Privacy Policy - New Frontier Group

At New Frontier Group, your privacy is very important to us. Part of the operation of the New Frontier Group website involves the collection and use of information about those who visit and/or use the website. This privacy policy explains what type of information we collect and what we may do with that information. This privacy policy may change from time to time, so please check it often.

The information we collect is used to improve the content of our site. Personal information is not shared with, nor is it sold to, other organizations for commercial purposes, except to provide better access and/or functionality that you may have requested. However, we do reserve the right to collect and aggregate data, ratings, and reviews for commercial purposes without identifying the source of such data, ratings, or reviews.

Scope of this Policy

This privacy policy applies to:

New Frontier Group and our affiliates (“Client,” “we,” “us,” “our”).
New Frontier Group’s online properties (including our websites and websites or mobile applications that link to it), our social media pages or handles, our products and services (the “Services”).

This Policy applies when you interact with us through our Services. It also applies anywhere it is linked. It does not apply to third-party websites, mobile applications, or services that may link to the Services or be linked to from the Services. Please review the privacy policies on those websites and applications directly to understand their privacy practices.

We may change this Policy from time to time. If we do, we will notify you by posting the updated version.

Information We Collect

We collect information from you directly, from the devices you use to interact with us, and from third parties. We may combine information from the Services together and with other information we obtain from our business records. We may use and share information that we aggregate (compile to create statistics that cannot identify a particular individual) or de-identify (strip information of all unique identifiers such that it cannot be linked to a particular individual) at our discretion.

Information you give us

You may provide the following information to us directly:

Contact and professional information, including name, email address, telephone number, and job title, as well as company name and size.
Demographic information.
Audiovisual information, including recordings of online events.
Payment information, including credit card information.
Content you may include in survey responses.
Information contained in your communications to us, including call recordings of customer service calls.
Information you make available to us via a social media platform.
Any information or data you provide by interacting in our online forums and chatrooms, or by commenting on content posted on our Services. Please note that these comments are also visible to other users of our Services.
Information you submit to inquire about or apply for a job with us.
Any other information you submit to us.

Information we collect automatically

We and partners working on our behalf may use log files, cookies, or other digital tracking technologies to collect the following information from the device you use to interact with our Services. We also create records when you make purchases or otherwise interact with the Services.

Device information, including IP address, device identifiers, and details about your web browser.
Analytical information, including details about your interaction with our website, app, and electronic newsletters.
Diagnostic information, including web traffic logs.
Advertising information, including special advertising and other unique identifiers that enable us or third parties working on our behalf to target advertisements to you. Please be aware that our advertising partners may collect information about you when you visit third-party websites or use third-party apps. They may use that information to better target advertisements to you on our behalf.
Business record information, including records of your purchases of products and services.

The following is a list of our partners who collect the information described above. Please follow the links to find out more information about the partner’s privacy practices.

Partner	Information Type Collected
Google Analytics	Analytical Information
Digital Advertising	Analytical Information

How We Use Your Information

We may use any of the information we collect for the following purposes:

Performance of a contract: To provide you with our products and services, including to take steps to enter a contract for sale or for services, process payments, fulfill orders, send service communications (including renewal reminders), and conduct general business operations, such as accounting, recordkeeping, and audits.
Legitimate interests: We also process your personal data to protect the legitimate interests of us or third parties, unless your interests, which require the protection of your personal data, outweigh them. Data processing is carried out on the basis of Article 6 paragraph 1 letter f) GDPR. Processing to safeguard legitimate interests is carried out for the following purposes or to safeguard the following interests:
- To improve and grow our Services, including to develop new products and services and understand how our Services are being used, our customer base and purchasing trends, and the effectiveness of our marketing.
- To protect and secure our Services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
Consent: We collect personally identifiable information for providing the website access and usage that you request.
Legal obligation: Except for the disclosure of information in accordance with and furtherance of the Terms of Use, we will not sell or give any personally identifiable information to any other third parties unless compelled by law or to investigate, prevent, or take action regarding illegal activities or suspected fraud. We may be required by law enforcement or judicial authorities to provide personally identifiable information to the certain governmental authorities. If requested by law enforcement or by judicial order, we will provide this information on receipt of the appropriate documentation. We may also release information to law enforcement agencies or other third parties if we feel it is necessary to protect the safety and welfare of our personnel, any other person, or to enforce these Terms of Use.

How We Share Your Information

We may share any of the information we collect with the following recipients.

