Frost Privacy Policy

Last Updated: January 8, 2021

  1. Introduction. Frost Technologies Inc. (referred to as “Frost” or “us” or “we” or "Company") provides Users (as defined below) with access to an online platform known as the Frost Platform, which provides aggregated and analyzed financial advice to guide our Users to trustworthy sources of advice as they make their own investments (the “Platform”). The Platform is accessible to users via the www.ifrost.com website (and all other Frost related websites) (collectively, the “Site”) and may be accessible via one or more Frost mobile or desktop applications (as further defined below, collectively, the "App"). This Privacy Policy (this “Policy”) discloses the privacy practices of Frost, including as related to the Platform, the Site, the App, the Content and other Services from time to time offered by Frost. Frost respects the privacy of its Users, and we created this privacy policy (the "Policy") to explain how we collect, use and disclose your information when you access the Platform, the Site and the App and otherwise use the Services. The Policy is only applicable to our Platform, the Site, the App and our other Services and not to any other website, service or online platform. BY DOWNLOADING, INSTALLING, REGISTERING WITH, ACCESSING OR UTILIZING THE PLATFORM, THE SITE OR THE APP, SUBMITTING ANY INFORMATION OR COMPLETING ANY FORMS VIA THE PLATFORM, THE SITE OR THE APP, OR OTHERWISE UTILIZING ANY OF THE SERVICES, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE LEGALLY BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT WISH TO BE BOUND BY THIS POLICY, PLEASE EXIT AND CEASE ALL USE OF THE PLATFORM, THE SITE, THE APP AND ALL OTHER SERVICES NOW. YOUR AGREEMENT WITH US REGARDING COMPLIANCE WITH THIS PRIVACY POLICY BECOMES EFFECTIVE IMMEDIATELY UPON COMMENCEMENT OF YOUR USE OF THE SERVICES

  2. Definitions. The following terms shall have the following meanings for purposes of this Privacy Policy. Capitalized terms not defined in this Section are defined elsewhere in this Privacy Policy or in the Terms of Use applicable to the Services.

"Affiliate(s)” means Frost’s owners, subsidiaries, affiliated companies, officers, directors, suppliers, partners, sponsors, advertisers and advertising providers, and agents and representatives, and includes (without limitation) all parties involved in creating, producing, and/or delivering the Site, the App, the Content and any of our other Services (including Apple and Google and our Data Providers).

“App” means any software applications (including desktop applications) or mobile applications from time to time made available by Frost for purposes of accessing the Platform and that may be downloaded, installed or made otherwise accessible on a User’s computer or mobile device via the Site, desktop application, the Apple App Store, the Google Play Store, or other similar platforms.

“Content,” means any content, material, information, data, instructions, media, article, post, communications, software, photos, video, graphics, music, sounds, and other material and services that can be viewed or otherwise accessed by Users on or through the Site, App or other Services but excludes User Material. 

"Services" means (i) the Platform, (ii) the Site, (iii) the App, (iv) all Content, (v) any specific service or offering that may be provided by Frost via the Platform, the Site or the App, which may include Premium Features (as defined in our Terms of Use), (vi) any support services and related technologies, software and/or APIs that may be provided by Frost in its sole discretion for facilitating, maintaining and monitoring your use of the foregoing, and (vii) any other services or offerings that Frost may provide from time to time via the Platform.

“User” or “you” or “your” (and similar terms) means any person or entity that visits, views, uses or accesses any portion of the Platform, the Site, the App or any of the other Services. "User" shall include employees or agents of an entity that registers to use any of the Services to the extent such individuals share their personal information with Frost as set forth herein.

“User Material” means the content, material, information (including financial information), data, instructions, media, article, post, communications, software, photos, video, graphics, music, sounds, and other material that a User may import, upload or otherwise provide to the Service in connection with a User’s use of the Service.

  1. Modification of Privacy Policy; Notice of Changes. Frost reserves the right to change this Privacy Policy at any time and for any reason. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to posting the revised Privacy Policy on the Site and/or the App. User acknowledges and agrees that it may be required for User to maintain a valid email address as a registered user and that this is User’s responsibility. It is also User’s responsibility to review the Site and/or the App and this Privacy Policy periodically and to be aware of any modifications. User’s continued use of the Services after such modifications will constitute User’s (i) acknowledgment of the modified Privacy Policy; and (ii) agreement to abide and be bound by the modified Privacy Policy.

  2. Types of Information Collected. In order to better provide Users with access to the Platform and Frost’s other numerous Services, Frost collects two types of information about Users: Personally Identifiable Information and Non-Personally Identifiable Information (collectively referred to as “User Information”). Frost’s primary goals in collecting information from User are to provide User with a smooth, efficient, and customized experience while using the Platform, the Site and the App or any of Frost’s other Services, to provide the Services and to collect information related to the Platform and the other Services.

