ONFRONTIERS PRIVACY POLICY

Last updated: Dec 7th, 2022

At OnFrontiers, your privacy is important to us.  This Privacy Policy describes how we collect data from and about you in connection with your use of the OnFrontiers website or app (collectively, the “OnFrontiers Platform”), including information that can be used to directly or indirectly identify you (“Personal Information”). This policy also describes how we, and certain third parties, may make use of that data, and your rights related to it. 

By registering as a Customer or Expert on the OnFrontiers Platform, you may participate in or make use of one or more Collections of experts. “Collections” include the OnFrontiers Marketplace and Knowledge Networks, together with Associated Services. “Associated Services” include, among other things, communications, recording, and transcription tools. The terms of this Privacy Policy apply to your use of and participation in OnFrontiers Collections, as well as Associated Services. As described below, certain terms apply to all expert Collections, while others apply exclusively to certain Collections but not others.

If you have a privacy concern, complaint or question, please reach out to us at hello@onfrontiers.com. If you reside in the EU, you may additionally have the right to lodge a privacy complaint with a Supervisory Authority pursuant to the terms of the European General Data Protection Regulation (“GDPR”) (Reg 2016/679).

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 www.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 Is That Information Collected?

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.

2.2 When you register to use the OnFrontiers Platform, you create a personal profile, and/or authorize the delivery to OnFrontiers of all or part of a personal profile previously created by or about you. We collect and store your name, email address, phone number, and the password that you create at the time of registration with the OnFrontiers Platform, as well as other information that you provide or authorize. For example, if you register as an Expert on the Platform, we may also collect and store your business’ or organization’s name, address, phone number, and information regarding your employment history and professional expertise and experience. We may also collect and store additional information relevant to you providing or using services through the OnFrontiers Platform, such as information related to your interests, professional experience, communication preferences, billing location, and so on, as well as a photo. We also collect and store any changes or updates to information about you, of which you may notify us from time to time.

2.3 If you are registered as an Expert on the OnFrontiers Platform, we will collect Personal Information contained in your LinkedIn profile and other publicly available resources to confirm and update information contained in your OnFrontiers Expert Profile(s) on an ongoing basis.

2.4 Some Platform Users may choose to share only their name and contact information, for the purpose of receiving occasional communications from OnFrontiers about information that may be of interest to the Platform User.  In such cases, we collect and store the information shared by the Platform User and use it exclusively for this purpose.

2.5 If you are an Expert who chooses to participate in a Knowledge Network, OnFrontiers may collect additional information about you which OnFrontiers is provided by the Knowledge Networkl’s Curator. Details of how a particular Curator may have collected information about you can be obtained by contacting that Curator directly. You can request contact details of any Curator by emailing OnFrontiers at hello@onfrontiers.com.   

2.6 OnFrontiers may additionally collect information from you related to your use of the OnFrontiers Platform. For example, we may 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. Your consultation sessions and message exchanges may be recorded and preserved by OnFrontiers for quality control purposes and for possible future internal use by OnFrontiers. Your consultation sessions and message exchanges may also be used by the Customer in accordance with the terms of your employment with Customer.

2.7 OnFrontiers may collect certain information about you automatically. In particular, the technology supporting the OnFrontiers Platform may use “cookies” and other technology to collect 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.

2.8 OnFrontiers may use device identifiers, metadata or other data collection techniques to collect data about your use of the OnFrontiers Platform. Collection of usage data, such as traffic and usage trends, allows us to understand how the OnFrontiers Platform is commonly used and improve the OnFrontiers Platform to better serve users. We combine this data with that of other users of the OnFrontiers Platform, so that it cannot reasonably be used to identify you individually.  

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 operate or improve the OnFrontiers Platform including, as relevant, the Marketplace and Knowledge Networks; (b) as a reasonably necessary to evaluate Experts for and connect them to consulting and employment opportunities, and Opportunity Calls, by or on behalf of OnFrontiers or another Curator; (c) to enable Experts to perform and Consumers to receive services through the OnFrontiers Platform; and (d) for legitimate internal business purposes or to secure and defend the legal rights of OnFrontiers or another Curator. For example, as relevant, information may be used:

• to Match Experts with Consumers
• to support Experts providing services through the OnFrontiers Platform 
• to bill Consumers or process a payment 
• to customize content that Experts or Consumers see through the OnFrontiers Platform
• to send Platform Users important information regarding OnFrontiers, such as changes to our agreements, policies or other terms of the agreement between us and such users
• to inform Platform Users of opportunities that we believe may be of interest to you
• 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
• for other legitimate purposes.

3.2 IMPORTANT: IF YOU ARE AN EXPERT WHO CHOOSES TO PARTICIPATE IN A KNOWLEDGE NETWORK, THE NETWORK CURATOR MAY MAKE USE OF YOUR PERSONAL DATA OTHER THAN ON THE ONFRONTIERS PLATFORM. In such cases, personal data that is collected from or about you using the OnFrontiers Platform may be subject to the terms and conditions of the Curator’s own privacy policy in connection with such  Off-Platform use. Please inquire with the relevant Curator to learn more. You can request contact details of any Curator by emailing OnFrontiers at hello@onfrontiers.com.   

4. With Whom Does OnFrontiers Share Your Personal Information and Other 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 have created an Expert Profile about yourself on the Platform, we share your personal information with Customers who may wish to consult with you. If your employer has created an Expert Profile about you, your personal information is made available to your Employer on the Platform.

4.3 OnFrontiers uses certain trusted third parties to 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.

4.4 Other than for the purposes described in this Privacy Policy, OnFrontiers will not disclose or transfer your Personal Information to third parties, 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. 

4.5 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 technical, organizational, and contractual measures to safeguard the Personal Information and other data that OnFrontiers collects from or about you. 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.

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. 

6. Data Accuracy and Retention

6.1 We do our best to keep the 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 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 and modify any Personal Information that we collect from or about you, and to have the information deleted altogether. You also have the right to restrict what uses we make of 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.

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.

1. 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, or if through the OnFrontiers Platform you are engaged to perform services off the OnFrontiers Platform on behalf of a third party, please consult the privacy policy of such third-party to understand how your personal information and other data will be treated.

1. Notice Regarding Knowledge Networks

9.1 If you are an expert who chooses to participate in a Knowledge Network on the OnFrontiers Platform, the Curator has access to, and can control and administer, your personal data, and OnFrontiers’ processing of your personal data in connection with the Collection may be governed by a contract between OnFrontiers and the Collection’s Curator. In such case, OnFrontiers will process your data to provide certain services to the Curator and you, and for OnFrontiers’ legitimate business purposes.

9.2 If you chose to participate in a Knowledge Network, the Collection’s Curator may make use of your personal data other than on the OnFrontiers Platform. In such cases, personal data that is collected from or about you using the OnFrontiers Platform may be subject to the terms and conditions of the Curator’s own privacy policy in connection with such use Off-Platform use. Please inquire with the relevant Curator to learn more. You can request the contact details of any Curator by emailing OnFrontiers at hello@onfrontiers.com.   

1. 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. We will not transfer your data to another country outside the United States (other than the country in which you are located), unless we notify you first. 

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.

1. 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.