FRONTLINE CALL CENTER PRIVACY POLICY

Last Updated: May 23, 2018

This Frontline Call Center Privacy Policy describes how Frontline Call Center, LLC and its subsidiary group companies (together the “Frontline Group” or “we” or “us”) treat Personal Data that you provide or we collect when you use any of our services (listed below).

Our service consists of (a) our website located at www.frontlinecallcenter.com and our community website located at www.fcccommunity.com, and any subdomains of thereof (collectively, the “Site”), (b) any web-based service made available to you by or on behalf of Frontline Call Center via the Site (each, a “Web-based Offering”), (c) our downloadable or cloud based software applications (each, an “App”) and IT tools (each, a “Tool”), and (d) all  content published on our Site  (other than user content) (the “Content”). The Site, the Web-based Offerings, the Apps, the Tools, and the Content are referred to collectively in this Privacy Policy as our “Service” and each a “Service”. Additional features of portions of the Service are described in our Terms of Use (the “Terms of Use”), which may be found at www.Frontline Call Center.com/terms (or any successor URL).

1. Definitions

The data protection declaration of Frontline Call Center, LLC is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, inter alia, the following terms:

Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

Frontline Call Center, LLC
9 Hope Lane
Eastsound WA, 98245

USA

Email: fccweb@frontlinecallcenter.com
Website: http://www.frontlinecallcenter.com

 

WHAT INFORMATION WE COLLECT

Client and Sales Support. We may collect Personal Data through your communications with our customer support or sales team. Please ensure that no sensitive personal data is submitted in connection with your requests for support (for example, health information, political or religious beliefs, information about minors, etc.).

OUR USE OF COOKIES AND RELATED TECHNOLOGIES

The Internet pages of Frontline Call Center, LLC use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, Frontline Call Center, LLC can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimized with the user in mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user's computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

HOW AND WHY WE USE PERSONAL DATA

The website of Frontline Call Center, LLC collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.  More specifically, we use your Personal Data in the following ways:

Internal and Service-Related Usage. We use data that you input into, or that is collected by, the website to perform the services requested in connection with those portions of our Service. For example, if you input information into our sales quote request form, we will use that information to assist us in providing a custom quote to you for our service offerings.

Contact possibility via the website.  The website of Frontline Call Center, LLC contains information that enables a quick electronic contact to our company, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.

Frontline Call Center Related Communication. When using this general data and information, Frontline Call Center, LLC does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Frontline Call Center, LLC analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

Legal basis for the processing. Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

Customer Testimonials. From time-to-time we may ask individual users to participate in customer testimonials posted on our website. We never post these testimonials without their express permission. Any information provided as part of these testimonials is used solely for the purpose of these testimonials and is not used in any other way. If you wish to update or delete your testimonial, you can contact us at fccweb@frontlinecallcenter.com.

HOW WE SHARE INFORMATION

Service Providers. We may use third party service providers to help us deliver parts of the Service and to improve the Service. For example, we use a third party service to provide web forms for gather information.  When we use third parties to assist us in processing your Personal Data, we require that they comply with appropriate confidentiality and data protection and security measures.

As Required by Law and Similar Disclosures. We reserve the right to disclose your Personal Data as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on the Service. We may also share Personal Data with third parties in limited circumstances, including when preventing fraud or imminent harm and ensuring the security of our network and services.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of our assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

YOUR RIGHTS AND YOUR CHOICES

Under Applicable Data Protection Laws, you may have the right, in certain cases, to request access to your Personal Data that we process, to request details about such Personal Data, including the purposes and potential recipients of this data, to have such Personal Data rectified or deleted, to have the processing thereof restricted, or to object to the processing of your Personal Data, as well as to request a copy of your Personal Data in a standardized format so that it can be provided to another vendor.

You may also have the right to lodge a complaint with your national data protection authority or other public authority governing the protection of your personal information.

Further rights are covered in the EU Standard Contractual Clauses referenced above.

In addition, you may decline to provide Personal Data to us and/or refuse cookies in your browser, but if you do (or if successfully object to the processing of your Personal Data by us, or successfully request that such Personal Data be deleted) some if not all of our features or services may not function properly as a result.

To exercise these rights, please follow the steps set out below, or contact us via email at fccweb@frontlinecallcenter.com or send us a notice in writing, addressed to the Data Protection Manager at Frontline Call Center, LLC, 9 Hope Lane, Eastsound WA 98245, USA.