Affiliates: We share information with other members of our group of companies.
Service providers: We engage vendors to perform specific business functions on our behalf, and they may receive information about you from us or collect it directly. These vendors are obligated by contract to use information that we share only for the purpose of providing these business functions, which include:
- Supporting Service functionality, such as vendors that support event registration, customer service and customer relationship management, subscription fulfillment, freight services, application development, list cleansing, postal mailings, and communications (email, fax).
- Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
- Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
- Analytics and marketing services, including entities that analyze traffic on our online properties and assist with identifying and communicating with potential customers.
- Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- Information technology vendors, such as entities that assist with website design, hosting and maintenance, data and software storage, and network operation.
- Marketing vendors, such as entities that support distribution of marketing emails.
Business partners: From time to time, we may share your contact information with other organizations for marketing purposes.
Online advertising partners: We partner with companies that assist us in advertising our Services, including partners that use cookies and online tracking technologies to collect information to personalize, retarget, and measure the effectiveness of advertising.
Social media platforms: If you interact with us on social media platforms, the platform may be able to collect information about you and your interaction with us. If you interact with social media objects on our Services (for example, by clicking on a Facebook “like” button), both the platform and your connections on the platform may be able to view that activity. To control this sharing of information, please review the privacy policy of the relevant social media platform.
Government entities/Law enforcement: We may share information when we believe in good faith that we are lawfully authorized or required to do so to respond to lawful subpoenas, warrants, court orders, or other regulatory or law enforcement requests, or where necessary to protect our property or rights or the safety of our employees, our customers, or other individuals.
Other businesses in the context of a commercial transaction: Customer lists, information, and all data on the website are properly considered assets of a business. Accordingly, if we merge with another entity or if we sell our assets to another entity, our customer lists and information, including personally identifiable information that you have provided us, would normally be included among the assets transferred.

Security

We operate secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the personally identifiable information provided by our users. We do not, however, guarantee that unauthorized, inadvertent disclosure will not ever occur.

Your Options and Rights Regarding Your Information

Your Account: Please visit your account page to update your account information.

Email Unsubscribe: If you do not wish to receive marketing information from us or wish to opt out of future email promotions from us, please contact us. Please note that all promotional email messages you receive from us will include an option to opt out of future email communications.

Ad Choices: You have options to limit the information that we and our partners collect for online advertising purposes.

You may disable cookies in your browser or mobile device using their settings menus. Your mobile device may give you the option to disable advertising functionality. Because we use cookies to support Service functionality, disabling cookies may also disable some elements of our online properties.
The following industry organizations offer opt-out choices for companies that participate in them: the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.
You may use our cookie settings menu.
You may contact us directly.

If you exercise these options, please be aware that you may still see advertising, but it will not be personalized. Nor will exercising these options prevent other companies from displaying personalized ads to you.

If you delete your cookies, you may also delete your opt-out preferences.

Do Not Track: Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices and the choices that we provide to you will continue to operate as described in this privacy policy regardless of whether a Do Not Track signal is received.
Jurisdiction-specific rights: You may have certain rights with respect to your personal information depending on your location or residency. Please see “privacy disclosures for specific jurisdictions” below. Please contact us to exercise your rights.

Special Information for Job Applicants

When you apply for a job with us, we may collect information from you, including:

Information you provide in connection with your application.
Information that you make available in your social media accounts.
Information about you that is available publicly.
Information that you authorize us to collect via third parties, including former employers or references.

In certain circumstances, you may submit your application for employment through a third-party service that displays our job posting. We do not control the privacy practices of these third-party services. Please review their privacy policies carefully prior to submitting your application materials.

Other Important Information

Data retention

We may store information about you for as long as we have a legitimate business need for it. The following are some examples that illustrate how New Frontier Group keeps your personal data and for what purpose:

New Frontier Group may keep your personal data collected during a site visit involving a purchase of services for as long as required by applicable tax law;
New Frontier Group may keep your personal data relating to your user account for up to 9 months following the date you delete your account so you may reactivate the account if preferred; and
New Frontier Group may keep your personal data associated with your hardware so you may continue access from your hardware device.
New Frontier Group will delete your email address used for direct marketing purposes (such as newsletters, service offers, etc.) after you have informed us that you no longer wish to receive such communications from New Frontier Group. We will retain your email address for service-specific communications unless you request removal, accomplished by deleting your account with New Frontier Group or the applicable subscriber.

