Privacy Policy

We may collect and use the following information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information,
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
• Geolocation data
• Audio, electronic, visual, thermal, or similar information
• Professional or employment-related information, including employment candidacy information, including contact, resume, and salary information as part of submissions for employment opportunities
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

This information is required for us to provide our products and services to you. If you do not provide certain personal information, it may delay or prevent us from providing our products and services to you.

We collect most of this personal information directly from you—by telephone, text or email, or via our Website and App.

We may also collect information:

• From publicly accessible sources (e.g., government databases);
• Directly from a third party (e.g., our service providers for the Services and our products and services, marketing and advertising partners);
• From a third party with your consent (e.g., your bank, financing partners, affiliate partners); and
• From cookies or other online tracking tools on our Services

We automatically gather information about your computer such as your IP address, browser type, referring/exit pages, and operating system. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

Geolocation Information Collection.

We may also use various technologies, including Google API, to collect and process information about your actual location. This location information allows us to tailor and provide our Services to you.

A note about information obtained from credit reporting agencies:

we may obtain credit information about you from an outside credit reporting agency to help us with customer authentication and credit-related decisions, such as eligibility for discounts or contract length. When possible, we use a “soft” inquiry to determine qualification, which does not use your social security number and is not recorded on your credit history.

Personal Information Collected through the Security Camera or other Camera-Enabled Products.

When you enable the recording features of our camera-enabled products, we, or our third-party service providers, will record, store, and process video and/or audio recordings from these devices according to the selections you make during the set-up process. We process and store information from your camera-enabled product in order to send you alerts when there is an event. If you have the recording features enabled, during the subscription period applicable to your camera-enabled product we will capture, process, and store video and audio recordings from your camera depending on your enabled settings. This data will be stored until your storage capacity is reached, at which point the data will be deleted to accommodate new incoming data on a first-in-first-out basis. YOU (AND NOT FRONTPOINT SECURITY SOLUTIONS, LLC) ARE SOLELY RESPONSIBLE FOR ENSURING THAT YOU COMPLY WITH ANY APPLICABLE LAWS WHEN YOU USE CAMERA-ENABLED PRODUCTS AND THE ASSOCIATED RECORDINGS.

Frontpoint and our marketing partners, affiliates, and analytics providers use technologies such as cookies, beacons, tags, and scripts, to analyze trends, administer the Services, track users’ movements around the Services, identify which emails and links have been opened by recipients, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We also may use cookies to maintain user shopping carts between sessions, or otherwise to remember users’ settings or movements around the Website and App. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Services, but your ability to use some features or areas of our Services may be limited.

From time to time we may partner with a third-party ad network to either display advertising on our Services or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on our Services and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here.Please note this does not opt you out of being served advertising. You will continue to receive generic ads

We may also use third party analytics, including Google Analytics in connection with the Services. You can opt out from the use of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout

Our Website and App may contain links to the websites of our affiliates and other third parties whose privacy practices may differ from ours. If you submit personal information to any of these third-party sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or link to from our Services.

We may use personal information for the following purposes:

• To confirm and/or fulfill your order;
• To provide products and services to you;
• To send you requested product or service information;
• To send product updates or warranty information;
• To respond to customer service requests;
• To administer your account;
• To comply with our legal and regulatory obligations;
• For our legitimate interests or those of a third party, meaning we have a business or commercial reason to use the personal information; or
• Where you have given consent.

In addition to the foregoing, the table below provides examples of how we may use your personal information and our reasons for such use:

How we may use your personal information

Our reasons To provide products and services to you For the performance of our agreement with you or to comply with your requests To prevent and detect fraud against you or Frontpoint For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you Processing necessary to comply with professional, legal and regulatory obligations that apply to our business To comply with our legal and regulatory obligations Ensuring business policies are adhered to, e.g. policies covering security and internet use For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information; and to comply with our legal and regulatory obligations Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price Updating and enhancing customer records To comply with our legal and regulatory obligations; and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products Marketing our services and those of selected third parties to:

• existing and former customers;
• third parties who have previously expressed an interest in our services;
• third parties with whom we have had no previous dealings.

For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers

A note about customer testimonials/comments/reviews:

we occasionally post customer testimonials/comments/reviews through our Services that may contain personal information. We obtain the customer's consent prior to posting the testimonial to display their name along with their testimonial. If you wish to update or delete your testimonials/comments/reviews, you can contact us at [email protected].

A note about blogs and community forums:

our Services may offer publicly accessible blogs and community forums. Any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new offerings.

