Privacy Policy

At OnFrontiers, we take your privacy seriously and employ information protection controls in keeping with industry standards to safeguard your Personal Information. This Privacy Policy describes how we collect Personal Information from and about you when you visit our website (onfrontiers.com) or use our software applications and technology (collectively, the “OnFrontiers Platform”). This policy also describes how we make use of your Personal Information, as well as your rights related to it. As used in this policy, “Personal Information” means information that can be used to directly or indirectly identify you.

By visiting any part of the OnFrontiers website (www.onfrontiers.com) , or registering as an Authorized User or Expert on the OnFrontiers Platform, you agree to the terms of this Privacy Policy as they may be amended from time to time. As we update our website and services over time, this Privacy Policy may change, so please check for updates.

Depending upon your jurisdiction of residence, you may have additional rights in relation to your Personal Information pursuant to applicable law.

If you have a privacy question or concern, please reach out to us at hello@onfrontiers.com. We are happy to help.

1. The Terms of this Privacy Policy are a Binding Legal Agreement between You and OnFrontiers

1.1 Your use of or registration on the OnFrontiers Platform constitutes your agreement to be legally bound by the terms and conditions of this Privacy Policy. Please read this Privacy Policy carefully and, if you do not agree to any of the terms, do not use or proceed with registration on the OnFrontiers Platform. By using or registering for any part of the OnFrontiers Platform, you become a “Platform User”.

1.2 We may change this Privacy Policy in the future, for example, to stay up to date with changing data protection laws. If we do change the policy, we will do our best to contact you to let you know, but please also check back at onfrontiers.com/privacy-policy from time to time for updates. If you do not agree with any change in terms, you must immediately discontinue use of the OnFrontiers Platform and promptly notify us by emailing hello@onfrontiers.com.

2. What Information Does OnFrontiers Collect From or About You, and How?

2.1 OnFrontiers collects Personal Information about you when you or your employer voluntarily provides it to us. We may also collect or verify information about you from publicly available resources, such as LinkedIn.

2.2 When you register to use the Platform (or your employer does this for you), we collect and store your name, email address, and the password that you create, and use these for the purpose of your Platform User credentials.  

2.3 If you create an Expert Profile about yourself on the Platform or your employer creates an Employee Profile, Consultant Profile or Alumni Profile about you (each of these profiles are referred to in this policy as a “Professional Profile”), we collect and store details of your professional knowledge, skills, and experience.  

In particular, we collect and store information such as the names and locations of  businesses and organizations that you work or have worked for, what positions you have held and when, professional projects and business development efforts that you have participated in, special skills or licenses you may possess which are relevant to professional engagement, your current general location and professional availability, and a photo. We may also collect and store information to facilitate you providing or using services through the OnFrontiers Platform, such as information related to your communication preferences, and so on. We also collect and store any changes or updates to information about you that you may provide or of which we otherwise become aware, from time to time.

2.4 If you or your employer creates a Professional Profile about you we will collect Personal Information contained in your LinkedIn profile and other publicly available resources to confirm and update information contained in your Professional Profile on an ongoing basis. This helps ensure that your Professional Profile is always complete and accurate, so that you are matched with as many professional opportunities as possible.

2.5 If you or your employer creates a Professional Profile about you, your employer may provide OnFrontiers and we will store additional information related to your professional knowledge, skills and experience. Details of how a particular Profile creator may have collected information about you can be obtained by contacting that Profile creator directly. You can request contact details of anyone who has created a Professional Profile about you by emailing OnFrontiers at hello@onfrontiers.com.  

2.6 OnFrontiers additionally collects information from you arising from your use of the OnFrontiers Platform. For example, we collect any information that you provide in the process of your performing or receiving services through the OnFrontiers Platform, and any message exchanges leading up to or resulting from such services.

2.7 OnFrontiers may gather anonymous and technical information related to your use of the Platform, such as computer browser type, Internet protocol address, cookie information, pages visited, and average time spent. This information is used to improve user experience, such as to alert you to software compatibility issues, to fulfill your requests for services, or analyze and improve our technology’s design and functionality.

2.8 The technology supporting the OnFrontiers Platform may use “cookies” to maintain information about your usage of the OnFrontiers Platform. A cookie is a small piece of data that is sent by OnFrontiers to your Internet browser and stored on your computer’s hard drive, and that delivers information to us about your activity on the OnFrontiers Platform. If you do not want information collected through the use of cookies, there is a setting that you may select in most web browsers that allows you to decline the use of cookies. Cookies are used to remember passwords and user preferences, and help us better understand how you use the OnFrontiers Platform, so that we can continue to improve it. OnFrontiers’ Cookie Policy is available at onfrontiers.com/cookie-policy.

