Privacy Policy

Privacy Policy

Ducker FSG Holdings LLC (“Ducker FSG”) is committed to maintaining the confidentiality, integrity, and security of personal information about Ducker FSG’s current and prospective customers. Whether through a tablet, mobile device, or other means, by accessing, viewing or using FrontierView TM , Ducker FSG’s websites, digital newsletters, social media, mobile, other products and services, and applications owned and operated by Ducker FSG (collectively referred to as the “Ducker FSG Services”) and also through any non-digital contacts with Ducker FSG, you hereby consent to the collection, use and disclosure of your personally identifiable information under the terms of this Privacy Policy.

 

This Privacy Policy is compliant with the European Union’s General Data Protection Regulation per Regulation (EU) 2016/679 (“GDPR”), the applicable personally identifiable information protection laws of the United States and any other non-GDPR country where Ducker FSG conducts business (together, the “Privacy Laws”). In the event of a conflict between the GDPR and a non-GDPR country’s applicable protection laws, the Privacy Law(s) that provides the greatest level of protection will supersede and control as required under the circumstances. Ducker FSG will review this Privacy Policy periodically in light of changing Privacy Laws, regulatory requirements, business practices and technology. Any changes to this Privacy Policy will be posted with prominent notice at least thirty (30) days prior to the changes taking effect.

 

Although Ducker FSG takes appropriate measures to safeguard your personally identifiable information, Ducker FSG cannot guarantee its absolute security. As such, Ducker FSG recommends that you use complex passwords for your accounts with Ducker FSG and for accounts with third parties that you link to any of your accounts with Ducker FSG to further protect your PII.

 

If you have any questions or would like to review, change, delete your PII, object to the processing of your PII, opt-out from marketing activities, or remove your posts from Ducker FSG owned platforms, in addition to the other communication methods contained in this Privacy Policy, please feel free to contact Ducker FSG via email at info@duckerfrontier.com or in writing at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. Ducker FSG will comply with your request as soon as reasonably practicable.

 

1. Personally Identifiable Information.

When you use or otherwise interact with the Ducker FSG Services, Ducker FSG may gather personally identifiable information (“PII”). PII is information that identifies you as an individual or relates to an identifiable individual. Depending on the type of product or service being used, different kinds of PII can be gathered when using the Ducker FSG Services. PII may include, without limitation, names, postal addresses, email addresses, and telephone numbers. If you disclose any PII relating to other people when using the Ducker FSG Services, you represent that you have the authority to do so and permit Ducker FSG to use the PII in accordance with this Privacy Policy. You should not send or disclose sensitive personally identifiable information through the Ducker FSG Services or otherwise to Ducker FSG including, without limitation, social security numbers, racial or ethnic origin information, political opinions, religious or other beliefs, health information, biometrics or genetic characteristics, criminal background, or trade union membership.

 

2. Collection, Use or Processing of PII.

Ducker FSG may collect, use or otherwise process PII for various reasons including, without limitation, the following: (a) the consent you provide to Ducker FSG at any point of collection; (b) when you register for the Ducker FSG Services, Ducker FSG may collect PII including, without limitation, an email address and password; (c) for billing purposes, Ducker FSG may collect and use your name, address, telephone number, email address, credit or debit card information, or other billing information; (d) to deliver and enable the use of the Ducker FSG Services; (e) during performance of the Ducker FSG Services; (f) to fulfill your requests for additional products and services; (g) to provide functionality; (h) to arrange access to your registered account; (i) to provide you with customer service or technical service; (j) to respond to your inquiries, requests, questions, suggestions, or complaints; (i) to complete your transactions; (k) to send you with information, notices, promotions, or surveys; (l) for the legitimate interests of Ducker FSG, a third party, or yourself if valid reasons exist and measures are taken to protect your privacy rights; (m) to conduct business operations within Ducker FSG; (n) to ensure that Ducker FSG’s networks and information are secure; (o) to prevent fraudulent or criminal activities; or (p) to comply with applicable laws, regulations, and legal processes and obligations. Ducker FSG may provide PII to Ducker FSG’s affiliates for the purposes identified in this Privacy Policy. PII may be collected in your country and subsequently transferred to Ducker FSG’s headquarters in the United States, to another country where Ducker FSG has facilities, or to Ducker FSG’s service providers. The courts, governmental authorities, law enforcement agencies, regulatory agencies or security authorities of such other countries may be entitled to access your PII.

