FRONTLINE Policy Statement

Personal Information

Your privacy is very important to us and we have the highest respect for the confidentiality of your personal information.

This Policy applies to all Personal Information of Customers (as defined below) that FRONTLINE Selling, LLC collects or receives, whether manually or digitally processed. The Policy applies to Personal Information received during the course of FRONTLINE Selling, LLC’ operations and governs FRONTLINE Selling, LLC and subsidiaries.

FRONTLINE Selling, LLC provides sales and marketing management services (“Services”) for its clients (“Clients”). In the course of those Services, FRONTLINE Selling, LLC receives Personal Information regarding the customers or potential customers (“Customers”) of its Clients. In all cases, FRONTLINE Selling, LLC acts as agent for our Clients and at their direction.

FRONTLINE Selling, LLC uses the Personal Information we collect to enhance Customers’ experience through the delivery of information and services based on Customers’ preferences.

Shared Data

FRONTLINE Selling, LLC shares Personal Information with Clients only for the purpose of improving the sales and marketing experience of their customers. As such, FRONTLINE Selling employees and contractors act as (“Intermediaries”) through accessing and using this information for the purpose of providing services to clients. These Intermediaries serve solely as links in the distribution chain, and do not store, retain, or use this Personal Information for any secondary purpose other than to provide the contracted service. We also may share Personal Information with other departments, who use the information solely to provide the requested service to FRONTLINE Selling, LLC and for no other purpose.

Types of Information

Any personally identifiable information you provide us – such as your name, telephone numbers, e-mail addresses, or postal addresses for example – may be used, collected or stored by us or our service providers. While you can choose not to provide your personal information, you may limit our ability to contact you, or to respond to your inquiries.

We also may obtain information about you from our sister companies and/or business partners and add it to information that you have previously provided to us in order to serve you better. Examples of information we receive from other sources include updated delivery and address information from third parties sources, which we use to correct and update our records.

We may receive, use, and store certain types of non-personal information automatically whenever you interact with our Web site or if you provide it to us upon request or through correspondence with us. For each visitor to our Web page, our Web server automatically recognizes the name of the visitor’s Internet domain. Once a visitor registers at our site, we apply a cookie to the visitor’s computer, which the visitor is free to accept or to decline. A cookie helps both the visitor and FRONTLINE Selling, LLC by storing information from previous visits (from the visitor’s computer), such as areas of interest within our Web site. At this time, no other computer identification tools besides cookies are used. For more information about the use of cookies and other similar technology, please visit a not-for-profit information site: www.networkadvertising.org.

Please note that FRONTLINE Selling, LLC does not currently use ad-serving companies to place banner ads from other firms on our site, so there is no tracking by these third-party companies from any banner ads, bulletin boards or other interactive venues on this site.

Storage of Personal Information

We utilize reasonable protections to ensure that Personal Information in our care is not misused or accessed without authorization. Personal Information is stored on secure hosted servers, with access restricted to those employees who have a need for such access to perform a legitimate business purpose relating to the Services or to maintenance, internal security or related issues. We use a variety of security technologies and procedures (passwords, encryption, ect.) to help protect Personal Information from unauthorized access, use or disclosure.

Access to Personal Information

Individuals seeking access to Personal Information that we receive from Clients should contact the Client directly. We would be happy to provide any interested Customer the applicable Client’s name and contact information. Individuals seeking access to Personal Information that we have collected must contact our Privacy Group: privacy@frontlineselling.com.

If you believe we have information about you that you wish to access as a consumer or business individual, please contact us as noted as directed at the foot of this policy. Please note that if we do not have any personal information about you, we cannot tell you about any non-personal information that we might have about you. In addition, as a service provider to various FRONTLINE Selling, LLC clients, we may hold information about you on behalf of another company. In such cases, we may not provide you requested access to information directly, but you may contact those clients directly for information they may contain about you, or to obtain information regarding their respective privacy policies. In most cases, FRONTLINE Selling, LLC can refer you to the proper client contact (if the client allows us).

If you wish to have this information changed, would like to express your preferences on how we communicate with you, or to be removed from our database, please let us know by contacting us with your exact name and address at either privacy@frontlineselling.com or optout@frontlineselling.com. See Opt Out Section below.

Use of Personal Information

If you request information from us, you will be asked to provide personally identifying information so that we can respond effectively to your requests and needs. We will never share your information with anyone who is not directly related to providing service and support of FRONTLINE Selling, LLC. If you provide us with personal information, we may attempt to contact you occasionally to determine if our service meets your expectations, or to offer additional assistance.

Additional customer data may be provided to a Telephone Representative during a call. If this occurs, we will follow the applicable guideline below:

  • Promotional: If a customer name is presented as a promotional referral (ex: Customer X says that Customer Y might also be interested), collect the referred individual’s name; however, do not proceed with a follow-up call until contact preferences are verified. Since the call to referred individual would be a new promotional touch, FRONTLINE Selling, LLC must verify contact preferences for individual in order to proceed with a promotional phone call.
  • Transactional: If a customer name is presented as a transactional referral (ex: During a call, Customer X may communicate that Customer Y is the more appropriate individual to speak with about Topic XYZ). First, ask the customer if it would be okay if a Telephone Representative contacts the new individual based on their referral. If the customer says yes, collect the referred individual’s contact information for follow-up. Proceed with the follow-up, but make sure you communicate to the referred friend that you are contacting them as a referral. If the customer asks not to be contacted by a specific communication method, update their contact preferences accordingly.

