1 Privacy policy

1. (a) Fronterly.com is operated by Fronterly Pty Ltd (ACN 659 014 749) who is referred to in this privacy policy as “we”, “us”, “our” and similar grammatical forms.
2. (b) By using our Free Plan, paying your subscription for any of our Plans or registering for an account with us, you are accepting the terms of this privacy policy, and you are consenting to our collection, use, disclosure, retention and protection of your personal information as described in this privacy policy.
3. (c) We appreciate that your privacy is important to you. Fronterly Pty Ltd will continue to protect the personal information you provide us and we will manage your personal information in compliance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
4. (d) We will take all reasonable steps to ensure that all information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment.

1.1 When do we collect information?

1. We do not automatically collect personal information from you, such as your name, address, phone number, email address or other personally identifiable information about you (personal information). We collect three categories of information when you use our Website:
   1. the personal information you voluntarily provide — that is, we collect personal information with your informed consent;
   2. anonymous non-personal information about how you use our Website; and
   3. “cookie” based information that makes your use of our Website easier by recording your preferences so that when you return to our Website the “cookie” re-loads that information into your web browser.
2. For example, we will collect personal information from you when you register on our Websites, place an order, subscribe to our newsletter, respond to a promotional offer, competition or survey or fill out a form related to any customer service feature operating on our Websites.
3. When you become a subscriber to Fronterly.com, you will need to provide certain details so that we can establish and manage your customer account.
4. When you log-into our Website using our secure log-in (or use any other log-in connected to any other social media platform) you are allowing that social media platform to share your personal information with us (that is, your personal information related to your log-in with that social media platform, which may include your email address and other personal information).

1.2 Why do we need to collect personal information?

We collect personal information when you volunteer that information in order to receive a service from our Website or one of our Services. The personal information collected will be used to provide the services you have requested, such as setting up and managing your subscription to one of our Plans or processing any purchases you may make. Your personal information may be used in relation to any survey, promotional offer or any competition you may enter on our Websites.

1.3 What information do we collect?

1. The type of information we collect from you will depend on what services you use on our Website. The personal information we may collect includes your name, postal address, email address, telephone numbers and contact details and information for identification purposes. If you make online purchases from us or pay your subscription for one of our plans by credit card or debit card or direct debit from your bank account we will collect your card or bank account details.
2. General information about visits to our Websites or our other Services is collected by our computer servers, with small files “cookies” that our Websites transfers to your computer’s hard drive through your Web browser (if you allow the delivery of “cookies”). The “cookies” are used to follow the pattern of movements of users by letting us know which pages on our Websites or Services are visited, in what order and how often and the previous website visited and also to process the items you select if you are making purchases from us. The anonymous non-personal information that when collect and analyse is not personal information as described in the Privacy Act.

1.4 Why do we use “cookies” and other web use tracking technologies?

1. When you access our Website, a small files containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your computer. The purpose of sending these files with a unique ID number is so that our Website can recognise your computer when you next visit our Website or use our Services. The “cookies” that are shared with your computer can’t be used to discover any personal information such as your name, address or email address they merely identify your computer to our Websites or our Services when you visit us.
2. We can also log the internet protocol address (IP address) of visitors to our Website or our Services so that we can work out the countries in which the computers are located.
3. We collect information using “cookies” and other tracking technologies for the following reasons:
   1. to help us monitor the performance of our Website and our Services so that we can improve the operation of the Website and the services we offer;
   2. to provide personalised services to each user of our Website and our Services to make their navigation through our Website and our Services easier and more rewarding to the user;
   3. to sell advertising on the Website in order to meet some of the costs of operating the Website and improve the content on the Website; and
   4. when we have permission from the user, to market the services we provide by sending emails that are personalised to what we understand are the interests of the user.
4. Even if you have given us permission to send you emails, you can, at any time, decide not to receive further emails and will be able to “unsubscribe” from that service.
5. If you are unhappy about having a cookie sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, some of our services may not function properly.

1.5 How do we store your information?

1. We use different technologies and procedures to help protect personal information from unauthorised access, loss, alternation, disclosure or use. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal information is held in data centers. We also use data encryption when personal information is transferred to and from our service providers. Our commitment to data security means:
   1. we have procedures to limit access to personal information within our organisation;
   2. we use security measures and technologies within our organisation to protect your personal information; and
   3. we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where credit card information is being transferred.

   Our website and server are hosted in Australia. See security page link below for more information titled “Our Data Centers” (bottom of page): https://fronterly.com/security

1.6 What use do we make of your personal information?

1. We will communicate with you in relation to any purchases you make from us and in relation to the management of your User Account and/or subscription account(s) with us which will include providing you with information about your Plan and services provided as part of your subscription.
2. We may send you information and updates about any other product, service or information that we provide to our customers; in addition, we may send you occasional company news and information about other products and services or special promotional offers of our affiliated companies. If at any time you would like to stop receiving future commercial messages from us, we include detailed unsubscribe instructions at the bottom of each email.
3. We may also release your personal information when we believe release is appropriate to comply with the law, enforce our subscription agreements, website policies and terms & conditions, or protect ours or others’ rights, property, or safety.

1.7 How can I access the personal information that you collect?

1. We are happy to provide you with details of personal information held about you. APP 12 allows you to get access to, and correct, the personal information we hold about you.
2. To access this information, you need to email or write to us using the contact details below. Please also include your name and email if you are a subscriber to Fronterly.com.
3. APP 13 allows you to ask us to take reasonable steps to correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.
4. If you believe that your personal information has been misused, you can inform us of your complaint by writing to our address and we will attempt to resolve the matter.

   Fronterly Pty Ltd
   Address:
   Level 5, 447 Collins St
   Email:
   [email protected]
   

5. If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC). Telephone: 1300 363 992.

   [email protected]
   OAIC complaints page: http://www.oaic.gov.au/privacy/privacy-complaints

1.8 Third party links

Our Websites and Services may include links to websites operated by third parties. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our Websites and Services and welcome any comment about linked websites.

1.9 Terms and conditions

Please also visit our Terms of Access to our Website and our Terms of Use regarding uploading material or information to our Website here which sets out the conditions of use and limitations of liability governing the use of our Website.

1.10 Your consent

By using our Website or our Services, you consent to this privacy policy.

1.11 Changes to our privacy policy

1. If we decide to change this privacy policy, we will post those changes on this page, and update the privacy policy modification date below.
2. This privacy policy was last modified on 23 February 2024.