(Effective January 22, 2020)
“Affiliates” means companies we own or control, a company that owns or controls us, or a company that is owned or controlled by the same company that owns or controls us. Ownership does not mean complete ownership, but means owning enough to have control.
“Non-affiliated third parties” means companies that are not Affiliates.
“Non-public personal information” means personally identifiable financial information provided by the consumer to obtain a financial product, or resulting from transactions with that product, or information that a financial institution obtains about the consumer in connection with the product. Examples of non-public personal information include social security numbers, financial account numbers, account balances, payment histories, transaction histories or any information that discloses that an individual has a financial relationship with a financial institution.
“Public personal information” means information that is public or a matter of public record. Examples of public personal information includes include but are not limited to publicly available property records, court records, addresses and telephone numbers, any available information from public sites and sources.
FRONTLINE collects, stores and uses certain personal and financial information about our clients’ customers, and representatives. FRONTLINE recognizes and respects both our clients’ and individuals’ privacy concerns and expectations about how FRONTLINE maintains and uses such information. FRONTLINE collects, uses and stores different types of personally identifiable information as a service provider for its clients pursuant to applicable law. Such information includes, but is not limited to, the decedent’s personal financial information provided to us by our clients and information provided to us by you. However, we here at FRONTLINE do not sell anyone’s Public personal information or Non-public personal information to any person or entity. “Public personal information” means information that is public or a matter of public record. “Non-public personal information” means personally identifiable financial information provided by the consumer to obtain a financial product, or resulting from transactions with that product, or information that a financial institution obtains about the consumer in connection with the product.
Information We Collect
We may have collected the following categories of personal information from consumers within the last 12 months:
- Categories of Personal Information
- Collected: Yes
- Examples: A real name, alias, postal address, email address, telephone numbers, Internet Protocol address, account number, or other similar identifiers.
- Personal Information Categories
- Collected: Yes
- Examples: A name, signature, address, bank account number, debit card number, or other financial information. Some personal information included in this category may overlap with other categories.
- Internet or other electronic network activity information
- Collected: Yes
- Examples: Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
How We Use Your Information
Personal information is collected solely for the purpose of recovery in a lawful manner and for lawful purposes. Personal information remains part of our records until we determine the information is no longer needed, or we are required by law to delete such information. We will collect the minimum amount of data necessary to perform out duties. 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. We do not sell and will not sell your personal information.
How We Collect Your Information
We collect most of this personal information directly from our clients for whom we provide services to, as well as from you by telephone, written correspondence through the mail, email or fax, by viewing our website, or other information available online. However, we may also collect information:
- From publicly accessible sources (e.g., property records or court records);
- From your transactions with us;
- From our service providers (e.g., letter vendors, location vendors, payment processing vendors, call analytics vendors, and/or electronic signature service providers);
- Directly from a third party (e.g., third parties contacted during location activities pursuant to 15 U.S.C. §1692b, such as relatives);
- From a third party with your consent (e.g., your authorized representative and/or attorney); and
- From activity on our website.
How We Share Your Information
FRONTLINE may share personally identifiable information it collects with its employees who need to know that information to service an account. Except as provided below, FRONTLINE does not share or disclose any personally identifiable information to any company or marketing group external to FRONTLINE. FRONTLINE may share your personal information with third parties to the extent it is reasonably necessary to manage or service an account in the ordinary course of business, verify employment, determine location, process payment, fulfill a transaction, provide customer service, or as otherwise authorized by law. FRONTLINE will only disclose information to Affiliated and Non-affiliated third parties as permitted or required by applicable rule or law, including, but not limited to, the California Consumer Privacy Act (“CCPA”), Fair Debt Collection Practices Act (“FDCPA”), and Gramm Leach Bliley Privacy Act (“GLBA”). “Affiliates” means companies owned or controlled by FRONTLINE, a company that owns or controls FRONTLINE, or a company that is owned or controlled by the same company that owns or controls FRONTLINE. Ownership does not mean complete ownership, but means owning enough to have control. “Non-affiliated third parties” means companies that are not Affiliates. When we share your information with these companies, they are required to limit their use of the information to the particular purpose for which it was shared and they are not allowed to share it with others except to fulfill that limited purpose. In addition, if permitted by applicable law, we may also share your information with our affiliated and non-affiliated third parties. We restrict access to Non-public personal information about you to those employees who need to know that information to service an account or manage our business.
