Frontegg Privacy Notice Last Revised: 7/12/2022 This policy sets forth how Frontegg Ltd. (“we” or “Frontegg”) collect and use information about users that access, use and engage with our website, located at https://frontegg.com/ or any other online services we provide (collectively, the “Service“). Respect for your privacy is extremely important to us. When you use the Service or otherwise communicate with us in connection with the Service (e.g. via email) you will provide, and Frontegg will collect, certain information, some of which can be used to personally identify and/or locate you (“Personal Information”) . Information Collected Through the Service When you use the Service, Personal Information about you will be collected as follows : Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. You may register to the Services directly through the portal or via single sign on (SSO) from the Customer system (if applicable). Registering through the portal: When you register to the Services through the portal, we may collect from you the following information: user’s full name, email address, as well as any other information you agreed to share with us. Registering through third party services: When you register or sign-in to the Services via third party services, we may have access to basic information from your account, such as Email address, IP address, name and company name. At all times, we will abide by the terms, conditions and restrictions of the third party platform. Voluntary Information: We may collect information which you provide us voluntarily. Further, we may collect information when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints, bugs and reports which you send to us. Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers as well as other information which relates to your activity through the Services. Please note that we may also collect and process information that is non-personal information which is information that cannot be used to identify a specific individual. Such information may include aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. browser type, language preference, access time, etc.) For avoidance of doubt, if we combine Personal Information with non-personal information, the combined information will be treated as Personal Information as long as it remains combined. Legal Basis for Processing Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations. Data Integrity and Purpose Limitation Frontegg may use the Personal Information collected through the Service as follows: To set up your account and to provide the Services; To identify and authenticate your access to the Services; To send you relevant notifications, which are based on different activities offered by the Services; To communicate with you and to keep you informed of our latest updates; To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests; To support and troubleshoot the Services and to respond to your queries; To investigate and resolve disputes in connection with your use of the Services; To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and To investigate violations and enforce our policies, and as required by law ,regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request, or to comply with our contractual obligations. With whom do we share Personal Information Frontegg may share the Personal Information with its subsidiaries, affiliated companies and subcontractors, which may be located across the world, for the following purposes: Providing you with our service, including providing a personalized display of our Site; Storing and processing such information on our behalf; Performing research, technical diagnostics or analytics; We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy. We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights. International transfer Since we operate globally, it may be necessary to transfer data, including Personal Information, to other countries than the country in which the information was collected. In these instances, we will ensure that the transfer is done only to such countries as approved by the European Commission as providing adequate level of data protection, or otherwise ensure that the transfer is done in accordance with an approved legal mechanism under the applicable privacy legislation. For how long we retain the information We retain the information that we collect for as long as necessary to provide our Services and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. Your privacy rights Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to exercise certain rights with respect to your Personal Information such as: Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted); Right to see what Personal Information about you we have; Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information); Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and Right to export Personal Information in a portable format. If you wish to exercise any of these rights, contact us at: privacy@frontegg.com. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services. Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority. How do we Safeguard Personal Information We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access. Changes to this Policy This Privacy Policy may change from time to time. We will post any policy changes on this page. You are encouraged to check for the latest policy often. Each version of this Privacy Policy will be identified at the top of the page by its effective date. Contacting us If you have any questions about this Privacy Policy or concerns about the way we process your Personal Information, or if you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: privacy@frontegg.com The details of Frontegg are as follows:Frontegg Inc2570 W El Camino RealMountain View , CA 94040United StatesOur data protection officer may be contacted by email at: privacy@frontegg.com
