Frent, LLC (“we”, “us”, or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy (“Privacy Policy”) to describe to you our practices regarding the information that we collect from users on our software (“Software”) and the products and services offered through the Software (collectively, the “Services”). By accessing or using this Software, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, you should not use or access this Software. We reserve the right to revise this Privacy Policy at any time. You are encouraged to review the Privacy Policy each time you use the Software because your use of the Software after the posting of changes will constitute your acceptance of the changes. Agreement to this Privacy Policy also constitutes your agreement to the Frent Terms of Service (the “Terms”), which is incorporated herein.

Biometric Data

“Biometric Data” is considered any biometric identifiers and biometric information, including a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry, regardless of how it is captured, converted, stored, or shared, which is used to identify an individual. The definition of Biometric Data may vary under different state laws.

Information Collected

When you consent to use our Services on our Software, you provide us your name, contact information, date of birth, and personal email address (“Personal Information”). In order to utilize the Services, you will have to allow the Software to create a biometric scan of your hand, which is included in the definition of “Biometric Date”. Frent does not collect, use, store, or disclose your Biometric Data without your consent. We may retain Personal Information on your behalf, such as emails that you send (including the content of the message and the recipient data), using your information.

Use of Your Personal Information

General Use

In general, Personal Information you submit to us is used either to respond to requests that you make, or aid us in serving you better.

We use your Personal Information in the following ways:
• respond to comments, requests, and questions and provide customer service
• identify you as a user in our system
• provide, process, and deliver the Services you request
• improve the quality of experience when you interact with our Services
• send you administrative e-mail notifications
• resolve disputes and/or troubleshoot problems

User Feedback

We may post user feedback on the Services from time to time. If you make any comments on a blog, social networking website, or forum associated with the Services, you should be aware that any information you submit there can be read, collected, or used by other users of these forums and could be used to send you unsolicited messages. We are not responsible for the information you choose to submit in these blogs and forums.

Disclosure of Information

Biometric Data

Unless otherwise required by law, your Biometric Data is accessible only to us and our service providers, which process your data only on our behalf to accomplish the purposes of our Software, which are to provide you with the Services. We do not share Biometric Data with any other third parties unless required by law. We do not sell, lease, trade, or otherwise profit from your Biometric Data. We may disclose your Biometric Data to our authorized service providers or other third parties if:

• You or your authorized representative consent to the disclosure;
• the disclosure completes a financial transaction requested or authorized by you or your authorized representative;
• the disclosure is required pursuant to a valid warrant, subpoena, or court order issued by a court of competent jurisdiction; or
• the disclosure is required by law.

Personal Information

When you use the Services, we may share your Personal Information with third-party service providers to provide you with the Services, provide updates and technical support, and market the Services. Regardless of any choices you make regarding your Personal Information, we may disclose Personal Information if we believe in good faith that such disclosure is necessary:

• In connection with any legal investigation;
• to comply with relevant laws or to respond to subpoenas or warrants served on us;
• to protect or defend the rights or property of Frent or users of the Services; and/or
• to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms.

Your Rights Under the California Consumer Privacy Act (CCPA)

You have the right under the CCPA of 2018 and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know:

1. The categories of personal information we have collected about you;
2. The categories of sources from which the Personal Information is collected;
3. Our business or commercial purpose for collecting or selling Personal Information;
4. The categories of third parties with whom we share Personal Information, if any; and
5. The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

1. Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
2. Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
3. Provide the Personal Information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any Personal Information that we may sell or disclose to a third party for a business purpose, you have the right to know:

1. The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
2. The categories of Personal Information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (“CCPA”) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your Personal Information. If you exercise your right to opt-out of the sale of your Personal Information, we will refrain from selling your Personal Information, unless you subsequently provide express authorization for the sale of your Personal Information.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

1. Delete your Personal Information from our records; and
2. Direct any service providers to delete your Personal Information from their records.

Please note that we may not delete your Personal Information if it is necessary to:

1. Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
3. Debug to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise her or his right of free speech, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act;
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
8. Comply with an existing legal obligation; or
9. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

1. Deny goods or services to you;
2. Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
3. Provide a different level or quality of goods or services to you; or
4. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

Choice/Opt-Out

We want to communicate with you only if you want to hear from us. You may choose to stop receiving marketing emails by following the unsubscribe instructions included in these emails, updating your communications preferences on our Software, or contacting us directly. Please note, however, that as a user of the Services, you cannot opt-out of some administrative communications that are reasonably necessary to the Services, such as billing notifications.

You have the right to access, update, and correct inaccuracies in your Personal Information in our custody and control, subject to certain exceptions prescribed by law. You may request access, an updating, or the correction of inaccuracies in other Personal Information in our custody or control by contacting us directly.

Retention and Storage

We will collect, store, transmit, and protect your Biometric Data and other information using a reasonable standard of care that is at least as protective as the way we collect, store, transmit, and protect other confidential and sensitive Personal Information.

Unless otherwise required by an order from a court of competent jurisdiction or applicable law, we will only retain Biometric Data until: (i) the Services for which the Biometric Data was collected have been satisfied, or (ii) for one (1) year following your last interaction with Frent, whichever occurs first, unless legally required to keep it for a different period.

Changes to This Privacy Policy

We may revise this Privacy Policy from time to time, and if we make any material changes in the way we use your Personal Information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on the Software and updating the “Last Updated” date below. If we make any changes to this Privacy Policy, they will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on the Software. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes.

Continued use of our Services following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Contact Us

Contact Us. Please send your feedback, comments, and requests for technical support by email at: support@Frent.com

Last updated: September 16, 2024