Further, FRONTLINE may disclose personally identifiable information (i) to another entity with which FRONTLINE enters or reasonably may enter into a corporate transaction, such as, for example, a merger, consolidation, acquisition, or asset purchase, (ii) to a third party pursuant to a subpoena, court order, or other form of legal process or in response to a request by or on behalf of any local, state, federal, or other government agency, department, or body, whether or not pursuant to a subpoena, court order, or other form of legal process, or in connection with litigation brought against, or on behalf of, FRONTLINE, where appropriate, (iii) to a third party if determined by FRONTLINE in its sole judgment that such disclosure is appropriate to protect the life, health, or property of FRONTLINE or any other person or entity, all in compliance with applicable law, (iv) to third parties as authorized or designated by you, or (v) to conduct any other legitimate business activity not otherwise prohibited by law. The foregoing is not intended to obviate or displace any legal obligations or duties applicable to FRONTLINE.
Except as necessary for FRONTLINE to provide the services, information, or products requested by a website user, or except for the disclosures identified in the preceding paragraphs, the user may opt out of having his or her personally identifiable information, which has been voluntarily provided to FRONTLINE through or from its website, prospectively retained by FRONTLINE, used by FRONTLINE for secondary purposes, or disclosed by FRONTLINE to third parties.
E-mail posted or sent to FRONTLINE may not be secure against interception by unauthorized individuals. To protect against interception by unauthorized individuals, or because we cannot verify your identity, we may be unable to respond to e-mail requests concerning accounts placed for collection unless you have requested or authorized us to do so.
How We Protect Information
Data security and compliance are our highest priorities at FRONTLINE. We value consumers’ privacy and are committed to upholding the trust our clients place in us with their personal data. FRONTLINE has implemented physical, electronic, and procedural security safeguards to protect against the unauthorized release of or access to personal information. We are PCI/DDS compliant, use SOCII certified data centers and utilize ISO 27002 information security framework. FRONTLINE also takes efforts to ensure that any party to which it shares personal information is under a contractual obligation to use the personal information solely for the purposes for which the information was disclosed by FRONTLINE. FRONTLINE exercises no control over such parties and it is not responsible for their conduct, actions, omissions, or information handling or dissemination practices. We employ strict internal and external system safeguards designed to protect confidentiality and security of personal information. The confidentiality of any communication or material transmitted to or from FRONTLINE via the website or via e-mail cannot be, and is not, guaranteed. You acknowledge that the technical processing and transmission of the website’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to confirm and adapt to technical requirements of connecting networks or devices. We will collect the IP Address of all visitors to the FRONTLINE website for internal security and other proprietary purposes. We do not release this data outside of our corporate team nor utilize the data other than for internal purposes. If any questions arise about security, please contact FRONTLINE using the information provided below.
FRONTLINE is committed to protecting children’s privacy online. FRONTLINE does not direct any website or online services to children under eighteen years of age and does not knowingly collect personal information, either from a website, service, or otherwise, from children under the age of eighteen.
FRONTLINE offers you certain choices in connection with the personal data it collects from you, including:
- You may review, update and correct your contact information, including your telephone number and email address, after logging in to the website, or by calling our office.
- You can elect not to utilize the payment portal of FRONTLINE’ website and not to make payments via debit card or check.
- You may opt out of having your personally identifiable information, which has been voluntarily provided to FRONTLINE, prospectively retained by FRONTLINE.
You may exercise your choices by contacting us at:
Frontline Asset Strategies, LLC
Attn: Compliance Dept.
2700 Snelling Ave N., Suite 205
Roseville, MN 55113