This Privacy Policy (“Policy”) describes the privacy practices applicable to Frain Partners LLC (“we, “our” or “us”), including our website at www.frainpartners.com and other sites or applications that are under our control if we post the Policy to the site or application (collectively, “Sites”). The Policy explains how we may collect, use and disclose personal information about individuals. The Policy also explains the rights and choices certain individuals may have regarding their own personal information that is subject to the Policy.

1. INFORMATION WE COLLECT

We collect and receive Personal Information and other information from a variety of sources and in a variety of ways, including those listed below. Personal Information means information relating to an identified or identifiable natural person. Personal Information does not include the information of legal entities. To the extent permitted by applicable law, Personal Information does not include information that has been deidentified, pseudonymized or anonymized or is publicly available.

Registration. When you register to use certain functions and tools on the Sites, or attend a webinar, you will provide information about yourself, including your name, company name and title, email address, telephone number, and general geographic location.

Interactions with the Sites and Us.  When you visit the Sites, you may choose to provide Personal Information and other information, such as your name, company name and title, email address, telephone number and general geographic location. For example, you may provide Personal Information by filling out our online contact form or calling us. You may also provide Personal Information to us in person at events and other locations.

Transactions.  We may collect Personal Information about you when you open accounts and/or make purchases from us on behalf of your company.

Service Providers.  We may collect Personal Information and other information about individuals associated with service providers that we may engage, such as name, postal address, email address, telephone number, company name and title.

Job Applications.  We collect information when you apply for a job with us, including your name, email address, telephone number, and information on your resume.  We may obtain this information from you or third parties, such as a recruiting agency, your references or a background check provider.

Device and Browser Information. When you visit the Sites, we may collect information, such as the type of browser and operating system you are using, the domain name of your Internet service provider, which pages you visit and how long you spend on each page, your geographic location, and the unique number (such as IP address) assigned to your server or Internet connection.

Other Information. We may obtain Personal Information about you from third parties, including entities that direct you to or are accessible via the Sites, and business partners.
You are not obligated to provide us with your Personal Information in all of the cases described above.  However, without your Personal Information, we may not be able to fulfill certain functions. For example, you will not be able to attend a webinar on the Sites or apply for a job with us without providing Personal Information.

2. USES AND PURPOSES OF PERSONAL INFORMATION

We use Personal Information for the purposes described below.

• To create, process, and manage your registrations and accounts with the Sites
• To verify your identity during the registration process
• To respond to your contact form, email or telephone inquiries
• To fulfill your requests made on the Sites and through other interactions with us
• To notify you of administrative information regarding the Sites and your registrations
• To enter into, administer, fulfill and enforce contractual obligations
• To provide marketing materials we believe would be of interest to you, to maintain and update your contact preferences and to add you to our databases for marketing purposes
• To evaluate job applicants
• To develop new products and services
• To improve the functionality, customization, personalization, security, design and/or content of the Sites
• To conduct web analytics, including analyzing usage and patterns on the Sites
• To aggregate and/or deidentify information from you and other users of the Sites
• For compliance purposes and legal obligations, such as validating identity, complying with legal and regulatory requirements, protecting and defending us and our affiliates against legal actions or claims, and preventing fraud

3. DISCLOSURE OF PERSONAL INFORMATIONWe do not sell Personal Information to third parties for their marketing purposes without your consent.Your Personal Information and other information may be shared with third parties as follows:

• Your Personal Information may be shared with third parties that we engage to provide services to us.  We may also provide your Personal Information to third parties that assist with the operation or maintenance of Sites, that provide us with analytic services, and other functions.  These third parties are authorized to use your Personal Information only as necessary to provide the services to us.
• We may share or transfer your information if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, or in preparation for any of these events.
• We may share with third parties information that has been deidentified or anonymized such that the third party cannot personally identify you from the information we share.
• We may disclose your information if we believe that the Sites are being used to commit unlawful acts; if disclosure of your information is required to comply with applicable laws or regulations or with a court or administrative order or will help to enforce any applicable terms of use; to protect your safety or security, including the safety and security of property that belongs to you; or to protect the safety and security of the Sites or third parties.
• We may share your Personal Information with other parties based on your consent.

