Privacy Policy

Privacy Policy — FrontPay

Last updated: February 5, 2026
Effective Date: February 5, 2026

Summary: This Policy explains what information FrontPay Holdings, LLC DBA FrontPay. (“we,” “us,” “our”) collects, how we use it, when we may share or sell it, your choices, and your rights under U.S. law. We follow applicable federal and state laws (including the TCPA, FCRA where applicable, and state consumer protection and privacy statutes) and industry standards.

1. Controller
   FrontPay is the data controller for user information collected via our mobile app and website. Contact:Info@JoinFrontPay.com, 801-810-6121, 1042 Fort Union Blvd. Unit 1096, Midvale, UT 84047
2. Information we collect

• Identifiers & contact: name, mobile phone number, email, device identifiers, mailing address.
• Financial & transaction data: bank account/routing numbers, debit card numbers, transaction history, balance and payment history.
• Usage & device data: IP address, device model, OS version, app usage metrics, crash logs.
• Communications: customer service records, SMS/MMS content (if provided), call recordings if consented.
• Derived/aggregate data: scoring models, propensity segments, anonymized analytics.
  We collect data when you register, apply for a cash advance, link accounts, make payments, contact support, use the mobile app or website, or otherwise interact with our services.

3. How we use information
   We use personal information to:

• Provide, operate, and improve our services; process cash advance applications and payments.
• Verify identity and prevent fraud
• Communicate with you (transactional notices, customer service, account updates).
• Personalize offers, marketing, and recommendations.
• Comply with legal obligations and law enforcement requests.
• Perform analytics and model development (risk scoring, product improvement).
  Legal bases: processing is necessary for contract performance, compliance with legal obligations, and our legitimate business interests (e.g., fraud prevention, service improvements). For marketing texts/calls, we obtain prior express consent where required by law (TCPA).

4. Sale or sharing of personal information
   We may share or sell personal information to third parties, including service providers, affiliates, marketing partners, data brokers, and any potential buyers of our business or assets. Categories of recipients and purposes include:

• Service providers/partners: payment processors, credit bureaus, identity verification vendors, customer support vendors, bank verification vendors — to perform services on our behalf.
• Marketing/advertising partners: to provide targeted advertising, offers, and analytics.
• Affiliates and business transfers: corporate affiliates; in the event of a merger, acquisition, or asset sale.
• Legal/regulated disclosures: law enforcement, regulators, or as required by subpoena or similar process.
  When we sell personal information, we do so in compliance with applicable law. Where required by law, we will provide notice and any required opt‑out mechanism. We require service providers to implement appropriate security and confidentiality measures.

5. Consumer rights and choices
   Depending on your state law, you may have rights including:

• Right to access: request the categories of personal information we collect and the specific pieces we hold.
• Right to deletion: request deletion of your personal information, subject to legal exceptions (e.g., transactional records, anti‑fraud obligations).
• Right to opt out of sale/sharing: where applicable (e.g., California’s CCPA/CPRA or similar state laws), you may opt out of the sale or sharing of your personal information. To exercise this right: Email Info@JoinFrontPay.com and we will honor verifiable requests per law and respond within applicable deadlines.
• Right to opt out of targeted advertising: follow the opt‑out links in marketing messages, or use device‑level ad settings and industry opt‑out tools.
• Right to non‑discrimination: we will not unlawfully discriminate for exercising privacy rights.
  We will verify requests to protect user privacy; some requests require identity verification.

6. SMS and telemarketing
   We obtain prior express written consent where required before sending marketing SMS or autodialed calls. Message frequency, carrier message rates, and opt‑out instructions will be provided. To stop marketing texts, reply STOP to any message or contact support; we will honor opt‑outs promptly.
   If you want to transfer consent to a third party (e.g., for marketing), that transfer will be described at the time of consent and treated in accordance with law.
7. Data retention
   We retain personal information as long as necessary to provide services, comply with legal obligations, resolve disputes, enforce agreements, and for legitimate business purposes (e.g., fraud prevention). Retention periods vary by data type and legal requirements.
8. Security
   We maintain administrative, technical, and physical safeguards designed to protect personal information. No system is perfect; if a security incident affecting your data occurs, we will notify you and regulators as required by law.
9. Children
   Our services are intended for users 18 and older. We do not knowingly collect information from children under 13. If we learn we have collected such data, we will delete it.
10. International transfers
    Personal information may be transferred to service providers in the U.S. or other countries. We will take measures to protect such transfers consistent with applicable law.
11. Third‑party sites and services
    Links to third‑party websites, partners, and analytics providers are governed by their own policies. We are not responsible for their practices.
12. Changes to this Policy
    We may update this Policy; material changes will be posted with an updated “Last updated” date and, where required, notified to users. You are advised to review this Privacy Policy periodically. Changes to this Privacy Policy are effective as of the date they are posted on this page (or the later effective date included in our notice).

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you including by placing a notice on the www.joinFrontPay.com website, by sending you an email and/or by some other means. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

13. Contact & opt‑out
    For privacy requests, to opt out of sale/sharing, or questions: email Info@JoinFrontPay.com or call 801-810-6121.