Frontline Privacy Policy

Last Modified: July 15, 2018

TL;DR

Occam Technologies is a data processor for every type of data processing outside of the direct administration of our services.

Occam’s services are to provide an interoperable, secure text messaging platform. We do not sell, or permit the sale of our, data to third parties.

Occam does transfer some data to third party platforms as components of our service. Those service providers include our web and app hosting; behavioral analytics to track website and app use; and a small number of email, support ticket, and productivity management applications. We do not send them personal information, unless prompted by a user or their communication, nor do we permit them to sell or advertise our user data – under any circumstance.

We are, however, hosted on Amazon Web Services in the United States. As a data processor, it’s important that our data controller users are aware that their use of our platform – and any multi-platform workflows run through our platform – may raise data protection liabilities.

If, at any point, you have questions or concerns about our policy or use of data, please contact support@frontlinesms.com or our CEO, directly sean@frontlinesms.com.

We strongly encourage our users to independently evaluate their compliance with applicable data protection, privacy, and rights law prior to using Frontline, or any other web-connected service.

The Full Policy

This Privacy Policy provides our policies and procedures for collecting, using, hosting, transferring, and disclosing your data. Users (“You”) can access FrontlineSMS, FrontlineCloud, FrontlineSync, our website, and our other services via www.frontlinesms.com and https://cloud.frontlinesms.com (together, the “Service”).

Data controllers acknowledge that use of our platform constitutes license to store and process data in the United States, or any other country in which Occam Technologies, Inc. or its subsidiaries (together, “Occam” or “We”), affiliates, or service providers operate. Occam will notify users of any services or new offices that affect their data protection rights.

Occam produces three (3) products: FrontlineSMS (desktop); FrontlineCloud (web-hosted), and FrontlineSync (Android Gateway). In addition, we have a website and a newsletter – both of which use analytics tools to understand use.

All of Occam’s products require affirmative consent and do not, beyond basic registration, collect personal information. Users may, however, use our platform to collect, store, process, automate, transfer, or create personal information. For all such actions, Occam and the Frontline products are processors, and enable compliance. If, for any reason, Frontline users have questions or concerns that any of our tools, platforms, or partners prohibit applicable data protection requirements, please contact support@frontlinesms.com.

Users acknowledge that we may collect, store, and transfer information that results from your use of the Service, including personal information, to affiliated entities, or to other third parties across borders from your country or jurisdiction and to other countries or jurisdictions around the world. In the event that we make changes to our data hosting, server architecture, or non-technical processes that have a material effect on your data or privacy we will give you notice with ample time to export or delete your data. To subscribe to our Terms of Service and Privacy Policy notification list serve, email info@frontlinesms.com.

If you are located in the European Union or other regions with laws governing data collection – specifically the GDPR – and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. By using the Service, you assume responsibility for the transfer of information to the U.S. or any other country in which Occam, its affiliates, and service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

This Privacy Policy governs your access to the Service, regardless of how you access it, and by using our Services you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy. All of the different forms of data, content, and information described below are collectively referred to as “information.”

The Information We Collect And Store

We may collect and store the following information when running the Service:

Information You Provide. When you register an account, we collect some personal information, such as your name, e-mail address, credit card or other billing information, and postal address. You may also provide us with your contacts’ phone numbers, email addresses or Personal Information, directly, or by granting us access to a third party service.

Log Data. A “Device” is any computer used to access the Service, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. When you use the Service, we automatically record information from your Device, its software, and your activity using the Services. This may include the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your communications, and other interactions with the Service.

Cookies. We also use “cookies” to collect information and improve our Services. A cookie is a small data file that we transfer to your Device. We may use “persistent cookies” to save your registration ID and login password for future logins to the Service. We may also use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage and web traffic routing on the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

How We Use Personal Information

Personal Information. In the course of using the Service, we may collect personal information that can be used to contact or identify you (“Personal Information”). Personal Information is or may be used: (i) to provide and improve our Service, (ii) to administer your use of the Service, (iii) to better understand your needs and interests, (iv) to personalize and improve your experience, and (v) to provide or offer software updates and product announcements.

If you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications, or send us an e-mail at support@frontlinesms.com.

Occam employees and contractors generally do not have access to view messages or contact information associated with your Account. Certain authorized employees and contractors of Occam have access to view data associated with your Account, including profile settings, automated services, log messages, and summary statistics – in order to assist you, with your consent. In limited circumstances, authorized employees or contractors of Occam may access other information associated with your Account, including contacts or messages, in order to investigate or resolve problems with the Service, or if required by legal process.