4. COOKIES AND SIMILAR TECHNOLOGIES.When you visit the Sites, we may place, or authorize third parties to place, a cookie on your computer or device.  Cookies are small files of information that are stored on your computer or device.  Cookies help the Sites operate more efficiently and improve your experience with the Sites by performing functions like allowing the website to recognize you when you return.  We also use cookies for statistical and analytical purposes, such as counting how many unique visitors have accessed the Sites and analyzing usage patterns on the Sites.  You may delete cookies from your computer or set your browser to reject cookies.  However, doing so may limit some functionalities of the Sites.  In addition, blocking or deleting browser cookies may not block other types of cookies.  We may also use other types of tracking technologies, such as web beacons, HTML5 and Flash Local Storage.  The Sites do not respond to “Do Not Track” or other automated signals on browsers.5. YOUR RIGHTS AND CHOICES

• Opt-Out of Marketing.  If you wish to opt-out of receiving marketing solicitations from us, please contact us at the email or postal address listed in Section 11. Even if you opt-out, we may still use and share the information we collect for non-marketing purposes.
• Unsubscribe from Emails. Our marketing emails will include an automated way for you to opt out (unsubscribe) from marketing emails sent by us. To unsubscribe, please follow the instructions in the email you receive.
• European Economic Area Data Subjects.  If you are an individual located in the European Economic Area and the General Data Protection Regulation (“GDPR”) applies to our processing of your Personal Information as a data controller, this section applies to you.
  • Lawfulness of Processing:  We process Personal Information on GDPR lawful bases, including: (1) it is necessary to perform contracts or to take steps prior to entering into a contract, including opening and administering accounts and selling and managing products and services; (2) it is necessary to comply with our legal obligations, including fraud prevention and investigation, enforcing our terms and conditions and regulatory requirements; and (3) it is necessary for the purposes of our and third party legitimate interests, including operating and expanding our business and analyzing, improving and marketing our products and services and the Sites.  In some cases, when another GDPR legal basis does not apply, we may process Personal Information based on your consent.  You may withdraw consent by contacting us at the email or postal address listed in Section 11, but the withdrawal will not affect the lawfulness of processing based on your consent prior to withdrawal.  In addition, you may not be able to access certain features or tools at the Sites following withdrawal of your consent.
  • Data Subject Rights:  You have the following rights to the extent provided by applicable law: (a) request access to your Personal Information; (b) rectify your inaccurate Personal Information; (c) request that we restrict processing or object to the processing of your Personal Information; (d) request the transfer of your Personal Information; and (e) ask us to delete your Personal Information. These rights have important conditions and exemptions, and we reserve the right to deny or limit the response to these requests to the extent permitted by applicable law. In addition, some features or tools at the Sites may not be available to you following the exercise of certain rights. We generally will not charge fees to handle requests; however, if your requests are manifestly unfounded or excessive, we may deny them or charge you a fee. To exercise your rights, please contact us at the email or postal address listed in Section 11.  We will take reasonable steps to verify your identity before responding to any requests, with the level and type of verification depending on the nature of your request and/or the nature of the Personal Information involved in the request.  We may deny or limit the response to requests where we are unable to verify your identity or we suspect fraudulent or malicious activity.  If you are not satisfied with the way we handled your request pursuant to GDPR, you have the right to lodge a complaint with a European Union supervisory authority.
• Notice to California Residents.  If you are an individual and a California resident and the California Consumer Privacy Act of 2018 (“CCPA”) applies to our processing of your Personal Information as a business under the CCPA, this section provides additional information to you. However, if our interaction with you occurred in a business-to-business context, this section does not apply to you as these interactions are exempt under CCPA.  Most of our interactions will occur in the business-to-business context.  If our interaction with you occurred in an employment context, the “CCPA Requests” of this section do not apply to you. If you have a disability and need information on how to access this Policy in an alternative format, please contact us at the email or postal address listed in Section 11.
  • Categories of Personal Information:  We collect the following categories of Personal Information listed in the CCPA, and may have collected any or all of this information in the preceding 12 months: (a) identifiers such as name, postal address, email address, account name, social security number, driver’s license number and passport number; (b) categories described in Cal. Civ. Code § 1798.80(e), such as telephone number, employment, bank, credit card number or other financial information and medical information; (c) characteristics of protected classifications under California or federal law, such as race, national origin, age over 40, disabilities, sex, marital status and military status; (d) commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; (e) biometric information; (f) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory, or similar information; (i) professional or employment-related information; and (j) education information, defined as information that is not publicly available personally identifiable information (as defined in 20 U.S.C. § 1232g, 34 C.F.R. Part 99).
  • Sources and Use of Personal Information.  We collect Personal Information from the sources listed in Section 1. We use Personal Information for the business and commercial purposes listed in Section 2.
  • Disclosure or Sale of Personal Information. We do not sell Personal Information of individual California residents (including Personal Information of minors under 16 years of age) to third parties. We may disclose Personal Information for business purposes and/or to the third parties listed in Section 3.
• CCPA Requests.  You have the right to make the following requests to the extent permitted by law.  These rights have important conditions and exemptions, and we reserve the right to deny or limit the response to these requests to the extent permitted by applicable law.  We generally will not charge fees to handle requests; however, if your requests are manifestly unfounded or excessive, we may deny them or charge you a fee.
  • Right to Know:  You may request that we disclose the following information, applicable to the 12-month period preceding the receipt of your request:  (a) categories of your Personal Information we collected; (b) categories of sources of your Personal Information; (c) business or commercial purposes for collecting your Personal Information; (d) categories of third parties with whom we shared your Personal Information; and (e) specific pieces of your Personal Information we collected.  We are not required to provide this information to the same person more than twice within a 12-month period.
  • Request to Delete: You have the right to request deletion of your Personal Information we collected.
  • Non-Discrimination. We will not discriminate against you for exercising your CCPA rights. Any CCPA-permitted financial incentive we offer will be reasonably related to the value of collecting your Personal Information and you will be provided written terms describing the material terms of the offer.  You may revoke your participation and terminate your account with a program at any time by following the instructions for submitting requests below.
  • Instructions for Submitting Requests. You may submit CCPA requests by emailing or writing to the contact addresses listed in Section 11. We will take reasonable steps to verify your identity before responding to any requests, with the level and type of verification depending on the nature of your request and/or the nature of the Personal Information involved in the request. You may use an authorized agent to submit your request if the agent has your legal power-of-attorney or you provide the agent signed permission, verify your identity with us, and confirm with us that you provided the authorized agent permission to submit the request.  We may deny or limit the response to requests where we are unable to verify your identity or the authorized agent’s authority or we suspect fraudulent or malicious activity. You have the right not to receive discriminatory treatment for exercising your CCPA privacy rights.

