Privacy Policy

PRIVACY POLICY

At Front and Centered, your privacy is very important to us and we have a few fundamental principles:

  • We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
  • We store personal information for only as long as we have a reason to keep it.
  • We aim for full transparency on how we gather, use, and share your personal information.
    Below is our Privacy Policy, which incorporates and clarifies these principles.

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use:

Throughout this Privacy Policy we’ll refer to our website, and other work collectively as “Services.”

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so–for example, to provide our Services, to communicate with you, or to make our Services better.

We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

  • Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who book a consultation or sign up for a Front and Centered advertising account to provide a contact name, company name, email address, physical address and telephone number–and that’s it.

  • Customer Profile Information: If you have an account with us, we collect the information that you provide for your internal customer profile and we will never share or sell that information with anyone outside our company.

  • Transaction and Billing Information: If you donate or subscribe to receive information from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information and contact information, PayPal account or your bank account information.

  • Communications With Us (Hi There!): You may also provide us information when you respond to emails or communicate with our team members about a sales or support question.

Information We Collect Automatically

We also collect some information automatically:

  • Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services–for example, when you create or make changes to your Booking on our Office 365 Booking Services.

  • Usage Information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views, features enabled for our website and interactions with other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.

  • Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Front and Centered uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may also get information, such as a mailing address, from third party services about individuals who are not yet our customers (…but we hope will be!), which we may use, for example, for marketing and advertising purposes like postcards and other mailers advertising our services.

How And Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

  • To provide our Services–for example, to set up and maintain your account or charge you for any of our paid Services;

  • To further develop and improve our Services–for example by adding new features that we think our users will enjoy or will help them to use our website more efficiently;

  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;

  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition–for example, we may analyze how many individuals purchased a Service after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;

  • To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Front and Centered and others, which may result in us declining a transaction or the use of our Services;

  • To communicate with you, for example through an email, about offers and promotions offered by Front and Centered, solicit your feedback, or keep you up to date on Front and Centered and our products; and

  • To personalize your experience using our Services, provide content recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account–for example, in order to enable access to our website on your device or charge you for a paid plan; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information–for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or

(5) You have given us your consent–for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.

Sharing Information

How We Share Information

We do not sell our users’ private personal information.

We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

  • Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.

  • Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers). We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g. our Cookie Policy).

  • Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.

  • More Information on Data Release and Retention
    • Before revealing any of this information to a party that is not the owner of the account, we require a validly issued subpoena, warrant, or court order that specifically requests it unless we have a good faith belief that there is an emergency involving death or serious physical injury. We do not voluntarily provide governments with access to data about users (private or public) for law enforcement, intelligence gathering, or other surveillance purposes. More information on our requirements for releasing private user information can be found below.

    • If have any concerns, please contact us at [email protected]

  • To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Front and Centered, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.

  • Emergency Requests from Government Agencies/Law Enforcement: As permitted by US law, we may disclose user information to the government or law enforcement, without a subpoena or warrant if we have a good faith belief that an emergency (imminent danger of death or serious physical injury) requires disclosure of information related to the emergency without delay.

  • Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Front and Centered goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.

  • With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.

  • Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services and we may share a hashed version of your email address to facilitate customized ad campaigns on other platforms.

How Long We Keep Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it–which are described in the section above on How and Why We Use Information–and we are not legally required to continue to keep it.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

  • Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.

  • Set Your Browser to Reject Cookies: At this time, Front and Centered does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Front and Centered’ website, with the drawback that certain features of Front and Centered’ website may not function properly without the aid of cookies.

  • Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services 🙁 🙁 🙁 :(, you can close your of Front and Centered account. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above–for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation (AKA the “GDPR”), data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;
  • Request correction or deletion of your personal data;
  • Object to our use and processing of your personal data;
  • Request that we limit our use and processing of your personal data; and
  • Request portability of your personal data.

You can correct or delete your personal data by contacting us. If you have any concern about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.

EU individuals also have the right to make a complaint to a government supervisory authority.

Controllers and Responsible Companies

Front and Centered’ Services are provided worldwide but based in the United States. Front and Centered is the controller of personal information, which means that we are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.

The “controller” is Front and Centered, the company that entered into the contract with you under the Terms of Service for the product or service you use.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact [email protected]

Other Things You Should Know (Keep Reading!)

Transferring Information

Because ‘Front and Centered’ Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our company, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

  • In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
  • In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by Front and Centered and does not cover the collection of information by any third party advertisers or analytics providers.

Privacy Policy Changes

lthough most changes are likely to be minor, Front and Centered may change its Privacy Policy from time to time. Front and Centered encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will notify you by revising the change log below, and, in some cases, we may provide additional notice (such as adding a statement to our homepage or sending you a notification through email. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

That’s it! Thanks for reading.

Change log

  • April 8, 2020: Added more specific information to help clarify our practices and added information to reflect the requirements of the EU’s General Data Protection Regulation.