4.1 Personally Identifiable Information. Personally Identifiable Information refers to information that lets Frost know the specifics of who Users are. When User engages in certain activities on the Site or the App or otherwise related to the Services, such as contacting Frost via the provided forms or sending Frost an email, Frost may ask User to provide certain information about User by filling out and submitting an online form. If User elects to engage in these activities, however, Frost may ask that User provide personal information, such as first and last name, organization name, email address and telephone number.  Depending upon the activity, some of the information Frost asks User to provide is identified as mandatory and some as voluntary. If User does not provide the mandatory information with respect to a particular activity (for example, subscribing to a Premium Feature or purchasing any paid Services), User will not be able to engage in that activity. Users may be required to provide additional personally identifiable information to become a User and to use certain Services. For instance, we require your name, age, phone number, address or zip code, and email address in order to register you with the Platform and provide the Services to you. We (or our service providers) will also collect certain Personally Identifiable Information (e.g., billing address and credit card information) as required to process User payments for the Services in accordance with our Terms of Use. We collect device IDs and IP addresses as well which can provide approximate locations (and in some jurisdictions IP addresses may be considered Personally Identifiable Information depending on what is exactly collected and how it is used). We will collect certain Personally Identifiable Information as required to process User payments for Premium Features and other paid Services in accordance with our Terms of Use. Our Terms of Use may also describe other Personally Identifiable Information that may be required from Users.

4.2 Non-Personally Identifiable Information. Non-Personally Identifiable Information refers to information that does not by itself identify a specific User. Frost gathers certain Non-Personally Identifiable Information about Users based upon their access to and use of the Platform, the Site, the App and/or our other Services, including, but not limited to: traffic data, location data, logs, communication data, the resources that a User accesses and uses on or through the Platform, the Site, the App and/or our other Services, the website's Uniform Resource Locator (“URL”) from which User just came and to which URL User next goes. It can also include including information about your mobile device and internet connection, including the device’s unique device identifier, operating system, browser type, and mobile network information. This information can be compiled and analyzed on both a per-user and an aggregated basis. We may also collect other Non-Personally Identifiable Information. In certain cases we may combine Non-Personally Identifiable Information with Personally Identifiable Information in which case all resulting or connected data will be considered Personally Identifiable Information.

4.3 Information from Third Party Sites. We may collect, store and use certain User Information from third party sites and services that are accessible via or integrated with the Platform, the Site or the App or are contemplated by use of the Services (e.g. Google, Facebook, Apple accounts, etc.), including information that may be transmitted by such third party sites in connection with use of the Services. We may also receive access, store and/or use User Information that is collected by third party service providers and our other vendors related to your use of the Services (e.g. Google Analytics, Stripe, etc.).

5. Collection of User Information. 

5.1 Disclosure of Personally Identifiable Information. Frost generally does not collect any Personally Identifiable Information about a User unless that User voluntarily provides it to Frost or it is related to use of a Service in connection with an integrated third party site or account. User provides certain Personally Identifiable Information to Frost when User (i) submits web forms or provides/imports information through the Platform, the Site or the App, including information provided at the time of registering to use the Platform, the Site or the App; (ii) transmits other information by telephone or email, including Frost’s “contact us” web form; (iii) connects third party accounts or facilitates access by the Platform, the Site or the App to such third party sites; (iv) accesses and/or downloads and installs an App (in each case as applicable); (v) provides information in an App or allows an App to access certain device permissions or settings; (vi) subscribes to certain Premium Features or other paid Services, or (vii) provides it via other methods Frost may request or allow from time to time. Frost may also collect information from a User at other locations on the Platform, the Site or the App that state that such information is being collected. In certain cases, we may collect Personally Identifiable Information related to your use of the Services automatically after you have subscribed to or purchased a Premium Feature or other paid Service (e.g. we may identify Users after purchase of a Premium Feature or paid Service to ensure that payment has been made and User is using the Premium Feature or Service in accordance with its terms).

5.2 Automatic Collection of User Information. In addition, Frost may also automatically collect, including through third party service providers (e.g. Google Analytics), certain User Information, including Personally Identifiable Information. Such User Information may be collected when you use the Services and may not require you to provide or input specific information. Frost may use User Information to diagnose problems with the Services and to improve and market the Services and as otherwise set forth in this Privacy Policy.

