This privacy policy was last Updated on 5th of May, 2015

Welcome to www.fronto.co, a website operated by NBT America, Inc. (“NBT America”, “We”, “Us”). NBT America provides a mobile application called Fronto (the “App”, and collectively with the Site and all services provided through the Site and App, the “Services”) that allows businesses to deliver contents (“Contents”), ads, coupons, and deals (collectively, “Advertisements”) to a user’s smartphone lockscreen — and compensates users with reward points (“Reward Points”) that can be redeemed for cash, products and services from participating partners and / or making charitable contributions to participating non-profit organizations. We have prepared this Privacy Policy to describe our practices regarding the Personal Information (as defined below) we collect through the Services.

1. User Consent.

By submitting Personal Information through our Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

2. A Note to Users Outside of the United States.

Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information may be less stringent than the laws in your country.

3. Types of Data We Collect

“Personal Information” means information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Information” means data that is not associated with or linked to your Personal Information. Anonymous Information does not, by itself, permit the identification of individual persons. We collect Personal Information and Anonymous Information, as described below through the Services.

a. Information You Provide to Us

- We may collect Personal Information from you, such as your first and last name, profile picture, gender, age, ethnicity, marital status, educational level, interests, hobbies, precise location-based information, e-mail and mailing addresses, phone numbers, contacts, PayPal account information, list of installed mobile applications and passwords when you create an account for our Services (“Fronto Account”), and any other information you directly give us through the Services.
– When you want to redeem your Reward Points, we may collect information about your PayPal account, the products and services you are purchasing with the redeemed Rewards Points and / or the charitable organization to which you are making a donation.
– We collect information about your interactions with the Services including, your engagement with particular Advertisements, the Reward Points you have accumulated through the Services, the products and services you have purchased and/or the charitable organizations to which you have made a donation.
– In connection with an Advertisement intended to create marketing leads for the advertiser, we may allow you to disclose your Personal Information to an advertiser through the Advertisement, but only where it is clear that your Personal Information is being collected by the advertiser.
– When you purchase products through the Services or make a charitable donation, we will collect all information necessary to complete the transaction, including your name and shipping information.
– If the value of the Reward Points you redeem through the Services exceeds the amount under which we are required to report to any taxing authority, we will collect your social security number or other tax identification number.
– We retain information on your behalf, such as files and messages that you store using your Fronto Account.
– If you provide us feedback or contact us via e-mail, we will collect your name and email address, as well as any other content included in the e-mail, in order to send you a reply.
– We may also collect Personal Information, such as at other points in our Services that state that Personal Information is being collected.

b. Information Collected via Technology.

– To make the Services more useful to you, the Services automatically collect information from you, including your browser type, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, user profiles, and/or a date/time stamp for your visit, and, with respect to our mobile phone, the unique device identifier, better known as the Google AD ID.
– We may collect information from third party service providers with your consent, which may include your profile content or other types of personally identifiable information.
– We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site and App. Persistent Cookies can be removed by following Internet browser help file directions.
– If you are accessing the Services through your mobile phone, we may use corresponding technologies used in connection with mobile phones, including the Google AD ID, to record date, time, search and viewing information related to your mobile phone.
– We may use third party analytics services such as Google Analytics or Google Adsense to collect information about how you use and interact with our Site and Services. Such third party analytics services may use cookies to gather information such as the pages you visited, your IP address, a date/time stamp for your visit and which site referred you to the Site.

c. Information Collected from You About Others.

– If you decide to invite a third party to create a Fronto Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. You or the third party may contact us at help@fronto.co to request the removal of this information from our database.

4. Use of Your Personal Information

a. General Use

In general, Personal Information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We may use your Personal Information in the following ways:
– to provide the Services, including the payment of money to you
– to direct certain Advertisements and Contents to you so that you are more likely to see Advertisements and Contents that are relevant to you
– to facilitate the creation of and secure your Fronto Account on our network
– to identify you as a user in our system
– to provide improved administration of our Services
– to notify visitors about updates to our Services
– to share your Personal Information with other organizations to help them contact consumers for marketing purposes
– to improve and customize the quality of experience when you interact with our Services
– to send you a welcome e-mail and to verify ownership of the e-mail address provided when your Fronto Account was created
– to send you administrative e-mail notifications, such as security or support and maintenance advisories
– to respond to your inquiries related to employment opportunities or other requests
– to send offers and promotional materials related to our Services and for other marketing purposes

b. Use of Data Collected via Technology

The Personal Information collected through technological means is used either to respond to requests that you make, or to aid us in serving you better. We may use your Personal Information in the following ways:
– to track user-specific information on what pages users access or visit
– to improve and customize the quality of experience when you interact with our Site, our App, and Services
– to personalize Services, including to direct certain Advertisements and Contents to you so that you are more likely to see Advertisements and Contents that are relevant to you.

c. Creation of Anonymous Information

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Information to analyze request and usage patterns so that we may enhance the content of our Services and improve Site/App navigation. Company reserves the right to use Anonymous Information for any purpose and disclose Anonymous Information to third parties in its sole discretion.