We may access, preserve, and disclose your Personal Data, other account information, and content, including after you terminate usage of the Service, if we believe doing so is required or appropriate to: comply with our legal obligations, resolve disputes, respond to your requests, or protect yours’, ours’ or others’ rights, property, or safety.

If you wish to terminate your community log-in, contact us at fccweb@FrontlineCallCenter.com.

 

INFORMATION CONFIDENTIALITY AND SECURITY

By using the Service or providing Personal Data to us, you agree that we may communicate with you electronically regarding your request. If we learn of a security system’s breach, we may attempt to notify you electronically by sending an email to you.

INTERNATIONAL USERS

Frontline Call Center, LLC. is a United States company and processes Personal Data on servers in the United States of America.  If you are visiting from the European Union or other regions with laws governing data collection and use, please note that by using our Site, making an enquiry, availing yourself of any Service or otherwise providing us with Personal Data you will be exporting Personal Data outside of the EEA to the United States.

Our Terms of Use incorporate the EU Standard Contractual Clauses prepared for transfers from data controllers to data processors, or data controllers to data controllers (depending on these circumstances of the transfer) which is a specific contract approved by the European Commission which give personal data the same protection it has in Europe (“Model Clause Agreement”). The template text is available in various languages at this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Where we are responsible for transferring your Personal Data out of the EEA (and where we are required to do so under Applicable Data Protection Law) we will ensure a similar degree of protection is afforded to it by ensuring at least one of the safeguards specified under applicable European data protection law is implemented, which may include that:

RETENTION OF DATA

In all cases, your Personal Data will be stored by Frontline Call Center for as long as necessary in order to fulfill the purposes set out in this Privacy Policy and to comply with minimum retention periods under applicable law.  The criteria used to determine the period of storage of personal data is the respective statutory retention period.  After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.

IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS-YOUR CALIFORNIA PRIVACY RIGHTS

Frontline Call Center does not share your Personal Data with third parties for their direct marketing purposes, as defined by California Civil Code Section 1798.83, unless we give you choice (opt-in or opt-out) before sharing with those third parties.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please contact us at Frontline Call Center, LLC, c/o General Counsel, 9 Hope Lane, Eastsound, WA 98245. You must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. Please note that we will not accept inquiries via the telephone, email, or by facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.

THIRD PARTY SITES

Please be aware that other websites that may be accessed through the Service may collect Personal Data about you. Please note that the privacy policies of these sites may differ from those of Frontline Call Center. Frontline Call Center is not responsible for the privacy policies and practices of any linked website. This Privacy Policy does not cover the information practices of those third-party websites linked to our site. We encourage you to read the privacy statement of any website you may visit.

Parts of the Service may include social media features, such as the Facebook Like button, and widgets, such as the Google Maps button or interactive mini-programs that run on the Service. These features may collect your IP address and which page you are visiting on our Site and may set a cookie to enable the feature to function properly. These features and widgets are either hosted by a third party or hosted directly on the Service. Your interactions with these features are governed by the privacy policy of the company providing it.

CHILDREN’S PRIVACY

Our Service is not intended for or directed to persons under the age of 18 and we do not knowingly collect, maintain, or use Personal Data from children under 18 years of age.  Any person who provides their information to Frontline Call Center through the account login page for new customers or any other part of the Service represents to Frontline Call Center that they are 18 years of age or older.  If you learn that your child has provided us with Personal Data without your consent, you may alert us at fccweb@frontlinecallcenter.com. If we learn that we have collected any Personal Data from children under 18, we will promptly take steps to delete such information and terminate the child’s account.

CHANGES TO PRIVACY STATEMENT

Frontline Call Center may update this Privacy Policy from time to time. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. When we change this Privacy Policy in a material way, a prominent notice will be posted on our Site along with the updated this Privacy Policy prior to the changes becoming effective. Please check this URL frequently to see the latest version of this this Privacy Policy.

FEEDBACK AND CONTACT FOR FURTHER ENQUIRIES

If you wish to exercise any of your legal rights referred to in this Privacy Policy, or if you have any questions in relation to this Privacy Policy, please contact Frontline Call Center at Data Protection Manager, Frontline Call Center, LLC, 9 Hope Lane, Eastsound, WA 98245 USA or at fccweb@frontlinecallcenter.com.

If you have comments on any part of the Service or ideas on how to improve it, please send email to fccweb@frontlinecallcenter.com. Please note that by doing so, you also grant Frontline Call Center and third parties permission to use and incorporate your ideas or comments into the Service (or third party software or content) without further compensation or approval.

EXISTENCE OF AUTOMATED DECISION MAKING

As a responsible company, we do not use automatic decision-making or profiling.