Updated: February 22, 2023
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By accessing or using the Services, or by accepting our Terms and Conditions, Terms of Use (where applicable) or Services Agreement or any other terms that incorporate this Privacy Policy by reference, you agree on behalf of yourself and any organization that you represent (together, “you”) that you have read and understand this Privacy Policy and that you consent to the collection, use, and sharing of information as discussed below. If you do not agree with this Privacy Policy, do not access or use the Services. This Policy is incorporated into and made a part of our Terms and Conditions, Terms of Use (where applicable) or Services Agreement.
FrontStream has developed this Privacy Policy to inform you how we collect data and use the data we collect. FrontStream provides a platform, applications, and our website (collectively, “Services”) specifically for fundraising activities by nonprofit and corporate customers.
In this Privacy Policy, “you” or “your” refers to a user of our Services who may use the Services directly through us or through one of our corporate customers (e.g., a nonprofit organization or other corporate entity) (“Customer”). For example, a you may be an individual seeking information from a Customer or you may be providing a donation to a Customer, and you use our platform or otherwise access the Services that we provide to the Customer. Please note that this Privacy Policy only covers the data we collect, and it does not apply to websites or services we do not control, including websites or services of our Customers.
Please review this Privacy Policy and our Cookie Policy carefully. If you have questions, please contact us. Additional contact details are at the bottom of this Privacy Policy.
When you use the Site, we collect and process the following types of information:
a. Information You Provide
You may register to use our Services, set up an account, make a donation, or respond to communications (e.g., surveys, polls, requests for feedback), we will collect the information you provide to us. This may include your IP address, first and last name(s), demographic information, mailing address, e-mail address, phone number, and credit card number. In the use of Services, you may also choose to disclose or provide your communication preferences, your physical location, and your demographic information (e.g., your age, marital status, ethnicity/race, and gender). All of this is “Personal Information,” because it can be used to identify you.
b. Information We Collect about You
We collect information about your use of our Services, including but not limited to: your Internet connections, computer equipment, web browsers, websites visited before using or accessing the Services, websites visited after leaving the Services, and other similar information about traffic and usage, as you navigate to, through, and away from our website. This is “Non-Personal Information,” because it does not identify you, but provides insights to us regarding the uses of our Services. For example, we use this information to generate statistical information, monitor and analyze traffic and usage patterns in connection with our Services, monitor and prevent fraud, investigate complaints and potential violations of our policies, and to improve the our content and the products, services, materials, and other content that we describe or make available through the Services.
In some jurisdictions, such as the United States, an IP address may be considered Non-Personal Information. In the European Economic Area an IP address is considered Personal Information under applicable data protection laws. If this is the case, we process Non-Personal Information for the same purposes as Personal Information under this Privacy Policy.
c. Geolocation Information
You may choose to allow us to access your location by granting the Services access to your location when prompted or through your device’s location services settings. You may change these settings on your device.
As part of our fundraising platform, you may choose to link our Services to a third party account or platform. For purposes of this Privacy Policy, if you authorize or otherwise enable an account or platform operated by a third party, then you will control that connection (“Connection”). For example, you may create a Connection to a social media account, in which case, we will receive Personal Information from the social media provider through the Connection. All information we receive through a Connection will be subject to this Privacy Policy.
Please review the Privacy Policy of any and all third parties. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party websites or services.
Please notify us immediately at privacy@FrontStream.com if you become aware of any unauthorized use of your password or account or any other breach of Service security or of this Policy. If our security system is breached, we will notify you of the breach as required by applicable law.
If you change your mind after opting to receive electronic communications, you may opt out of receiving such communications from us by communicating your preferences to us by e-mailing privacy@FrontStream.com, or by following the unsubscribe link contained in the applicable e-mail. We will comply with your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our Services.
In certain circumstances, you may also request that we delete your Personal Information, for example if our retention of your Personal Information is no longer necessary as part of the Services.
If you would like to review, correct, or update Personal Information that you have previously disclosed, you may do so by signing into your account or by contacting us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Unless otherwise prohibited by law, we may charge you a fee for providing you with a copy of your data.
a. Access and Collection. Collected Information may be transferred to, stored in, and processed in the United States, and FrontStream will comply with the requirements of the Privacy Act that apply to cross-border disclosures of Collected Information.
b. Corporate Parents, Affiliates, and Subsidiaries, or Associated Entities. We may share Collected Information with our corporate parents, subsidiaries, other affiliated entities, and associated entities (as that term is defined under Australian law) for the purposes described in this Policy.
c. Privacy Complaints for Australian Users. If you have a complaint about how we collected or handled Collected Information, please contact us. We will endeavor in the first instance to deal with your complaint and take action to resolve the matter. If your complaint cannot be resolved at the first instance, we will ask you to lodge a formal complaint in writing, explaining the circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how you believe your complaint should be resolved. We will acknowledge receipt of your formal complaint and indicate the timeframe that you can expect a response. We will endeavor to resolve the complaint as quickly as possible, but if the matter is complex and our investigation may take longer, we will let you know when we expect to provide our response.
If you are unhappy with our response, you may refer your complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as the Victorian Health Services Commissioner or the Australian Communications and Media Authority.
FrontStream is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. FrontStream complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to Collected Information received or transferred pursuant to the Privacy Shield Framework, FrontStream is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, FrontStream may be required to disclose Collected Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, FrontStream commits to resolve complaints about FrontStream’s collection or use of your Collected Information (personal information). EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact FrontStream at: privacy@FrontStream.com.
FrontStream has further committed to refer unresolved Privacy Shield complaints to Privacy Trust, an alternative dispute resolution provider located in the U.S. If you do not receive timely acknowledgment of your complaint from FrontStream, or if FrontStream has not addressed your complaint to your satisfaction, please contact or visit Privacy Trust at https://www.privacytrust.com/cert/411716.html for more information or to file a complaint. The services of Privacy Trust are provided at no cost to you.
Under certain conditions, more fully described on Annex I of the EU-US Privacy Shield Framework Privacy Shield website (How to Submit a Complaint) you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
If you have any questions or concerns about this Policy, please contact us by email at:
privacy@FrontStream.com, or in writing to:
FrontStream Payments Inc.
Attn: Privacy Team
2093 Philadelphia Pike #1677
Claymont, DE 19703
USA
Copyright 2023 FrontStream Holdings, LLC.
Copyright 2023 FrontStream Holdings, LLC.