You have the right to opt out of receiving promotional communications at any time by:

• Using the “unsubscribe” link in emails
• Texting the word “STOP” to us in texts; or
• Updating your marketing preferences at https://go.frontpoint.com/SubscriptionManagement.

Information regarding our promotional text messages as well as the terms of service governing such messages can be found here. Phone numbers collected by us will not be shared with affiliates or third parties for marketing purposes.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

• Our affiliates;
• Service providers we use to help deliver our products and services to you, such as payment service providers, warehouses and delivery companies;
• Other third parties we use to help us run our business, such as marketing agencies or website hosts;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Credit reporting agencies;
• Our insurers and brokers;
• Our banks; and
• Our investors.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

We also impose contractual obligations on service providers restricting their use of your personal information to provide services to us and to you.

We may also share personal information with external auditors. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We may also disclose personal information that we collect or you provide as described in this policy:

• In the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets in which personal information held by us about you is among the assets transferred;
• To enforce or apply our other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect our rights, property, or the safety of our company, our customers, or others;
• For any other purpose disclosed by us when you provide the information; or
• With your consent.

We may aggregate, de-identify, and/or anonymize any information collected through the Services so that this data no longer contains any personally identifiable information and cannot be linked to any particular individual. We may use and share this aggregated and anonymized information which does not contain any personal information for any purpose and may also share this data with third parties.

We do not sell your personal information to third parties.

We have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information
• Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Personal health information (e.g., age, gender, medical conditions, allergies)
• Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)
• Geolocation data
• Audio, electronic, visual, thermal, or similar information
• Professional or employment-related information, including employment candidacy information, including contact, resume, and salary information as part of submissions for employment opportunities
• Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

Frontpoint is based in the United States, and personal data collected by Frontpoint worldwide (including within the European Economic Area) may be transferred to the United States for processing and storage. For example, we may import your personal information into the United States to fulfill our contractual obligations to you. By providing personal information to Frontpoint, you consent to the transmission of your information outside your own country to be stored in the United States. We take steps to ensure that any such transfer complies with data protection law and that all personal information is secure, including, where appropriate, putting in place standard contractual clauses or implementing other lawful tools and processes for transferring personal information.

We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To comply with laws and regulations and provide to law enforcement agencies;
• To preserve our business records; and/or
• To conduct our business operations.

You may be entitled to the additional privacy rights listed below based on various state privacy laws, including if you are a resident of California, Colorado, Connecticut, Utah and Virginia:

• The rights to know/access. You may have the right to request to access or know (i) the specific pieces of personal information we have about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources from which that personal information was collected; (iv) the categories of personal information we have sold or disclosed; (v) the categories of third parties to whom you personal information was sole or disclosed; and (vi) the purposes for collecting and selling your personal information. Generally:
• We have collected the categories of personal information detailed in the section titled “Personal Information We Collect About You” above.
• We have disclosed the categories of personal information detailed in the section titled “Personal Information We Have Sold or Disclosed for a Business Purpose” above.
• The right to correction. You may have the right to request that we correct the personal information that we have collected or maintain about you.
• The right to deletion. You may have the right to request that we delete the personal information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we deny your request for deletion, we will let you know the reason why.
• The right to restrict or opt out of the sale of your personal information. You may have the right to opt out of the sale or sharing of your personal information and can do so using the “Data Request” tab on the Privacy icon popup on our Website.
• The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Services

You may request your right to know and your right to deletion free of charge up to two (2) times in any twelve (12) month period.

To exercise the rights described above, please contact us as follows:

Mail:Frontpoint Security

22650 Executive Drive, Stes 119-122 Sterling, VA 20166 Email: [email protected] (please use “CCPA” in the subject line)

Phone: +1.877.602.5276

Please note that in order for a request to be verifiable, you may be required to confirm information that we have on file for you; including email address, phone numbers, full names, addresses and other information. We reserve the right to deny a consumer request if the identity of the requesting party cannot be confirmed.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

The Services are not intended for use by anyone under the age of 16. We do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not create an account with us or attempt to send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at [email protected].

This policy is effective as of the date first listed above. We may change this privacy notice from time to time–when we make material changes to this policy we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website or our App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to Contact Us” above).

Please contact us if you have any questions about this privacy policy or the information we hold about you.

Mail:

Frontpoint Security

22650 Executive Drive, Stes 119-122

Sterling, VA 20166

Email: [email protected]

Phone: +1.877.602.5276

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to Contact Us” above).