Information Gathering/Collection of Data
This policy describes the types of information, including Personal Information, collected and processed through Frontline Asset Strategies, LLC’s websites and through the services delivered via Frontline Asset Strategies, LLC’s applications, and how Frontline Asset Strategies, LLC treats such information.
Information that by itself cannot be used to identify you does not qualify as Personal Information. This includes but is not limited to your age, your gender, or other preferences.
1. INFORMATION COLLECTED BY FRONTLINE ASSET STRATEGIES, LLC’S WEBSITES
Frontline Asset Strategies, LLC’s websites gather information in two ways: (1) indirectly (for example, through our site’s technology), and (2) directly (for example, when you, the site visitor, voluntarily provide information on various pages).
Frontline Asset Strategies, LLC is a debt collection company. Our interactions with individuals are made as an attempt to collect a debt and any information obtained will be used for that purpose. When you disclose personal information to us, it may be used or disclosed in accordance with the normal course of business of Frontline Asset Strategies, LLC. The only exception involves any required disclosure to the government accordingly for normal business practices and / or our internal Policies for such matters. Personal information contained in any e-mail sent by individuals may be used by Frontline Asset Strategies, LLC to answer questions, follow-up on suggestions or complaints and process requests or transactions.
We do not disclose personal information to third parties except to our clients or to authorized service providers who assist us in our normal business practices, unless otherwise required by law. In instances where we provide personal information to our clients or service providers as noted herein, the recipients of that information remain responsible for the privacy of such information with respect to the individuals concerned.
2. INFORMATION COLLECTED INDIRECTLY
Frontline Asset Strategies, LLC indirectly collects a variety of information through your interaction with and use of Frontline Asset Strategies, LLC’s websites, applications and services. This information may include, but is not limited to, browser and device information, data collected through automated electronic interactions, application usage data, demographic information, geographic or geo-location information, statistical and aggregated information (“Other Information”).
Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Information. For example, we may aggregate Personal Information to calculate the percentage of visitors and/or users in a zip code.
If we combine other Information with Personal Information, we will treat the combined information as Personal Information.
2.1. Tracking Data
Website traffic volume and patterns, such as the number of visitors to a given website or page daily is typically referred to as Tracking Data. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that “serve up” Web pages, automatically identify your computer by its IP address. When you visit any Frontline Asset Strategies, LLC’s websites, our servers log your computer’s IP address.
Only designated administrators of Frontline Asset Strategies, LLC can access the information gathered by our data analytics tools, and the information is used only for administrative and planning purposes to meet the needs of our users, such as to improve the content of the site and to customize the content and/or layout of the site for individuals or groups of users.
2.2. Frontline Asset Strategies, LLC Cookies
The information generated by the cookie about your use of Frontline Asset Strategies, LLC’s websites and/or services, including your IP address, will be transmitted to and stored by Third Party Analytics Providers’ servers. On behalf of Frontline Asset Strategies, LLC, the Third-Party Analytics Providers will use this information for evaluating your use of Frontline Asset Strategies, LLC’s websites, compiling reports on our website activity, and providing other services relating to our website activity. The Third-Party Analytics Providers will not associate your IP address with any other data held by them.
No other website can read a cookie set by Frontline Asset Strategies, LLC.
3. INFORMATION COLLECTED DIRECTLY
Frontline Asset Strategies, LLC also collects Personal Information and other information that users voluntarily provide. It is entirely your decision to provide the requested information.
Frontline Asset Strategies, LLC keeps all information directly collected confidential, and will only use the information for the purpose stated at the point of collection. Frontline Asset Strategies, LLC will seek your specific permission for any additional use. Frontline Asset Strategies, LLC will never barter, trade, or sell access to your information without your specific consent.
3.1. User Account Data
When setting up an account on one of the Frontline Asset Strategies, LLC’s websites (“User Account”), you may be asked to provide personal information including, but not limited to, your name, e-mail address, and your phone number. If you choose to complete transactions using our self-service websites, you will be asked to provide payment details and your full address for billing purposes.
As a customer/user of Frontline Asset Strategies, LLC’s website or services, we may obtain personal information about you when you register to use one of our websites, services or when you provide feedback about our services. As a customer/user, we will use your personal information, unless otherwise prohibited by law, for the following purposes:
i. To communicate with you about your account or transactions with us and send you communication or reminders as you consented to.
ii. To provide you with the services you request.
iii. To provide support including, but not limited to, customer service, and other similar communications.
Any User Account data will only be stored when we service your account or until you decide to terminate your User Account. In case we are obliged to further store your Personal Information due to statutory retention requirements, your Personal Information will be barred for further use by Frontline Asset Strategies, LLC and only be stored until such retention periods expire.
3.2. Other Personal Information Provided Directly
Personal Information provided by you on Frontline Asset Strategies, LLC’s websites, e.g. via contact forms, or via telephone will be stored in our service database and retained for the period necessary to fulfill the business need, unless a longer retention period is required by law.
