How we use Administrative Data. We collect and process Administrative Data for our business purposes, which include, for example:
Account Registration. We may use your name, business address, business phone number, and business email address to register an account for you for certain Services we provide (for example, to create an account in our application) and to communicate important information to you. If you set up an account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your personal information.
To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing our Services to your employer, providing support related to our Services, and protecting our Services, including to combat fraud and to protect your information. For example, we collect Usage Information for the purpose of facilitating the proper, efficient, and secure operation of our Services. For example, we may collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services to comply with US trade restrictions. We may also collect IP addresses from users when they log into the Services as part of our log-in and security features. We use Cookies to remember your preferences and navigation through our application to provide you an efficient experience with our application.
Customer Service and Technical Support. We may use your name, business address, business phone number, business email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience.
Communicate with You and Tell You About Other Services. We may use your business contact information to communicate with you about our Services and to give you offers for third party (for example, our Integration Partners) products and services that we think may be of use to you. Please see below under “General Information—Your Rights and Managing Your Privacy” for the choices you have regarding these communications.
To Improve Services and Develop New Services. We use Administrative Data to personalize or customize your experience and the Services, develop new features or services, and to improve the overall quality of FRAXN’s Services.
Feedback. We may use (a) any suggestions that you make to us and (b) information you volunteer in surveys you answer for us, and combine them with feedback and/or answers from other customers, in order to better understand our Services and how we may improve them. Answering any survey is optional.
Research, Including Publishing or Sharing Combined Information from Multiple Customers or Users, But Only in a Way that Would Not Allow the Customer or Any Other Person to be Identified. Only in a way that would not allow a customer or any other identifiable person to be identified, we may prepare and share information about our customers with third parties, such as advertisers or partners, for research, academic, marketing and/or promotional purposes. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow a customer or any other identifiable person to be identified.
How long we retain Administrative Data. We will retain Administrative Data as long as necessary to serve you, to maintain a customer’s account for the entire period during which a customer subscribes to our Services, or as otherwise needed to operate our business. We retain and use Administrative Data as required by applicable law and FRAXN’s records and information management policies to comply with our legal obligations, resolve disputes, enforce our agreements, complete any outstanding transactions, and for the detection and prevention of fraud, as well as to improve our Services, develop new services, and for any other business use, including disclosure to third parties or publicly, provided that we will not publicly disclose information that identifies a customer by name or its employees without the customer’s consent, unless otherwise required by law. We retain Administrative Data until we determine that we no longer need it for the purposes described above. We may retain different types of Administrative Data for different periods. Currently, we retain a record that a customer’s account existed (and related billing and customer relationship management information) and the individuals who are associated with the customer and who have access credentials and other Administrative Data indefinitely.
When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and, unless you have opted out of receiving marketing communications, let you know about products and services that may interest you.
GENERAL INFORMATION
Call Recordings
As noted above, we record calls and video conferences both in the sales and service delivery context. Recordings contain identifiers of individual participants in the call, such as name, as well as audio and, if a participant has their camera on in a video conference, visual information. We use these recordings for training, note-taking, service delivery, process analysis and optimization, recordkeeping (for example, as Business Record information), and research and development. Recordings may be shared with FRAXN personnel who need to access it for these business purposes. We store the recordings in our systems, including those of our vendors that we use to store and analyze the recordings. We retain recordings until the earlier of your request that we delete your information (subject to any limitations provided by applicable law) and our determination that we no longer need your information for the purpose for which we collected it.
How We Disclose Your Personal Information
In the course of providing our Services and operating our business we disclose personal information outside of FRAXN.
Service Providers. We provide or make available information (or service providers collect information on our behalf), including personal information and Usage Data, to service providers who perform various functions to enable us to provide our Services and help us operate our business, including, for example, functions like website design, telephony and system administration, marketing (including website marketing tools), sales (including sales tools), customer support, data enrichment, email communications, communication management, fraud detection and prevention, customer care, data storage, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the personal information we provide to them, only act on our behalf and under our instructions, and/or not use personal information we provide to them for purposes other than the product or service they’re providing to us or on our behalf or as otherwise permitted by applicable law. Use of our service providers’ services may generate data (for example, log data or aggregated usage data) that we do not input into these services and over which we have no control. These types of usage data are subject to the privacy policies of the applicable service provider.