The Service provides automatic notification when a member of Occam staff accesses your workspace, including the name and purpose of their visit. If you have any concerns about an unauthorized member of our team accessing your account, email support@frontlinesms.com.

Geo-Location Information. Some Devices allow applications to access real-time location-based information (for example, GPS). We do not collect such information from your mobile device at any time during use our Service. Some of the information we collect from a Device, for example IP address, can sometimes be used to approximate a Device’s location.

Analytics. We collect information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyze use of the Service, for the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to verify users have the authorization needed for the Service to process their requests. As of the date this policy went into effect, we use Google Analytics, Heap Analytics and Facebook pixel. To learn more about the privacy policy of Google Analytics, click here, and to learn how to opt out of that service click here.

Information Sharing and Disclosure

Your Use. We will display your Personal Information in your profile page and elsewhere on the Service according to the preferences you set in your account. Any information you choose to provide should reflect how much you want others to know about you – however, we do not share user profile pages with other users. Still, please consider carefully what information you disclose in your profile page and your desired level of anonymity. You can review and revise your profile information at any time. We do not sell your personal information to third parties. We may request your consent to use your data, for example if you use a third party application to access your account (see below). Through certain features of the Service, you may also have the ability to make some of your information public. Public information may be broadly and quickly disseminated.

Service Providers, Business Partners and Others. We may use third party companies and individuals to help us provide, analyze, and improve the Service (including but not limited to data storage, message transport, maintenance services, interface design, database management, web analytics, payment processing, and improvement of the Service’s features). These third parties may have access to your information, though only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy. For a list of our Service Provider Partners and links to their Privacy Policies, please e-mail support@frontlinesms.com.  

Third-Party Applications and Service Providers. We may share your information with a third party application with your consent. For example, any messages transmitted via the Service may be accessible to third-party organizations, such as mobile networks and SMS gateway services, that may be used to transmit the messages. These organizations may have their own rules, policies, and security measures controlling who has access to messages transmitted through their services. We are not responsible for what those parties do with your information, so you should make sure you trust the application or mobile network operator - and that it has a privacy policy acceptable to you.

Compliance with Laws and Law Enforcement Requests; Protection of Occam’s Rights. We may disclose your Personal Information to parties outside Occam when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation, or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of Occam or its users; or (d) to protect Occam’s property rights.

Where your personal information has been requested by any governmental entity or other third party pursuant to subpoena or similar legal process, we will notify you as quickly as practicable before providing any such information, unless we are legally prohibited from doing so or we believe in good faith that disclosure is or may be necessary to protect life, avoid serious physical injury or property loss or damage, or to prevent or investigate an ongoing crime.

Business Transfers. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email, our Terms of Service and Privacy Policy listserv and/or a prominent notice on our website) of any change in control or use of your Personal Information, or if either become subject to a different Privacy Policy. We will also notify you of choices you may have regarding the information.

Non-private or Non-Personal Information. We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Service.

Changing or Deleting Your Information

If you are a registered user, you may review, update, correct or delete the Personal Information provided in your registration or account profile by changing your “account settings.” If your personally identifiable information changes, or if you no longer desire our service, you may update or delete it by making the change to your account or e-mailing us at support@frontlinesms.com. In some cases we may retain copies of your information if required by law. For questions about your Personal Information on our Service, please contact support@frontlinesms.com. We will respond to your inquiry as soon as possible.

Data Retention

We will retain your Personal Information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, you may delete your account by sending us an e-mail at support@frontlinesms.com. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion. In addition, we do not delete from our servers files that you have in common with other users.

The Frontline Community

Our Service offers publicly accessible community services such as blogs, forums, and wikis. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Your posts may remain even after you cancel your account. For questions about your Personal Information on our Service, please contact support@frontlinesms.com.

Our Site includes links to other Web sites whose privacy practices may differ from those of Occam. If you submit personal information to any of those sites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any Web site you visit.

Security

The security of your information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website or contact us at support@frontlinesms.com.

Our Policy Toward Children

Our Services are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@frontlinesms.com If we become aware that a child under 13 has provided us with Personal Information, we will take steps to delete such information from our files.

11. Contacting Us

If you have any questions about this Privacy Policy, please contact us at support@frontlinesms.com.

12. Changes to our Privacy Policy

This Privacy Policy may change from time to time. If we make a change to this privacy policy that we believe materially reduces your rights, we will provide you with notice (for example, by email and via our Terms of Service and Privacy Policy listserv). By continuing to use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy