Privacy Policy

FrontPay's Privacy Policy
Effective date: May 20th, 2022
FrontPay Holdings, LLC (“us”, “we”, or “our”) operates the www.joinFrontPay.com website
and the FrontPay web application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal
data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in this
Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms
and Conditions.

Definitions
Service
Service means the www.joinFrontPay.com website operated by FrontPay Holdings, LLC.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or
from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from
the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small files stored on your device (computer or mobile device).
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our
Service to you.

Types of Data Collected

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable
information that can be used to contact or identify you (“Personal Data”). Personally identifiable
information may include, but is not limited to:
Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional
materials and other information that may be of interest to you. You may opt out of receiving any,
or all, of these communications from us by following the unsubscribe link or the instructions
provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit our Service or
when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address
(e.g. IP address), browser type, browser version, the pages of our Service that you visit, the
time and date of your visit, the time spent on those pages, unique device identifiers and other
diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information
such as the type of mobile device you use, your mobile device unique ID, the IP address of your
mobile device, your mobile operating system, the type of mobile Internet browser you use,
unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so
(“Location Data”). We use this data to provide features of our Service, to improve and customize
our Service.
You can enable or disable location services when you use our Service at any time by way of
your device settings.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we
hold certain information.Cookies are files with a small amount of data which may include an
anonymous unique identifier.
Cookies are sent to your browser from a website and stored on your device. Other tracking
technologies are also used such as beacons, tags and scripts to collect and track information
and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
However, if you do not accept cookies, you may not be able to use some portions of our
Service.
Examples of Cookies we use:
Session Cookies - We use Session Cookies to operate our Service.
Preference Cookies - We use Preference Cookies to remember your preferences and various
settings.
Security Cookies. We use Security Cookies for security purposes.
Financial Data

While using our service we may ask to gather your data from financial institutions.
Use of Data
FrontPay Holdings, LLC. uses the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with relevant messaging from our partners and affiliates in the form of
advertising
To create and develop anonymous market research products for partners such as financial and
market research companies.
To provide you with news, special offers and general information about other goods, services
and events which we offer that are similar to those that you have already purchased or enquired
about unless you have opted not to receive such information
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on —
computers located outside of your state, province, country or other governmental jurisdiction
where the data protection laws may differ from those of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note
that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents
your agreement to that transfer.
FrontPay Holdings, LLC will take all the steps reasonably necessary to ensure that your data is
treated securely and in accordance with this Privacy Policy and no transfer of your Personal
Data will take place to an organization or a country unless there are adequate controls in place
including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If FrontPay Holdings, LLC is involved in a merger, acquisition or asset sale, your Personal Data
may be transferred. We will provide notice before your Personal Data is transferred and
becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, FrontPay Holdings, LLC may be required to disclose your
Personal Data if required to do so by law or in response to valid requests by public authorities
(e.g. a court or a government agency).

Legal Requirements
FrontPay Holdings, LLC may disclose your Personal Data in the good faith belief that such
action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of FrontPay Holdings, LLC.
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

Security of Data
The security of your data is important to us but remember that no method of transmission over
the Internet or method of electronic storage is 100% secure. While we strive to use
commercially acceptable means to protect your Personal Data, we cannot guarantee its
absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web
browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your
web browser.
Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service
Providers”), provide the Service on our behalf, perform Service-related services or assist us in
analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf
and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics - Google Analytics is a web analytics service offered by Google that tracks and
reports website traffic. Google uses the data collected to track and monitor the use of our
Service. This data is shared with other Google services. Google may use the collected data to
contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms
web page: https://policies.google.com/privacy?hl=en
Firebase - Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your
device advertising settings or by following the instructions provided by Google in their Privacy
Policy: https://policies.google.com/privacy?hl=en
We also encourage you to review the Google’s policy for safeguarding your data: https://
support.google.com/analytics/answer/6004245.
For more information on what type of information Firebase collects, please visit the Google
Privacy Terms web page: https://policies.google.com/privacy?hl=en
Amazon Web Services - https://aws.amazon.com/privacy/
Behavioral Remarketing
FrontPay Holdings, LLC uses remarketing services to advertise on third party websites to you
after you visited our Service. We and our third-party vendors use cookies to inform, optimize
and serve ads based on your past visits to our Service.
Google Ads (AdWords) - Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display
Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://
tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser
Add-on provides visitors with the ability to prevent their data from being collected and used by
Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms
web page: https://policies.google.com/privacy?hl=en
Twitter - Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://
support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy
Policy page: https://twitter.com/privacy
Facebook - Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page:
https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://
www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising
established by the Digital Advertising Alliance. You can also opt-out from Facebook and other
participating companies through the Digital Advertising Alliance in the USA http://

www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://
youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://
www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy:
https://www.facebook.com/privacy/explanation
AdRoll - AdRoll remarketing service is provided by Semantic Sugar, Inc.
You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page:
http://info.evidon.com/pub_info/573?v=1nt=1nw=false
For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy
web page: http://www.adroll.com/about/privacy
AppNexus - AppNexus remarketing service is provided by AppNexus Inc.
You can opt-out of AppNexus remarketing by visiting the Privacy the AppNexus Platform web
page: http://www.appnexus.com/platform-policy#choices
For more information on the privacy practices of AppNexus, please visit the AppNexus Platform
Privacy Policy web page: http://www.appnexus.com/platform-policy/
SEMcasting - SEMcasting remarketing service is provided by Semcasting, Inc.
You can opt-out of Semcasting by visiting https://privacychoice.com/ and their privacy policy by
visiting https://www.semcasting.com/privacy-policy/

Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click a third party
link, you will be directed to that third party’s site. We strongly advise you to review the Privacy
Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18.
If you are a parent or guardian and you are aware that your Child has provided us with Personal
Data, please contact us. If we become aware that we have collected Personal Data from
children without verification of parental consent, we take steps to remove that information from
our servers.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change
becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this
Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email:Info@joinFrontPay.com