5.3 Other Potential Methods for Collecting User Information. Frost, and/or its Affiliates or its service and technology providers may use various other methods to collect Personally and Non-Personally Identifiable Information about Users. These methods may include, but are not limited to (i) cookies - a small text file containing a string of alphanumeric characters placed on User’s computer or mobile device that identifies User’s web browser; (ii) analytics and user tracking technologies that may allow us to monitor what actions Users take on the Site or the App or otherwise with respect to the Services; (iii) log Files – information, which is automatically reported by User’s web browser each time User views a web page, possibly including, but not limited to, User’s IP address, browser type and language, number of clicks, domain names of websites visited, pages viewed, and the order of those pages, the amount of time spent on particular pages, the date and time; (iv) clear gifs - web beacons, which are pieces of data used to track the online usage patterns of Users anonymously, and which may also be used in HTML-based emails sent to Users to track which emails are opened by recipients; (v) third party service-based technologies and information, including, but not limited to, linked services (such as Google Accounts) that User authorizes to share information about User with Frost; (vi) other social media or third party site connects or authorizations to share information’ (vii) other available technologies that may be integrated into the Site or the App or the other Services; and (viii) requests for data or information collected through the Site, the App or the other Services.

6. Use of User Information. Frost will use User Information to:

Frost uses User Information generally in our business operations and activities and for any of our commercial purposes consistent with applicable law. We may also match or combine User Information that You provide with information that we obtain from other sources or that is already in our records, whether collected online or offline or by predecessor or affiliated group companies, for the purposes described above.

If Frost should ever file for bankruptcy or have Frost’s assets sold to or merge with another entity (or otherwise engage in any business combination or similar transaction), information Frost receives from User through use of the Services is Frost’s asset and may be transferred without any restriction.

7. Sharing of User Information. Frost may share and disclose User Information with third parties, including as follows:

8. Updating and Correcting Information. Frost believes Users should have the ability to access and edit the Personally Identifiable Information that you have provided to Frost. Users may contact Frost to determine what Personally Identifiable Information we have on such User by contacting Frost through the appropriate contact information or web forms located on the Platform, the Site and/or the App.

Please include first and last name, address, and email address when contacting Frost.  Frost encourages each User to promptly update their Personally Identifiable Information if it changes. In addition, it may be impossible to completely delete a User’s Personally and Non-Personally Identifiable Information without some residual information because of reasons including, but not limited to, server backups and disaster recovery. User acknowledges that altering, updating or deleting any Personally or Non-Personally Identifiable Information may alter the functioning or operation of the Services for User.

9. User Choices on Collection and Use of Information.

9.1 Email(s). Frost may, from time to time, send User email(s) regarding Frost’s products and services or the Services. If User does not want to receive such mailings, simply contact Frost as set forth in this Privacy Policy or as set forth in such emails. 

9.2 Disabling Cookies. User also has choices with respect to cookies, as described below. By modifying browser preferences, User may have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If User chooses to reject all or some cookies, some parts of Frost’s Services may not work properly in User’s case.

9.3 Opt-Out. At any time, you may opt out of allowing us to use your Personally Identifiable Information by contacting us at the information set forth below in Section 14. We will process your request within a reasonable time. However, please note that in certain instances, we may have already used or shared your Personally Identifiable Information consistent with this Policy prior to your opt out. In addition, you may not be able to use the Services if you opt-out.

10. Security of Information. The importance of security for all Personally and Non-Personally Identifiable Information associated with Frost’s Users is important to Frost. Frost values the privacy and security of User Information and uses reasonable efforts to protect User’s Personally and Non-Personally Identifiable Information so that it is secure.  However, User acknowledges that no data transmission or hosting over the Internet or any wired or wireless network can be guaranteed to be 100% secure and neither can the storage of such data or information. As a result, while Frost strives to protect User’s Personally and Non-Personally Identifiable Information, User acknowledges that (i) there are security and privacy limitations of the Internet and mobile platforms which are beyond Frost’s control; (ii) the security, integrity and privacy of any and all information and data exchanged between User and Frost through the Services and data and information that is stored by Frost cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit or in rest by a third party. AS A RESULT, WITH REGARD TO THE SECURITY AND INTEGRITY OF PERSONALLY AND NON-PERSONALLY IDENTIFIABLE INFORMATION, USER USES THE PLATFORM, THE SITE, THE APP AND ALL OF THE OTHER SERVICES AT USER’S OWN RISK.

