Privacy Policy

1 - Definition and nature of personal data

During your use of the services that can be accessed on the Website www.frontapp.com hereinafter referred to as the “Website”), we may require you to provide us with personal data. The term “personal data” means any data that enables a person to be identified, which corresponds in particular to your family name, first name, photograph, postal address, email address, telephone numbers, date of birth, data relating to your transactions on the Website, detail of your orders and subscriptions, bank card number, as well as any other information about you that you choose to provide us with.

2 - Purpose of this privacy policy

The purpose of this Privacy policy is to inform you of the means that we use to collect your personal data, with the strictest respect for your rights. We would like to point out to you on this subject that we comply, in the collection and management of your personal data, to the current version of the French law N° 78–17 dated 6th January 1978 on Information Technology, Data Files and Civil Liberties.

3 - Collecting personal data

Your personal data is collected to meet one or several of the following requirements:

  • To manage your access to the services provided by the Website and their use,
  • To carry out operations that relate to the management of customers concerning the contracts, orders, deliveries, invoices, - fidelity programs, follow-up of the customer relations,
  • To constitute a file of registered members, users, customers and prospects,
  • To send newsletters, entreaties and promotional advertisements. If you would not wish to receive these, we offer you the - option to check a box expressing your refusal on this subject when data is being collected.
  • To provide commercial and service use statistics
  • To organize promotional games, sweepstakes or any promotional operation except gambling and online gambling, that are subject to the approval of the Regulatory Authority of Online Games,
  • To manage customer’s opinions on products, services or contents,
  • To manage unpaid invoices and possible disputes about the use of our products and services,
  • To respect our legal and regulatory obligations.

We will inform you, when requesting your personal data, if certain data must be provided or if it is optional. We will also inform you of the consequences should you not wish to provide this data.

We take commercially reasonable efforts to maintain security protections in accordance with industry practices to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure.

3.1 - Privacy Shield

FrontApp Inc complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. FrontApp Inc has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Liability. A violation of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit privacyshield.gov.

FrontApp Inc is overseen by the US Federal Trade Commission (FTC). JAMS is the US-based independent organisation responsible for reviewing and resolving complaints about our Privacy Shield compliance – free of charge to you. We ask that you first submit any such complaints directly to us at privacyshield@frontapp.com. If you are not satisfied with our response, please contact JAMS at www.jamsadr.com/eu-us-privacy-shield. In the event that your concern still is not addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.

Within the scope of our authorization to do so, and in accordance with our commitments under the Privacy Shield, FrontApp Inc will provide individuals access to personal data about them. FrontApp Inc also will take reasonable steps to enable individuals to correct, amend, or delete personal data that is demonstrated to be inaccurate.

FrontApp Inc 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. FrontApp Inc complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

4 - Recipients of the collected data

Only our personnel, the services in charge of control (especially: external auditor) and trusted third-party applications may have access to your personal data. Government agencies may also be recipients of your personal data, exclusively to meet legal obligations, or representatives of the law, ministerial officers and organizations responsible for the collection of debts.

5 - Transfer / sale of personal data

We shall not sell, transfer or lease out your personal data to third parties.

6 - Duration that personal data is kept

6.1 General provisions

Your personal data is stored for the duration that you use the Services. It will be deleted one year after your membership has ended, at the latest, with the exception of data that is required to establish proof of a right or a contract which will be stored for the duration provided by enforceable law.

6.2 Provisions specific to bank card data

Data relating to bank cards are stored no longer than the time necessary to allow the fulfillment of the transaction, except in the case of a subscription, to facilitate the payment of regular customers. In that case, bank card data are stored for the whole duration of your subscription and at least until the date at which you carry out your last transaction. Such storage is implemented by our secured payment service provider Stripe.

By subscribing to the services offered on the Website, you expressly agree to this storage. Data relating to the visual cryptogram or CVV2 on the back of your bank card are not stored. In the case of a payment by bank card, however, data relating to the bank card may be stored as intermediary archives for evidence purpose in the case of possible disputes regarding the transaction, for the duration provided by article L.133–24 of the French Monetary and Financial Code, i.e. 13 months from the debit date. This duration may be extended to 15 months, to take into account the possible use of delayed debit card.

7 - Safety

For your information, we take all necessary precautions, as well as the appropriate organizational and technical measures, to maintain the security, integrity and confidentiality of your personal data, and in particular to prevent it from being deformed or damaged and to prevent any unauthorized third party from accessing it. We also use secured payment systems consistent with the state of the art and the applicable regulation.

8 - Cookies

Cookies are alphanumeric identifiers that are transferred to your computer or mobile device from your browser. There are two types of cookies: technical cookies and advertising cookies. We use technical cookies to facilitate your browsing experience. Thanks to them, you do not have to retype your login and password when you connect to your mailbox for example. They simplify your visit and enhance the dialog ergonomics. You can refuse the installation of technical cookies in your browser settings. However, this refusal could prevent you from using the services offered on the Website. In comparison with technical cookies, advertising cookies enable the use of the retargeting technique which is a marketing model whose purpose is to propose advertisements to the internet user that are adapted specifically for them. We hereby inform you that we do not use such cookies. However, if we should decide to use them in the future, we will inform you prior to this and you may express your opposition, should you wish.

When you choose to provide your personal data you expressly give your consent for the collecting and use of your personal data in compliance with the provisions set forth in this Privacy policy and the legislation in force.

10 - Modifications

We reserve the right, at our sole discretion, to modify this Privacy policy or any portion thereof. Any changes will be effective from the time of publication of the new Privacy policy. Your use of the Website after the changes have been implemented implicitly expresses your acknowledgement and acceptance of the new Privacy policy. Otherwise, and if the new Privacy policy does not suit you, you must no longer use the Services.

11 - Contact

Have questions or concerns about Front and privacy? Contact us at privacy@frontapp.com.