FrontLobby Privacy Officer
1900 W Gray St , Unit 131143
Houston TX, 77019 USA