Cross-border data transfer

We may collect, process, and store your information in the United States and other countries. The laws in the United States regarding information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law. See below for data transfers from Europe.

Information about children

The Services are intended for users who are thirteen years old and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 13, we will delete that information. Please contact us with any concerns.

Sharing of Medical or Health Information

Use of protected health information (PHI) covered by HIPAA is subject to NFG’s business associate agreements with covered entities. To the extent that we receive protected health information about you, that information is subject to electronic disclosure to the extent permitted by applicable law.

Privacy Disclosures for Specific Jurisdictions

European Economic Area, United Kingdom, and Switzerland

We process “personal data,” as that term is defined in the European Union’s General Data Protection Regulation (“GDPR”).

For Users who are “natural persons” as defined under General Data Protection Regulation (“GDPR”) and are visiting our Platform and Site from the European Union (“EU”) or any other country outside the United States, please be advised that your information may be transferred to, stored, and/or processed in the United States, which is where New Frontier Group servers are located. Data protection and other laws of the United States or other countries might not be similar or as comprehensive as those in your country, but please be assured that New Frontier Group takes the appropriate steps pursuant to laws and regulations in the United States to ensure that your privacy is protected.

In order to use the New Frontier Group platform, either directly or via a hosted subscriber portal, Users must provide a name and email address. New Frontier Group will encrypt personal data when such data is transferred (aka “Pseudonymisation”). Users personal data may be transferred to and stored in locations outside the European Economic Area (“EEA”) (such as the United States of America) at a New Frontier Group server.

If New Frontier Group (either directly or indirectly) transfers your personal data to a recipient outside the EEA, it will only do so in compliance with the GDPR. If your personal data is obtained and stored on New Frontier Group server as a result of your relationship with a New Frontier Group’s subscriber, New Frontier Group we will take appropriate steps to ensure that your personal data is adequately protected under applicable law. Typically, New Frontier Group carries out data security reviews of any recipients and imposes contractual requirements with such recipients to ensure they employ the same or similar technical, functional, and organizational measures as New Frontier Group, so your data is consistently protected under the same or similar standards.

As noted above, your personal data may end up on a server in the United States perhaps because you engaged one of New Frontier Group’s subscribers or otherwise consented to provide such data or personal information to New Frontier Group. New Frontier Group does not use the personal data collected to make automated decisions regarding employment or credit screening.

Your rights under the GDPR: Users who are located in the European Economic Area (“EEA”), U.K., or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in the EEA, U.K., or Switzerland, you have the following rights.

Access and Portability: Request access to personal data we hold about you or request transmission of your data to a third party.
Correction: Request that we rectify inaccurate or incomplete personal data we store about you.
Erasure: Request that we erase personal data when such data is no longer necessary for the purpose for which it was collected, when you withdraw consent and no other legal basis for processing exists, or when you believe that your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
Restriction of processing: Request that we restrict our processing of personal data if there is a dispute about the accuracy of the data; if the processing is unlawful; if the processing is no longer necessary for the purposes for which it was collected but is needed by you for the establishment, exercise or defense of legal claims; or if your request to object to processing is pending evaluation.
Objection to processing: Object to processing of your personal data based on our legitimate interests or for direct marketing (including profiling). We will no longer process the data unless there are compelling legitimate grounds for our processing that override your interests, rights, and freedoms, or for the purpose of asserting, exercising, or defending legal claims.
Transfers: Obtain information about and a copy of the safeguards we use to transfer personal data across borders.

Please contact us to exercise these rights.

California

Your California Privacy Rights; “Shine the Light” Law
We do not share your personal information with third parties for those third parties’ direct marketing purposes.

California Consumer Privacy Act
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of information about them, as well as rights to know/access, correct, delete, and limit disclosure of personal information. You have the right to be free from discrimination based on your exercise of your CCPA rights. To the extent that we collect personal information that is subject to the CCPA, that information, our practices, and your rights are described below.

Notice at Collection Regarding the Categories of Personal Information Collected

You have the right to receive notice of certain information about our data collection, use, and disclosure. The following table summarizes the categories of personal information we collect; the categories of sources of that information; whether we disclose, sell, or share that information to service providers or third parties, respectively; and the criteria we use to determine the retention period for such information. The categories we use to describe personal information are those enumerated in the CCPA. We collect this personal information for the purposes described above in “How We Use Your Information.”