 

3. Analysis of Your Use of the Ducker FSG Services.

Ducker FSG may collect and store information about the computer, mobile device or other devices you use to access the Ducker FSG Services. Such information regarding your use of the Ducker FSG Services may include, without limitation, your device type, internet protocol addresses (the region or general location where your computer or device is accessing the Internet), operating system, unique device identifiers, browser type, browser language, web server logs, the name of your Internet service provider, information on the countries you track, the metrics you view and track, how your metrics are weighted, the number of links you click, the pages visited, the date and time of your visit, the average time of usage, web pages you linked, and any other information about your use of the Ducker FSG Services. Ducker FSG also may combine this information with other information Ducker FSG may collect about you. Ducker FSG may use this information optimize the Ducker FSG Services including, without limitation, to customize features and recommendations, improve design and functionality, and facilitate site navigation.

 

4. Development of New Products and Services.

Ducker FSG may perform statistical, demographic and marketing analyses of a user’s use of the Ducker FSG Services so Ducker FSG may analyze or predict a user’s preferences for product and services development purposes and to determine Ducker FSG’s promotional campaign effectiveness so Ducker FSG can adapt such campaigns to the needs and interests of users. Ducker FSG also may use this information to improve customer relationships, to support strategic business and marketing decisions, and to measure and track Ducker FSG’s brand health. Ducker FSG may engage in these activities to manage Ducker FSG’s contractual relationship with you, to comply with applicable laws, regulations, and legal processes and obligations, or because Ducker FSG has a legitimate interest in doing so.

 

5. Administrative Purposes.

Ducker FSG and Ducker FSG’s service providers use the information Ducker FSG has about you for the following administrative purposes: (a) for auditing purposes, to verify that Ducker FSG’s internal processes function as intended and comply with legal, regulatory and contractual requirements; (b) for fraud and security monitoring purposes including, without limitation, detecting and preventing cyberattacks; or (c) to monitor your satisfaction with the Ducker FSG Services or Ducker FSG’s Customer Service and Information Technology Departments.

 

6. Acquisition, Merger, Sale or Other Disposition.

Ducker FSG may have a legitimate interest in disclosing or transferring PII to a third party in the event of any acquisition, merger, sale, or other disposition of all or any portion of Ducker FSG’s business, assets or stock. Such third parties may include an acquiring entity and its representatives and advisors.

 

7. Sharing PII with Service Providers.

Ducker FSG will not sell, rent, swap or authorize any third party to use your email address, provided, however, that Ducker FSG may contract with service providers to provide services on Ducker FSG’s behalf. These services may be for payment and billing processing, information technology, security services, and other forms of legitimate business. In the course of performing such services, Ducker FSG’s service providers may access PII subject to applicable laws, regulations, and legal processes and obligations.

 

8. Tracking Technologies.

Ducker FSG and its service providers may use cookies, pixel tags, web beacons, scripts and other technologies to track certain information about you or your use of the Ducker FSG Services (together, “Tracking Technologies”). These Tracking Technologies allow the support, operation, and use of the Ducker FSG Services. Access to certain areas of Ducker FSG’s websites, including www.FrontierView.com, may not be allowed if your computer does not accept Tracking Technologies. Some advertisements, promotions, and other marketing tools included in the Ducker FSG Services may be delivered or served by third party providers, which may collect information about your use of the Ducker FSG Services. Ducker FSG does not have access to, nor control over, these service providers’ use of Tracking Technologies or how they may be used. Your access to Ducker FSG’s websites should not be affected if you do not accept Tracking Technologies served by these third parties.