5. Disclosure of Your Personal Information

We disclose your Personal Information as described below and as described elsewhere in this Privacy Policy.

a. Third Party Service Providers

We may share your Personal Information with third party service providers to: provide you with the Services that we offer you through our Site and our App; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Information other than to provide the services requested by Company.

b. Affiliates and Acquisitions

We may share some or all of your Personal Information with our ad agencies, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy

c. Social Networking Sites

The Services may automatically post, only with your consent, information on your Facebook wall and Twitter feed based on your most recent activities (e.g., you used a coupon to purchase tickets to the newest blockbuster movie). See the section entitled Our Relationship with Social Networking Sites for more information.

d. As Part of the Services

To make the Services more engaging, we have created a Leaderboard that provides visitors to the Site and users of the Services information about the individuals who have accumulated the most Reward Points during certain periods of time. We may display your user name, picture and Reward Point accumulations in connection with the Leaderboard. You may be able to opt-out of such disclosure through the Services or by making a request at contact@fronto.com. We Do Not Share Personal Information With Advertisers. We do, however, allow advertisers to request that their advertisements are directed at certain users (e.g., users in a certain geographic location, or age, gender and / or with certain interests). In the event that you interact with a certain Advertisement, the advertiser (or the company with which the advertiser works, for example, its ad agency or an advertising network) may determine certain characteristics about you

e. Other Disclosures

Regardless of any choices you make regarding your Personal Information, the Company may disclose Personal Information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of the Company or users of the Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use.

6. Third Party Websites and Applications

When you click on a link or swipe left to connect to any other website or location, you will leave our Services and go to another site and another entity may collect Personal Information or Anonymous Information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links or swipe left to connect to such outside websites

7. Our Relationship with Third Party Services

We offer you interfaces that allow you to connect with third party services and social networking services such as Facebook and Twitter (collectively, “SNS”) through our Services. We will work with the SNS’s application protocol interface (better known as their developer API) in a way that allows you to authorize us to access your account on that SNS on your behalf. In order to provide this authorization, you will not provide us with your user name or password to the SNS, but you will need to log-in to that SNS directly through our Site. Once authorized by you, the SNS will provide us a token that allows the SNS to recognize us when we ask, on your behalf, for access to your account information or to post information. You will be able to revoke our access to any SNS Site at any time by amending the appropriate settings from within your account settings on the applicable SNS, though such revocation may limit the Services we are able to provide you. In addition, when you engage in certain activities within the Services, those activities may be automatically posted to your Facebook and Twitter feeds. We allow you to disable this functionality at any time by logging into your profile and selecting the option to disable this feature.

8. Your Choices Regarding Your Personal Information

a. Choices

We offer you choices regarding the collection, use, and sharing of your Personal Information: We will periodically send you free newsletters and e-mails that promote the use of our Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive, by terminating your Fronto Account or by contacting us directly (please see contact information below). We do not collect personally identifiable profile information unless consumers are notified and given an opportunity to opt out at the time and place that the personally identifiable information is collected.

We allow personally identifiable information to be combined with previously collected non-identifiable information with the consumer’s prior affirmative consent. Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

b. Changes to Personal Information

You may change any of your Personal Information in your Fronto Account by editing your profile within your Fronto Account or by sending an e-mail to us at the e-mail address set forth below. You may request deletion of your Personal Information by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Additionally, it is important to note that system recorded personal information is not editable. When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud prevention or similar purposes

9. Security of Your Personal Information.

Company is committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. We also require you to enter a password to access your Fronto Account information require you to enter that same password again in order to access sensitive information, including credit card information. Please do not disclose your Fronto Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Information, Company cannot guarantee its absolute security.

10. Contact Information.

Company welcomes your comments or questions regarding this Privacy Policy.
Please e-mail us at help@fronto.co or contact us at the following address:
NBT America, Inc.
415 Jackson St. STE B
San Francisco, CA 94111

Changes to This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or prominently posting notice of the changes on our Services. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate your Fronto Account with us. Continued use of our Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.