Integration Partners. As noted above, we may access Customer Data that we need to perform our Services through integrations with other vendors who provide back office or financial services (for example, payroll services providers). Accessing data via integrations increases the efficiency of our Services. We develop, or work with these integration partners to develop, these integrations. FRAXN may let customers know about the service or product (by contacting an individual point of contact at a customer or providing reference materials to customers) of an integration partner, or an integration partner may let its customers know about a FRAXN service or product. In some cases, we participate in partner programs with these integration partners and may receive incentives from the partner for providing referrals. It will be clear who is referring the service or product, and who is providing the service or product. If a customer (whether a FRAXN or integration partner customer) chooses to accept an integration partner’s services, after providing consent to either the integration partner or to us, we may exchange information regarding a customer, including personal information about individuals representing the customer (for example, business contact information), as well as information about how the customer or its users interact with each company’s service or product. This exchange of information is necessary to maintain business operations and to provide the ongoing service. By requesting or accepting these products or services, customers and their representatives are permitting us to provide information, including personal information, to the other party. These partners’ activities are subject to their privacy policies and data governance programs.
Promotional Partners. From time to time we present events or content with partners who provide other services of interest to our customers. We may share attendee information with these partners at an attendee’s direction. These partners may contact attendees based on these lists. These partners’ activities are subject to their privacy policies and data governance programs.
Third Party Website Services Providers. We use services of third parties that are not “service providers” (as defined in the California Consumer Privacy Act (CCPA)) on our website. These include ad networks and analytics and marketing services that we use for internet marketing and website analytics purposes.
Response to Subpoenas and Other Legal Requests. We may share information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request. We may also share information with litigants in civil litigation in accordance with our customer agreements and as required by law.
Protection of FRAXN and Others. We may share account information, personal information and Usage Data when we believe it is appropriate to enforce or apply our agreements; or protect the rights, property, or safety of FRAXN, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the practices described in this Privacy Policy.
Affiliates. We may disclose the information you provide or that we collect to our affiliates for service delivery purposes.
Sale of Our Business. If we sell, merge, or transfer any part of our business, we may transfer to the acquirer information in our possession or control, including personal information.
Business Advisors. We may disclose information customers provide to us or that we collect or prepare to professional advisors who are subject to professional or contractual confidentiality requirements such as lawyers, bankers, auditors, brokers, and insurers.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your personal information may be shared with other third parties.
Per Customer Instructions. An authorized representative of a FRAXN customer may from time to time instruct us to disclose information to a third party that includes personal information.
De-identified and Aggregated Data
Once de-identified or aggregated in a way that does not permit reidentification, data is not personal information and we may use it for any purpose and retain it for any period.
International Data Transfers
In accordance with and as permitted by applicable laws and regulations, we reserve the right to transfer your information, process and store it outside your country of residence to locations where we or our third party service providers operate. Our employees and service fulfillment partners personnel are located both inside and outside of the United States. Information that we provide or make available, or that you provide directly, to our service fulfillment partners may, as permitted by law, be transferred outside the United States for purposes of Service fulfillment.
How to Contact Us
If you have questions or comments about this Privacy Policy, please contact us. We welcome your feedback and comments.
Via Email. If you have questions or complaints regarding our Privacy Policy or practices, please contact us by email at privacy@fraxn.com.
Changes to our Privacy Policy
From time to time we may change or update our Privacy Policies. We reserve the right to make changes or updates at any time. More information about how we will notify you is below.
If we make material changes to the way we process your Personal Information, we will provide you notice via our Services or by other communication channels, such as by email or posting on this website. Please review any changes carefully. If you object to any of the changes and no longer wish to use our Services, you may provide a notice of non-renewal in accordance with your agreement with us. All changes are effective immediately upon posting and your use of our Services after a notice of material change or posting of an updated Privacy Policy shall constitute your consent to all changes.