6. CROSS-BORDER TRANSFERSAny information that you provide to us, including Personal Information, may be transferred to and/or processed in the U.S.  If you are located outside the U.S., please be advised that the U.S. does not offer safeguards to protect Personal Information that are as stringent as some other jurisdictions in the world.  The European Union does not consider U.S. privacy safeguards to be adequate to protect Personal Information. When we collect Personal Information from outside of the U.S., we rely on lawful mechanisms to transfer and process that information in the U.S. Lawful mechanisms include your consent; the establishment, exercise or defense of legal claims; legal arrangements such as data protection clauses; and the performance of a contract. If we rely solely on your consent, and not another lawful mechanism, you have the right to withdraw your consent by contacting us at the email or postal address listed in Section 11 but the withdrawal will not affect the lawfulness of a transfer based on your consent prior to withdrawal.7. DATA RETENTION

   We will retain your information for as long as necessary to provide any services you request; for as long as you accept marketing communications from us; as necessary for the performance of legal agreements; to comply with legal obligations, including document preservation practices; to resolve disputes; during applicable statutes of limitations; in accordance with our internal document retention policy; and for other legitimate purposes.  If you need additional information regarding our data retention practices, please contact us at the email or postal address listed in Section 11.

   8. SECURITY

   Although we employ technical and organizational controls that we believe are reasonably appropriate to protect your information, we do not guarantee that our security precautions will protect against the loss or misuse of your information. Similarly, we cannot guarantee the privacy of information you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to us.

   9. OTHER WEBSITES AND LINKS

   The Sites may contain links to other websites.  We are not responsible for the information collection or privacy practices of other websites. You should consult the privacy policies of other sites before you visit those sites or provide any information to those sites.

   10. REVISIONS TO THIS POLICY

   We reserve the right to revise this Policy at any time. Please review this Policy periodically for changes and at any time you provide information to us.  We will post any revised versions of the Policy on the Sites.  We will also notify you if we make material changes to the Policy by posting a notice on the Sites or contacting you by other methods.  By continuing to access or use the Sites and our services after changes become effective, you agree to be bound by the terms of the revised Policy.

   11. CONTACTING US

   If you have any questions or concerns regarding this Policy, or wish to exercise any of your rights described in this Policy, please contact us by filling out the Contact Us web form located here: https://frainpartners.com/contact-us/ or write to us at the address below:

   Frain Partners LLC
   PO Box 281
   Princeton Junction, NJ 08550
   Attn: Privacy Policy

   Last Updated: March 1, 2024