Category	Information Type	Source	We disclose to:	We sell to/share with:
Identifiers	Contact information or personal characteristics (name; email address; postal address; telephone number; signature) Social media handles	You; our social media pages; third party subscription service providers	Service Providers	Business partners
Health Information	Protected health information Physical or mental status or ailments	You	Service Providers	Not sold / shared
Financial Information	Payment card data Bank account information Credit information	You	Service Providers	Not sold / shared
Protected Classifications and Other Sensitive Data	Date of Birth Gender	You	Service Providers	Not sold / shared
Commercial Information	Transaction Information Billing and payment records Order history	You	Service Providers	Not sold / shared
Geolocation Information	Precise (information that describes location with more precision than ZIP code, e.g., GPS data) Coarse (information that describes location at ZIP code-level or less precision)	You; our analytics and advertising partners	Service Providers	Advertising partners (coarse location only)
Internet or Electronic Network Activity Information	IP address Device identifier (e.g., MAC) Advertising identifier (e.g., IDFA, AAID) Information provided in URL string (e.g., search keywords) Cookie or tracking pixel information Information about your interaction with our website, app, email correspondence, or products Browsing history Search history Diagnostic information (e.g., crash logs, performance data)	You; our analytics and advertising partners	Service Providers	Advertising partners
Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information	Call recordings Photographs Video	You	Service Providers	Not sold / shared
Professional or Employment-Related Information	Current Employer Job Title	You	Service Providers	Not sold / shared
Education Information	Education History Level of Education	You	Service Providers	Not sold / shared
Inferences Drawn About You	User profile reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes	You; our analytics and advertising partners	Service Providers	Advertising partners
Content of Communications	Contents of phone calls, emails, or text messages Photos	You	Service Providers	Not sold / shared
Contacts	List of contacts that you supply List of contacts we collect from your device with your permission	You	Service Providers	Not sold / shared

We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated investigation or litigation.

Entities to whom we disclose information for business purposes are service providers, which are companies that we engage to conduct activities on our behalf. We restrict service providers from using personal information for any purpose that is not related to our engagement.

Entities with whom we “share” information are third parties. Under the CCPA, a business “sells” personal information when it discloses personal information to a company for monetary or other benefit. NFG never sells data. A company may be considered a third party either because we disclose personal information to the company for something other than an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for purposes unrelated to the service it provides to us. A business “shares” personal information when it discloses personal information to a company for purposes of cross-context behavioral advertising.

Your rights under the CCPA

Opt out of sale or sharing of personal information: You have the right to opt out of the sale or sharing of your personal information to third parties. NFG never sells personal information. To exercise this right, please visit contact us. Your right to opt out does not apply to our disclosure of personal information to service providers.

Know and request access to and correction or deletion of personal information: You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. You also have the right to request in certain circumstances that we correct personal information that we have collected about you and to delete personal information that we have collected directly from you. Please contact us to exercise these rights.

Colorado, Connecticut, Utah, and Virginia

Residents of the States of Colorado, Connecticut, Utah, and Virginia have the following rights:

Opt out of “sales” of personal information and use of their personal information for “targeted advertising,” as those terms are defined under applicable law. NFG never sales personal data.
Opt out of “profiling” under certain circumstances, as defined under applicable law. (Residents of Colorado, Connecticut, and Virginia only.)
Confirm processing of and access to personal information under certain circumstances.
Correct personal information under certain circumstances. (Residents of Colorado, Connecticut, and Virginia only.)
Delete personal information under certain circumstances.

Residents of these states can exercise their rights by contacting us at using one of the methods listed below.

Nevada

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties. Currently, we do not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please contact us. NFG never sales data.

Contact information, submitting requests, and our response procedures

Contact

Please contact us if you have questions or wish to take any action with respect to information to which this privacy policy applies.

Email: info@newfrontiergroup.com

Making a request to exercise your rights

Submitting requests: You may request to exercise your rights by submitting the form on this page or making a request using the contact information above.

If you are a resident of California, Colorado, or Connecticut, you may, under certain circumstances, authorize another individual or a business, called an authorized agent, to make requests on your behalf.

We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Verification: We must verify your identity before responding to your request. We verify your identity by asking you to provide personal identifiers that we can match against information we may have collected from you previously. We may need to follow up with you to request more information to verify identity.

We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

Appeals

Residents of Colorado, Connecticut, and Virginia have the right to appeal a denial of their request by contacting us as described in the notice of denial.