Transfer of Personal Information

Unless required by law, we do not disclose Personal Information to third parties other than our Clients except as expressly set forth in this section. In order to maintain accurate records of Customers, we also may associate Personal Information we receive with records of existing Customers in our database, and update those records as needed. FRONTLINE Selling, LLC does not store, retain or use the Personal Information for any other purpose. Finally, we will disclose Personal Information as required to enforce or protect our legal rights with respect to a Client or Customer, or as required by court order, subpoena or other operation of law. FRONTLINE Selling may sell or buy subsidiaries, or specific business units to grow our business. In such transactions, personal information of prospects and customers generally is one of the transferred assets, but remains subject to any pre-existing Privacy Policy, and to any “do-not-contact” list of FRONTLINE Selling, LLC to which you have participated. Also, in the unlikely event that substantially all of our assets are acquired, personal information will be part of our transferred assets.

We also will transfer personal information when we believe the transfer is necessary to comply with the law; or to protect our rights or safety, or the rights or safety of our users, or others.

Please note that if you, as a visitor, have provided us with a postal address, an e-mail address, or a telephone number, a FRONTLINE Selling, LLC representative may contact you. This will result when you have expressed an interest or a query in a particular product(s) or service need(s).

Opt Out

As already noted, at all times we use any Personal Information we receive only at the direction of the Client or otherwise in furtherance of the Client engagement. In addition, we clearly notify Customers of the Personal Information we collect and allow them the right to “opt-out” of such collection.

Most customers tell us they appreciate receiving our news and promotions; however, we believe it is very important for you to be able to choose whether you receive periodic mailings and information from us. You can choose to opt out at any time by simply replying to a mailing to inform us of your preference. All of our mailings will clearly explain how you can easily opt out and stop receiving information from us.

Data Security and Integrity

FRONTLINE Selling, LLC only uses Personal Information that is necessary to perform the Services requested. Occasionally, a Client or Customer provides us with more Personal Information than is necessary for that purpose (for example, providing us with a name, street address and e-mail address, when only the name and e-mail address are necessary). In those cases, we employ automated programs (or manual procedures in the case of difficulty) that identify and utilize only those data that are needed.

To help protect your confidentiality, FRONTLINE Selling, LLC employs security safeguards; however, we cannot eliminate all security risks. For instance, FRONTLINE Selling, LLC’s Web site may contain links to other Web sites. We have no responsibility or control over linked Web sites and their privacy policies or the way they collect and control your personal information. We encourage you to learn about the privacy practices of any Web site before providing personally identifying information.

FRONTLINE Selling works in accordance with industry best practices and applicable laws to maintain the security of your information. We maintain policies and procedures covering the proper logical and physical security of workplaces, records, and various other types of information in our systems and on our premises. We also use technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware safeguards) to protect against unauthorized access or alterations to information.

Safe Harbors

FRONTLINE Selling, LLC voluntarily complies with the U.S. Department of Commerce European Data Protection Directive “Safe Harbor” program. We have certified that we adhere to the Safe Harbor Privacy Principles agreed upon by the American and European regulators. For more information about the Safe Harbor and to view the certification of FRONTLINE Selling, LLC, visit the U.S. Department of Commerce’s Safe Harbor Web site.

If you believe that we are not in compliance with the Safe Harbor principles, first contact our company by mail, e-mail, or telephone as noted in this policy. If you do not receive a prompt acknowledgment of your inquiry, or if your inquiry has not been satisfactorily addressed, you can then contact the [U.S.] Direct Marketing Association (DMA) Safe Harbor Dispute Resolution Program. The DMA will then serve as a liaison to us to resolve your concerns in a timely manner.

You can reach the DMA Safe Harbor Program at:

Safe Harbor Line
Direct Marketing Association
1615 L Street, NW, Suite 1100
Washington, DC 20036-5624
Telephone: USA (202) 861-2445
http://www.export.gov/safeharbor/SH_Overview.asp

Monitoring of Privacy Policy

We believe strongly in respecting your privacy and your wishes about the use of your personal information. While we may need to change this policy from time to time as new situations arise, we will never change our commitment to protecting your confidentiality and informing you of how we intend to use any information you provide to us. Our most up-to-date privacy policy will always be posted here. You should check our Web site(s) frequently to see recent changes to our Privacy Policies. Unless stated otherwise, our current Privacy Policy applies to all information that we have about you and your relationship with our company. If you have any concern about our privacy practices, please contact us by any means stated below.

Enforcement of Privacy Policy

Concerns regarding our adherence to this Policy should be raised first with our Privacy Group. Contact information provided below. FRONTLINE Selling, LLC’s compliance with this Policy is subject to the ultimate authority of the United States Federal Trade Commission, to which complaints that are not adequately resolved through these avenues also may be directed.

Contact

If you feel that this site is not following its stated information policy or you wish to inquire further about our policy, please contact us promptly with necessary details of your inquiry through any of the following methods. Thank you for taking time to review this policy statement in its entirety. Our goal is your complete satisfaction, security and information protection, and your full understanding of our privacy practices that we have undertaken to serve customers better.

To contact our Privacy Group or to address questions regarding FRONTLINE Selling, LLC privacy practices, please e-mail privacy@frontlineselling.com or call 877-RAMP-UP1 877-726-7871. Letters may be sent to: Privacy Group, 4550 North Point Parkway, Suite 370, Alpharetta, GA 30022.