frntlne Privacy Policy

When you use the frntlne Platform (“Platform”) you can trust us with your information. This Privacy Policy is to be read in conjunction with our standard Terms and Conditions (“T&Cs”) and helps you understand what information we collect, why we collect it, and what we do with it. This page describes how the privacy of your personal information is respected in a variety of common interactions with the Company.

At frntlne we take privacy seriously:

• We aim to be transparent by providing you a privacy policy which is an important part of fair processing and use of the Platform.
• We aim to be fair, open and honest about who we are and what we are going to do with any of your personal data we collect.
• We aim for the information we provide to you about the processing of your personal data to be concise, transparent, easy to understand and easily accessible as stipulated below.

frntlne has additionally described three kinds of data information that we collect including:

1. Personal Data

frntlne is GDPR compliant and respects the rules of Privacy as outlined: https://gdpr.eu/

Wherever possible frnlne will inform you of how your personal data will be used, and storied. We will also provide you with the ability to remove any data provided to us in full compliance with GDPR standards: https://gdpr.eu/

2. Education Data

frntlne is a micro education and certification platform that delivers education modules to retail staff which they’re financially remunerated for upon completion. The Education Materials, surveys, results and credential information is considered Education Data for the purpose of our Privacy Policy.

3. Commercial Data

frntlne shares its results from its Education Programs with brands and this information is considered commercial data for the purposes of this Privacy Policy.

Data sharing
Extracted analytics are shared with our retail and brand partners. This includes the following metrics

1. Uptake rate of course
2. Financial payout as a result of uptake
3. Aggregated test results
4. Aggregated timestamped user activity
5. Aggregated qualitative category results

frntlne (“The Company”) values your Privacy.

We will ensure that your Privacy is respected in accordance with the GDPR standards which came into force 25 May 2018. Including:

  • Right to be informed: frntlne will always tell you what data is being collected, how it’s being used, how long it will be kept and whether it will be shared with any third parties.

  • Right of access: frntlne acknowledges that you have the right to request a copy of the information that we hold.

  • Right of rectification: frntlne will ensure that you have the right to correct data that is inaccurate or incomplete.

  • Right to be forgotten: frntlne will ensure that on request we will erase any personal data that is stored on you.

  • Right of portability: On request frntlne will ensure they transfer any data that it holds on them to another company.

  • Right to restrict processing: individuals can request PictotryTale limits the way it uses its personal data.

  • Right to object: individuals have the right to challenge certain types of processing, such as direct marketing if frntlne requests it.

  • Rights related to automated decision making including profiling: individuals can ask organisations frntlne to provide a copy of its automated processing activities if they believe the data is being processed unlawfully. You are reminded you are free to exercise these rights.

The information you provide us or the information we provide you may contain personal information that identifies personnel and individuals, and maintains the same high level of protection in this respect also. When you use the frntlne Platform your personal data is used by the Company only to the degree in which you consent for us to use it.

Your personal data is primarily used to provide you with the frntlne products and services you have agreed to be party of namely the frntlne Platform. It may also be used to comply with legal obligations we are subject to or to fulfill our legitimate interests, such as to personalise your experience, develop and improve our services or to detect illegal activities. You consent to brands sendin you offers and promotions through frntlne.

You have a number of rights including the right to request access to, change, or remove your personal data, or to change your marketing preferences (including withdrawing your consent at any time).

Our Data Protection Officer can be contacted by emailing: dataprotection@frntlne AS.
You have a right to lodge a complaint with your local Data Protection Supervisory Authority or with the EU Information Commissioner’s Office.

The Company will not use or disclose personal information about an individual for a purpose other than in the Terms and Conditions with its Customers available on our website. Personal information means information that identifies you as an individual, or from which your identity can be reasonably ascertained.

Information you Provide Us
The Company works hard to ensure the security of your information. Once it comes into its possession, reasonable steps will be taken to protect and secure this information.

When you send information to us containing personnel Information this will be used strictly for the purposes outlined in our Terms and Conditions. Your information will never be used for purposes it was not intended by you. This consent will be specified, and informed with
an unambiguous indication of the data that you agree to be processed. This data will be agreed to upon processing’ (Article 4(11) of the GDPR).

This complies with international regulations that apply to the use of ‘personal data’ which is also defined as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable’ (s6(1) of the Privacy Act’) to which this Privacy Policy complies.

Please note in all circumstances frntlne will ensure that information in relation to your privacy will be concise, transparent, intelligible and easily accessible, and use clear and plain language consistent with Articles 13 and 14 of the GDPR.

Using this Site, Products and Services
We will only accept personal information with your consent.

From time to time we link to other websites. These websites are responsible for their own privacy practices, and you should check those websites for more information about how they will handle your personal information.For further information on how the Company values surrounding data protection please contact us on info@frntlne.com.

Anonymity and Data
The Company will to the best of its ability ensure the anonymity of data, location and personal use of the platform including geo specific locations is not stored.

Our Customer Database
The Company maintains a database of customer information in order to promote its site and product and service offerings. This is used for email, printed mail as well for Direct Marketing purposes. The Company will provide you with information about our products and services that we think will interest you.

The information we keep about you
You have a right to request access to or correction of your personal information held by us. If you wish to access, correct or update any personal information we may hold about you, please contact us as set out below. However, we may charge for providing access to this information and we may refuse access where the Act allows us to do so. We will also take reasonable steps to destroy any information or to ensure it is de-identified if the information is no longer needed for any purpose permitted under the GDPR rules: https://gdpr.eu/

Complaints process
If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe that we have not complied with this Privacy Policy or the Act, please contact us as set out below. This includes ensuring compliance with the European Union General Data Protection Regulation (GDPR) that came into effect 25 May 2018.

We will investigate the complaint and determine whether a breach has occurred and what action, if any, to take. When contacting us, please provide as much detail as possible in relation to the query, issue or complaint.

We will take any privacy complaint seriously. We will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days. We request that you cooperate with us during this process and provide us with relevant information we may require.

Storage and security of your personal information
The Company will take reasonable steps to keep any personal information we hold about you secure. However, except to the extent liability cannot be excluded due to the operation of statute, the Company excludes all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.

The following outlines the way in which frntlne protects your personal information:

Data Storage

  • The application is powered by a Google Spreadsheet. It is stored in Google’s infrastructure and its security is managed by Google.

  • All non-video files such as images, certificates, etc. are uploaded in Google Cloud.

  • All videos are displayed via links. As such, they are stored in AWS S3 with public read access, to allow the application to play the video properly. Check here for more details.

Data Encryption

  • Data stored in Google cloud is encrypted, see here for more details.

  • Videos stored in AWS, although having public read access, are also encrypted. See here for more details.

Data Access

  • Data is only accessible by super admins. Only C level executives have this level of clearance.

Application Security

  • The application is built using Glide, powered by Google sheets. Check here to see how security is managed with Glide.

  • Moreover, Glide is audited by 3rd parties to ensure that the Google sheet that powers the application is secure. Check here for the message of the CEO.

Changes to this Privacy Policy
The date of this Privacy Policy is set out below. We may change this Privacy Policy at our discretion. By continuing to use our Site, or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

Under the European Union General Data Protection Regulation (GDPR) frntlne complies with the standards set out here: https://gdpr.eu/

Do you have any specific questions about this Privacy Policy?
Please contact us at privacy@frntlne.com

frntlne
5/39 Bruce Street
Toorak VIC 3142
23 December 2020

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