 

9. Non-Personally Identifiable Information Collected.

Other information that does not specifically identify you and is not personally identifiable information may be collected and used by Ducker FSG. Ducker FSG may use and disclose this non-personally identifiable information for any purpose. If Ducker FSG combines non-personally identifiable information with PII, Ducker FSG will treat the combined information as PII.

 

10. Aggregating and/or Anonymizing PII.

Ducker FSG monitors users’ activity and preferences and may compile aggregate data concerning the broad interests represented within its user base. In such cases, Ducker FSG will aggregate and/or anonymize any PII so that it will no longer be PII. Ducker FSG may use and disclose aggregated or anonymize information for any purpose. If Ducker FSG combines aggregated or anonymize information with PII, Ducker FSG will treat the combined information as PII.

 

11. Opt-Out from Marketing Activities.

If, at any time, you prefer not to receive marketing email, telephone, or any other solicitations originated by Ducker FSG and wish to opt-out, please either (a) for marketing email solicitation, please follow the “unsubscribe” instructions located near the bottom of each email or (b) for marketing email, telephone or any other solicitations, please send an “unsubscribe” directive to Ducker FSG at privacy@frontierstrategygroup.com. Ducker FSG also may be reached via mail at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. Please include your account number and phone number in the body of your email or letter, and place “Opt-Out” in the subject line. It is important to note that this opt-out request does not prohibit Ducker FSG from sending you important administrative disclosures for non-marketing purposes. Ducker FSG will comply with your request as soon as reasonably practicable.

 

12. Your California Privacy Rights.

Under the California “Shine The Light” law, California residents may opt-out of Ducker FSG’s disclosure of PII to third parties for direct marketing purposes. If, at any time, you wish to opt-out, please contact Ducker FSG via email at privacy@frontierstrategygroup.com or in writing at Frontier Strategy Group LLC, 1150 18th Street, NW, Suite 350, Washington, DC 20036, Attention: Data Protection Officer. Please include your account number and phone number in the body of your email or letter, and place “Opt-Out” in the subject line. It is important to note that this opt-out request does not prohibit Ducker FSG from sending you important administrative disclosures for non-marketing purposes. Ducker FSG will comply with your request as soon as reasonably practicable.

 

13. Public Activities.

Ducker FSG may offer you opportunities to engage in public activities. Public activities are any actions designed to be visible to other users, including comments, recommendations, reader reviews, ratings and other similar communications whereby any submitted PII may be read, collected and used by others publicly. Ducker FSG is not responsible for your submission of PII during your public activities. Ducker FSG has no responsibility to publish, take down, remove or edit any of your public activities or submissions except if required by applicable laws, regulations, and legal processes and obligations. Any information you disclose during your public activities will be covered by the privacy policy maintained by the receiving party on its platform and not this Privacy Policy.

 

14. PII Retention.

Ducker FSG may retain PII for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable laws, regulations, and legal processes and obligations, or because Ducker FSG has a legitimate interest. The criteria used to determine Ducker FSG’s retention periods include: (a) the length of time Ducker FSG has an ongoing relationship with you and provide the Ducker FSG Services to you; (b) whether there is a legal obligation to which Ducker FSG is subject; or (c) whether retention is advisable in light of Ducker FSG’s legal position.

 

15. Legal and Regulatory Compliance.

Ducker FSG may access, preserve and disclose PII if Ducker FSG is required to do so by law or Ducker FSG has a good faith belief that such action is necessary to (a) comply with applicable laws, regulations, and legal processes and obligations; (b) cooperate with courts, governmental authorities, law enforcement agencies, regulatory agencies or security authorities; (c) protect the personal safety or property of Ducker FSG’s users or the public; or (d) protect and defend Ducker FSG’s rights and property including, without limitation, protecting against any misuse or unauthorized use of the Ducker FSG Services.

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