3. How Does OnFrontiers Use Information That We Collect From or About You?

3.1 OnFrontiers will only use information that we collect from or about you (a) to enable you to perform or receive services through the OnFrontiers Platform; (b) as a reasonably necessary to identify particular knowledge that you may possess and to connect you to consulting and employment opportunities related to such knowledge; (c) to operate or improve the OnFrontiers Platform, including the Marketplace and Knowledge Networks; and (d) for legitimate internal business purposes or to secure and defend the legal rights of OnFrontiers For example, as relevant, information may be used:

• to provide and maintain Platform services
• to Match employees and consultants with Customers
• to support employees and consultants providing services, and Customers receiving services, through the OnFrontiers Platform
• to bill Customers or process a payment
• to customize content that you see through the OnFrontiers Platform
• to send Platform Users important information regarding OnFrontiers services, such as changes to Platform availability, or our policies and agreements
• to inform Platform Users of opportunities of a type in which they have expressed interest
• to monitor the usage of our services
• to detect, prevent, and address technical issues
• to provide fraud detection and prevention
• for our internal business purposes, such as data analysis, audits, identifying usage trends and determining the effectiveness of promotional campaigns
• to meet legal requirements, such as complying with court orders, discovery requests, and other valid legal mechanisms, or to prosecute or defend a lawsuit
• to fulfill other legal, accounting, and security obligations related to operating our business
• to provide support and improve the OnFrontiers Platform

3.2 Consultation sessions and message exchanges while using the Platform are recorded, transcripted, and preserved by OnFrontiers, and used for quality control purposes, such as to verify that all Platforms Users abide by applicable OnFrontiers policies.

3.3 If you are an independent contractor who is matched with a Customer on the OnFrontiers Platform and subsequently provides services for such Customer off-Platform, personal data that is collected from or about you by the Customer in connection with such Off-Platform engagement may be subject to the terms and conditions of the Customer’s own privacy policy. Please inquire with the relevant Customer to learn more. You can request contact details of any Customer by emailing OnFrontiers at hello@onfrontiers.com.  

4. With Whom Does OnFrontiers Share Your Personal Information?

4.1 We share your personal information with your consent, and to complete any transaction or provide any service you have authorized.

4.2 If you create a Professional Profile about yourself on the Platform, we share that Professional Profile with Customers who may wish to consult with you. If your employer creates a Professional Profile about you, or you create a Professional Profile about yourself at your employer’s request, your personal information is made available on the Platform to such individuals as your Employer may authorize.

4.3 Recordings and transcriptions of consultation sessions and messages exchanged while using the Platform are shared with the Customer, and may be used by the Customer for internal purposes, in accordance with the terms of Customer’s Customer agreement with OnFrontiers.

4.4 OnFrontiers shares your Personal Information with certain trusted third-parties who help us operate the OnFrontiers Platform and conduct our business. Such third-parties are contractually required to treat your information confidentially and to process it in a secure manner.  A list of third-party service providers that OnFrontiers uses to provide services on the OnFrontiers Platform is available at onfrontiers.com/sub-processors.

4.5 In a prospective business transaction, OnFrontiers may disclose Personal Information where OnFrontiers has entered into an agreement that restricts use and disclosure of that information solely for purposes related to the transaction, protects the data by security safeguards appropriate to the sensitivity of the Personal Information, and if the transaction does not proceed, the data is returned to OnFrontiers or destroyed within a reasonable time.

4.6 OnFrontiers will never sell your Personal Information or disclose or transfer your Personal Information to third parties, other than as described in this policy or otherwise expressly permitted by you, except: (a) in the good-faith belief that access, use, preservation or disclosure of such information is reasonably necessary to comply with any applicable law, regulation, legal process, or court or government request, or to enforce OnFrontiers’s rights pursuant to the terms of agreements between us and policies by which you have agreed to be bound; (b) to detect, prevent, or otherwise address fraud, security, or similar issues; and (c) to a buyer or transferee of all or a portion of OnFrontiers’s business or its assets, in conjunction with the sale or transfer of such business or assets; however, we will seek to notify you before Personal Information becomes subject to a different privacy policy.

4.6 When OnFrontiers collects information about you that does not personally identify you, we may share that data with third parties at any time. For example, we may share certain aggregated, anonymous, non-personal information, such as the number of experts in our OnFrontiers Platform who possess expertise or experience in a particular subject area. Such information does not identify you or any user of the OnFrontiers Platform individually.

5. Data Security; Notice of Breach of Security

5.1 OnFrontiers utilizes reasonable and appropriate technical, physical, organizational, and contractual measures to safeguard the Personal Information that OnFrontiers collects from or about you against loss, misuse, theft and unauthorized access, disclosure, alteration, and destruction. However, no technology or practice can guarantee that data is 100% secure and OnFrontiers does not guarantee that information collected from or about you is or will be completely secure from misappropriation by hackers or from other dishonest or criminal activities of third parties, or in the event of a failure of computer hardware, software, or a telecommunications network. Unless otherwise agreed in a written agreement between OnFrontiers and the applicable party, OnFrontiers is not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law.

5.2 OnFrontiers works hard to maintain the security of your information. However, if we ever do experience a security breach that materially affects you, we will notify you without undue delay, and will also let you know what information about you we believe was affected, when we believe the breach occurred, and what steps we took or are taking to respond to the breach. We will notify any relevant regulatory bodies within 72 hours of a breach.