Your Rights and Managing Your Privacy
Updates and Access. You can update information that you have provided to us (for example, in the context of account creation). Contact your account manager to make a request or email privacy{at}fraxn.com. In addition, as required by applicable law (see for example, “California and Virginia Privacy Rights” below), you may contact us to confirm whether we maintain any of your personal information and to review it in order to verify its accuracy. Where you have determined that the personal information we collected about you is inaccurate, you may also request that your personal information be updated or corrected. Subject to applicable law, you may also request that we delete your personal information. Requests for access to your personal information and to have it corrected, amended, or deleted should be sent to privacy{at}fraxn.com. If you believe that one of our customers collects data about you that we are processing, please contact the customer directly.
Managing Marketing Communications From Us. We will honor your choices about receiving marketing communications from us. Please note that even if you choose not to receive marketing communications from us, we will continue to send you required Service or transactional communications.
Cookies and Other Tracking Technologies. You have control over some of the Cookies that we use on our corporate websites. Information on changing your browser settings to opt out of Cookies can be found in your browser settings. For the third party services and re-targeted advertising described in “Information for Prospective Customers—Types of information we collect—Operation of our corporate website” you can opt-out by following the instructions at the links provided. If you opt-out and later delete your Cookies, use a different browser, or buy a new computer, you may need to renew your opt-out choices.
Do Not Track. Like most other companies, our Services and corporate website are not currently configured to respond to browsers’ “Do Not Track” signals.
California and Virginia Privacy Rights
If the California Consumer Privacy Act (CCPA) or the Virginia Consumer Data Protection Act (VCDPA), applies to you (for example, if you are a “consumer” under the CCPA), you have the following rights with respect to personal information that we process in our capacity as a “business” under the CCPA (“controller” under the VCDPA), which includes personal information described in the following sections and subsections:
- “Information for Prospective Customers,”
- “Information for Customers”
- “Business Record Data” (other than any “Customer Data” contained in “Business Record Data”) and
- “Administrative Data” sections of “Information for Customers,”
- “General Information”
- “Call Recordings”
If you submit a verifiable consumer request, you have the right, subject to either the CCPA or VCDPA, if and as applicable:
- To receive disclosure of:
- The categories of personal information that we have collected about you;
- the categories of sources of the personal information we have collected about you;
- the business or commercial purpose for our collecting, selling or sharing of personal information about you;
- the categories of third parties to whom we disclose your personal information (please note that this Privacy Policy provides the information that we would provide upon verifiable request for this data category and the above three data categories);
- the categories of personal information that we have sold or shared;
- the categories of third parties to whom personal information was sold or shared;
- the categories of third parties to whom personal information was disclosed for a business purpose; and
- the specific pieces of personal information that we have collected about you (subject to applicable legal limitations);
- To request deletion of your personal information by us, subject to applicable legal limitations;
- To request correction of inaccurate personal information; and
- To be free of discrimination on the basis of having exercised your rights under the CCPA or VCDPA.
In the last twelve months, we have “sold” or “shared” within the meaning of the CCPA the following categories of personal information to the following categories of third party:
| Category of Personal Information |
Category of Third Party to Whom Disclosed |
| Identifier (cookie or internet protocol address) |
Third party web services providers |
| Internet activity information |
Third party web services providers |
| Geolocation data (to the extent that is determinable from your internet protocol address) |
Third party web services providers |
For disclosures required by CCPA Section 1798.110(c) and Section 1798.115(c)(2), as well as additional information related to our data processing in our capacity as a “business” under the CCPA, please see the tables and sections set forth above in this Privacy Policy.
You have the right to opt out of “sales” or “sharing” within the meaning of the CCPA of your personal information if you are a California resident. You can opt out of our “selling” or “sharing” of your personal information if you are a California resident, or targeted advertising if you are a Virginia resident, by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our webpages. To our knowledge, we have not sold personal information of consumers (as defined in the CCPA) under 16 years of age.
If you have any questions about how we handle your information, the contents of this Policy, how to update your records or how to obtain a copy of the information that we hold about you or exercise your rights under the CCPA or VCDPA, please write to privacy{at}fraxn.com. We will generally verify your identity using information in your inquiry and data in our possession. We may ask you for additional information to verify your request.