4. DATA COLLECTION, EMAIL, AND SECURITY
Many Frontline Asset Strategies, LLC’s websites offer users the opportunity to select their most favorable communication method.
If you have given your consent to receiving e-mail communications from Frontline Asset Strategies, LLC but wish to discontinue this service, you may request to do so at any time by contacting us. In addition, as a registered user, you can change your settings within your User Account under “MY ACCOUNT” by updating your “Profile” settings.
You always have the option always to delete your User Account for any of the Frontline Asset Strategies, LLC’s websites or to request a revision of your user information at any time. To do so, please contact us.
4.2. Information Security
Frontline Asset Strategies, LLC employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Information. Our websites are protected with security measures such as change control procedures, passwords, and physical access controls. We also use a variety of other mechanisms to ensure that data you provide is not lost, misused, or altered inappropriately.
Frontline Asset Strategies, LLC has appointed a Director of Security or Security Officer to monitor privacy practices. Access to user data is strictly limited to specific individuals who are trained to respect user privacy. The access given to these employees is restricted to their need for such information for business purposes. A log of those who accessed the data is maintained and monitored to prevent security breaches.
Any attempt to circumvent our security or network is prohibited, including to access data not intended for you, log into a server or account you are not expressly authorized to access, or probe the security of other networks (such as running a port scan), and may be investigated up to and to the extent allowed by law or reported to appropriate authorities.
4.3. Third-Party Information Storage
4.4. Links to Other Sites
Frontline Asset Strategies, LLC’s websites may contain links to sites owned and/or operated by other organizations, and the privacy policies of those sites may differ from that of Frontline Asset Strategies, LLC. These sites may collect data and use it in ways that Frontline Asset Strategies, LLC does not. We encourage you to review the privacy policies posted on all third-party sites.
4.5. Location of Data Collection and Processing
4.6. Compliance and Cooperation with Regulatory Authorities
Frontline Asset Strategies, LLC complies with applicable laws. For more information, please contact our Compliance Officer.
5. Access, Correction and Options for limiting Use of your Personal Information
Information collected is securely stored and may not be available to you for modification once submitted. Frontline Asset Strategies, LLC does not sell this information. When updating your personal information, we may ask you to verify your identity before we can facilitate communication with you.
Frontline Asset Strategies, LLC will obtain your consent before sharing your Personal Information with any third party that is not acting as an agent or vendor to perform tasks on our behalf or to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you. An exception to this will be where Frontline Asset Strategies, LLC is required to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
For sensitive information (e.g., social security numbers or other national identifiers, information related to ethnic or racial origin, or criminal background), we will obtain your affirmative express consent (opt in) if such information is to be
i. disclosed to a third party, or
ii. used for a purpose other than those for which it was originally collected or subsequently authorized by you through the exercise of opt-in choice.
Frontline Asset Strategies, LLC is not required to obtain affirmative express consent (opt-in) with respect to sensitive information where the processing is;
a. in the vital interests of the data subject or another person;
b. necessary for the establishment of legal claims or defenses;
c. necessary to carry out Frontline Asset Strategies, LLC’s obligations in the field of employment law; or
d. related to information that is manifestly made public by the individual.
6. LICENSE TO USE SERVICES AND APPLICATION
Frontline Asset Strategies, LLC reserves the right to prevent any User from using our website, services and Applications.
6.1. Laws and Regulations
Users represent and warrant that your use of Frontline Asset Strategies, LLC’s websites, Services and Applications is lawful, does not violate any local, municipal, state, international or other laws and does not violate the rights of any third party.
Our Web Services and Applications are intended solely for use by users who access the Application in the United States of America.
7. LIMITATION OF LIABILITY
In no event shall Frontline Asset Strategies, LLC nor its directors, employees, partners, agents, suppliers, or affiliates, be liable for any indirect, incidental, special, consequential or punitive damages, including without limitation, loss of profits, data, use, goodwill, or other intangible losses, resulting from:
i. your access to or use of or inability to access or use the Services;
iii. any conduct or content of any third party on the Services;
iv. any content obtained from the Services; and,
v. unauthorized access, use or alteration of your transmissions or content, whether based on warranty, contract, tort (including negligence) or any other legal theory, whether we have been informed of the possibility of such damage, and even if a remedy set forth herein is found to have failed of its essential purpose.
8. DISPUTE RESOLUTION
If you have any complaints regarding our compliance with this Policy or general privacy related complaint, you should first contact us. We will investigate and attempt to resolve complaints and
disputes regarding use and disclosure of Personal Information in accordance with this Policy.
Frontline Asset Strategies, LLC is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and the Fair Debt Collection Practices Act (FDCPA).
9. POLICY UPDATES
The following terms shall have the following meanings:
“Services” refers to all services provided by Frontline Asset Strategies including:
i. Frontline Website
ii. Frontline Mobile Applications
iii. Frontline Electronic Communications
“Services” means any one of the services provided through the IConnect App.
“Users” refers to users of the Frontline Asset Strategies websites, services and applications,
“Company” and “We” refers to Frontline Asset Strategies, LLC
This document was last updated on: 06/14/2018.