11. Additional Information on Cookies and Other Tracking Technologies.

11.1 General Information. When User uses the Site or certain other Services, Frost may store cookies on User’s computer in order to facilitate and customize User’s use of the Site or such Services. . Also, as part of your use of the Services, certain service providers may place a separate cookie or other tracking technologies on your computer (e.g. Google Analytics, Stripe, etc.). A cookie is a small data text file, which a web site stores on User’s computer's hard drive (if User’s Web browser permits) that can later be retrieved to identify User to Frost.  The cookies make User’s use of the Site or other relevant Services easier, make the Site or Services run more smoothly and help Frost to maintain and operate the Site and Services securely, although Frost makes no such guarantees about the operation of the Site or any other Services. User is always free to decline Frost’s cookies and other tracking technologies if User’s browser permits, but some parts of the Site or other Services may not work properly in that case. To learn more about cookies, including how to enable cookies, change your browser settings and find and delete cookies on your hard drive, please refer to your web browser’s help menus or visit www.allaboutcookies.org. By using the Site and other Services, you are deemed to unambiguously agree to its use of any cookies that you do not disable.

11.2 Third Party Cookies. As part of your use of the Services, certain service providers may place a separate cookie on your computer (e.g. Google Analytics, Stripe, etc.).

12. Third Party Providers; Scope.

12.1 Third Party Providers. As described above, we may use third party service providers to facilitate use and operation of the Site and/or the App and for other Services related activities. Your User Information may be provided to and used by such third parties. For example, we use Stripe for payment, analytics, and other business services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Stripe and read its privacy policy at https://stripe.com/privacy.

12.2 Scope of Privacy Policy. This Privacy Policy only addresses the use and disclosure of information Frost collects from Users. Other sites, including but not limited to those of Frost’s Affiliates and other sites available through the Site or the App or any of the other Services, have their own privacy policies and data collection use and disclosure practices. Please consult each site's privacy policy, including, without limitation, those set forth above. To the extent possible, we seek to limit the rights of these parties with respect to your User Information where reasonable, and we do not grant any rights to these organizations to use this information for any marketing or other purpose beyond providing services to us to manage business activities. Subject to the foregoing, Frost is not responsible for the policies or practices of third parties. Frost is not responsible for the policies or practices of third parties. User should contact these advertisers, providers, or other third parties directly if User has any questions about the use of the information that these third parties collect.

13. Do Not Track Disclosures; California Requirements.

13.1 Do Not Track. Do Not Track is a privacy preference that Users can set in their web browsers. When a User turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the User. For information about Do Not Track, visit www.allaboutdnt.org. At this time, Frost does not respond to Do Not Track browser settings or signals. In addition, Frost may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the Site or Services or one of the affiliated pages hosted at the Frost domain. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

13.2 Request of Information for California Users. California Civil Code Section 1798.83 entitles California Users to request information concerning whether a business has disclosed certain information about you to any third parties for the third parties’ direct marketing purposes. California Users who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the “How to Contact Us” section below.

14. Miscellaneous Issues.

14.1 Age Policies. User must be at least 18 years old to have Frost’s permission to use any of the Services. Frost’s policy is that Frost does not knowingly collect, use or disclose any Personally Identifiable Information (or other information) about Users that are under 13 years of age.

14.2 Server Host Country. The Site and the App and our other Services are hosted in the United States. If User is visiting from the European Union (“EU”) or other regions with laws governing data collection and use that may differ from U.S. law please note that User is transferring personal data to the United States which does not have the same data protection laws as the EU, or other nations, and by providing personal data to Frost, User consents to: (i) the use of User’s personal data for the uses identified above in accordance with this Privacy Policy; and (ii) the transfer of User’s personal data to the United States as indicated above. You currently may not use the Services if you are located in the European Union.

14.3 Questions or Concerns About this Privacy Policy. If you have any questions about this Privacy Policy, contact Frost at the contact information set forth below, or through the contact information provided on the Site.

support@ifrost.com

14.4 Terms of Use. Your use of the Services is also subject to, and you agree to, our Terms of Use applicable to the Services. The term “including” as used in this Policy shall mean “including, without limitation,” unless the context otherwise requires.

BY USING THE PLATFORM, USING THE SITE, DOWNLOADING OR INSTALLING THE APP AND/OR SUBMITTING ANY INFORMATION OR COMPLETING ANY FORMS VIA THE SERVICES, OR OTHERWISE ACCESSING OR USING ANY OF OUR OTHER SERVICES, USER AGREES TO BE BOUND BY THIS PRIVACY POLICY. IF USER DOES NOT WISH TO BE BOUND BY THIS PRIVACY POLICY, PLEASE EXIT THE SITE AND/OR THE APP NOW AND CEASE ALL FURTHER USE THEREOF AND OF ALL OTHER SERVICES. USER’S AGREEMENT WITH US REGARDING COMPLIANCE WITH THIS PRIVACY POLICY BECOMES EFFECTIVE IMMEDIATELY UPON COMMENCEMENT OF USER’S VISIT TO THE SITE OR USE OF ANY OF THE SERVICES.