6. Data Accuracy and Retention

6.1 We do our best to keep data we maintain about you accurate and up to date, to the extent you provide us updates or we otherwise become aware of any inaccuracy.

6.2 OnFrontiers will retain information collected from or about you only for the period reasonably necessary to fulfill the purposes of your participation in the OnFrontiers Platform and other permitted uses outlined in this Privacy Policy, unless a longer retention period is required by applicable law.

7. Your Rights Related to Data Collected about You

7.1 You have choices when it comes to the data you share. You can exercise your rights by contacting OnFrontiers at hello@onfrontiers.com or using the tools we provide on the OnFrontiers Platform. Sometimes, your ability to access or control data about you will be limited as required or permitted by applicable law.

7.2 You have the right to review, modify, and correct any Personal Information that we collect from or about you, and to have the information deleted altogether. You also have the right to restrict how we use or disclose your Personal Information, and to receive a copy of Personal Data we have collected about you, in a structured, commonly used, and machine-readable format.

7.3 If you ever wish to review your personal information, or to have your personal information updated, changed, deleted, or sent elsewhere, you may do so by contacting us at hello@onfrontiers.com. We will respond to your request within 30 days. In some cases, however, we may limit or deny your request if the law permits or requires us to do so, if it infringes on the privacy of other individuals or internal procedures, if we find the request to be unfounded or excessive, or if we are unable to verify your identity. If the volume or complexity of your request requires internal processing at OnFrontiers beyond 30 days, we will inform you within 30 days of the reasons for the extension and may charge a reasonable fee to cover administrative costs.

7.4 OnFrontiers commits to resolve complaints about your privacy and our collection or use of your personal information. If you have any questions or concerns regarding our collection or use of your data, please contact us at hello@onfrontiers.com.

8.Third Party Websites and Applications

8.1 This Privacy Policy does not govern the information collection or privacy practices of any party other than OnFrontiers. If the OnFrontiers Platform links or refers you to a third-party website or mobile application, please consult the privacy policy of such third-party to understand how your personal information and other data will be treated.

9. Notice Regarding Knowledge Networks

9.1 If you are an employee or independent consultant who participates in a Knowledge Network on the OnFrontiers Platform, the Customer that maintains that Knowledge Network has access to, and can process, use, copy, modify, and control any Personal Information about you that exists within such Knowledge Network. OnFrontiers’ processing of Personal Information that exists within a Knowledge Network is governed by the terms of a contract between OnFrontiers and the Customer.

9.2 If you are an employee or independent consultant who  participates in a Knowledge Network, the Customer that maintains that Knowledge Network may make use of your Personal Information other than on the OnFrontiers Platform. In such cases, Personal Information that is collected from or about you using the OnFrontiers Platform may be subject to the terms and conditions of the Customer’s own privacy policy in connection with such Off-Platform use. Please inquire with the relevant Customer to learn more. You can request contact details of any Customer who maintains a Professional Profile about you by emailing OnFrontiers at hello@onfrontiers.com.  

10. We Operate in the United States

10.1 Our servers and offices are located in the United States, so your information will be processed and stored in the United States. If you are not located in the United States, this means that your information will be transferred outside your own country of domicile.

10.2 If you are located outside the United States, by accessing or using any part of the OnFrontiers Platform, you consent your Personal Data being transferred to, as well as processed and stored in, the United States by OnFrontiers and the third parties with which we share your data, as described in this Privacy Policy.

11.Children’s Privacy

11.1 OnFrontiers does not knowingly collect or maintain personal information from persons under 18 years of age, and no part of the OnFrontiers Platform is directed to persons under 18. If you are under 18 years of age, you are not authorized to use or access the OnFrontiers Platform at any time or in any manner. Parents have the right to review personal information collected from their child and also the right to have such information, or any portion of it, deleted. To exercise these rights, or to request deletion of a child’s personal information or account, contact us at hello@onfrontiers.com.

12. Important Notice to Residents of the European Union and United Kingdom

12.1 Your Personal Information will be collected, transferred to and stored by OnFrontiers in the United States, and may be shared with OnFrontiers Customers internationally. As a result, your Personal Information may be processed in a country that is not subject to an adequacy decision by the relevant EU or UK authority, and which may not provide for the same level of data protection as the EEA or United Kingdom. In this event, OnFrontiers will seek to ensure an adequate level of protection, for example by entering into standard contractual clauses for the transfer of data as approved by the European Commission or UK Information Commissioner’s Office, as the case may be, or we will ask you for your prior consent to such international data transfers.

12.2 OnFrontiers commits to resolve complaints about your privacy and our collection, use, and processing of your Personal Information, in accordance with the requirements of the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”) and the United Kingdom General Data Protection Regulation of 2021 (“UK GDPR”), as applicable.

12.3 Requests, questions, and concerns related to OnFrontiers’ processing of your Personal Information can be sent to hello@onfrontiers.com or to our mailing address at:

OnFrontiers, Inc.

43 West 23rd Street, 6th Floor

New York, NY 10010 USA

Attention: Data Privacy

Link to EU Data Protection Authorities:

https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

Link to UK Information Commissioner’s Office:

https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints/

‍