Privacy Policy

We collect the following categories of personal information.

• Identifiers and contact information: name, title, email address, telephone number, practice name, practice and shipping addresses, account username, and IP address.
• Professional and verification information: National Provider Identifier (NPI), professional license numbers and states, specialty, practice affiliation, and tax identification number. For a sole proprietor, the tax identification number may be a Social Security number.
• Account credentials: login credentials and security information for your account.
• Agreement records: your electronic signature and initials, the date and time, your IP address, and the title and version of each document you accept.
• Commercial information: the Products you order, quantities, prices, shipping details, order history and support history. Payment card and bank details are collected and processed by our payment processor; we do not store full card numbers.
• Order recipient information: for an order shipped to a recipient a provider designates, the recipient’s name, shipping address and telephone number (see Section 2).
• Partner information: for partner accounts, contact details, the providers you introduce, commission and payout records, and the tax information needed to pay you.
• Communications: messages you send through chat, support tickets, email or forms, and any feedback.
• Internet and device activity: browser and device type, pages viewed, links clicked, referring pages, dates and times of access, and approximate location derived from IP address, collected through cookies and similar technologies (see Section 5).

Sources. We collect personal information directly from you; automatically when you use the Platform; from the provider who places an order (for order recipient information); from a partner who introduces you to the Platform; from public and third-party sources we use to verify providers, such as the NPPES NPI Registry, state licensing databases and tax identification number verification services; and from our service providers, such as payment and shipping status.

The Platform is not designed to receive health information about any individual, and we ask that you never submit it. When a provider directs us to ship an order to a recipient the provider designates, the provider gives us the recipient’s name, shipping address and telephone number. We use that information only to fulfill, ship, track and support the order and to support any product withdrawal or recall. We share it only with our warehousing, logistics and shipping providers for those purposes. We keep it only as long as needed for those purposes and to meet our legal and recordkeeping obligations, and we never sell it or use it for marketing. Partners do not see it. If we need a document from a provider to respond to a claim or governmental inquiry, we request it from the provider and use it only for that purpose. Providers may not enter any other information about a recipient, or health information about any individual, through the Platform, including its chat, support and ticketing tools, order notes, forms or file uploads. When we become aware that we have received information about an individual that this Section does not permit, we will delete, redact or de-identify it and will not use it for any other purpose. Our systems may do this automatically before the information is stored.

We use personal information to:

• create and manage accounts, and verify each provider’s identity, licenses and eligibility;
• process, fulfill, ship and support orders, and calculate and collect applicable taxes;
• administer the partner program, including commission calculation and payment;
• record and evidence the agreements you accept;
• respond to questions and support requests;
• send account, order, security and legal notices;
• send business marketing communications, which you may opt out of at any time;
• carry out product withdrawals, recalls and stop-use notices, and respond to product complaints and safety reports;
• protect the Platform and our users, and detect and prevent fraud, diversion, security incidents and misuse;
• comply with law, respond to lawful requests from governmental authorities, and establish, exercise or defend legal claims; and
• maintain and improve the Platform, including through aggregated or de-identified analytics.

We do not use personal information to make decisions that produce legal or similarly significant effects about consumers based solely on automated processing, and we do not use personal information to train large language models.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising. We disclose personal information only as follows:

• Service providers and processors that act on our behalf under written contracts that limit their use of the information, such as hosting and cloud storage, electronic signature, payment processing, warehousing and logistics, verification, customer support, email delivery and analytics providers.
• Partners. If a partner introduced you to the Platform, that partner may see limited account and order information needed to administer the partner program. Partners do not see information about order recipients.
• Affiliates. Companies under common control with Frontier, such as Frontier Biomed Tech IP LLC, for the purposes described in this Policy.
• Legal and safety. Governmental and regulatory authorities, courts and others when we believe disclosure is required by law or legal process, or is necessary to protect the rights, property or safety of Frontier, our users or others, including in connection with product recalls or regulatory inquiries.
• Business transfers. A buyer, successor or other party in connection with a merger, financing, acquisition, reorganization or sale of all or part of our business, subject to this Policy.
• With your consent or at your direction.

We use cookies and similar technologies that are strictly necessary to operate the Platform, such as for login, security and remembering your preferences, and analytics technologies, provided by service providers acting on our behalf, to understand how the Platform is used. We do not use advertising cookies or allow third parties to collect information about your online activities on the Platform for targeted advertising across other websites. You can control cookies through your browser settings; blocking strictly necessary cookies may prevent parts of the Platform from working. Because we do not sell or share personal information for targeted advertising, we treat a Global Privacy Control signal as a request to opt out of any such sale or sharing. Some browsers offer a “Do Not Track” setting; because there is no common standard for responding to it, the Platform does not respond to Do Not Track signals.

We keep each category of personal information only as long as reasonably necessary for the purposes described in this Policy, using these criteria: account, verification and partner information for as long as the account is active and for up to seven (7) years after it closes; agreement records, order and commercial information, and tax and payout records for at least seven (7) years after the transaction or agreement, to meet tax, accounting, product-traceability and legal requirements; order recipient information for as long as needed to fulfill, support and trace the order and to meet those requirements; communications for up to three (3) years after the issue is resolved; and internet and device activity for up to twenty-six (26) months. We may keep information longer when needed to resolve disputes, enforce our agreements or comply with a legal hold. When we no longer need information, we delete it or de-identify it.

We use administrative, technical and physical safeguards designed to protect personal information, including encryption in transit, access controls and logging. No system is completely secure, and we cannot guarantee the security of information. Please keep your login credentials confidential and tell us promptly at legal@frontierbiomed.com if you believe your account has been compromised.

You can review and update your account information in the portal or by contacting us. You can opt out of marketing emails at any time through the unsubscribe link in any marketing email; we will still send account, order, security and legal notices.

Depending on where you live, you may have the following rights under state privacy law, including the laws of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, and other states with similar laws as they take effect:

• Access and portability: to confirm whether we process your personal information and to obtain a copy of it, in a portable format where required.
• Correction: to correct inaccurate personal information.
• Deletion: to delete personal information we collected from or about you.
• Opt out: to opt out of the sale of personal information, sharing for cross-context behavioral or targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not engage in these activities.
• Sensitive information: to limit or consent to the use of sensitive personal information. We use sensitive personal information only as needed to provide the Platform, verify eligibility, process payments and taxes, secure accounts and comply with law, and not to infer characteristics about you.
• Third-party list: where state law provides it, to obtain a list of the categories of third parties, or the specific third parties, to which we have disclosed personal information.
• Non-discrimination: to exercise these rights without discriminatory treatment.

How to submit a request. Email legal@frontierbiomed.com with the subject line “Privacy Request,” tell us which right you are exercising and your state of residence. We will verify your request by matching information you provide with information in our records and, for account holders, by confirming through your account email. An authorized agent may submit a request on your behalf with your signed permission, and we may ask you to verify your identity directly. We will respond within forty-five (45) days, or within the time required by applicable law, and may extend that period as the law allows. Some rights are subject to exceptions under applicable law, including for information we must keep to complete transactions, meet legal obligations or defend legal claims, and some rights may not apply to information collected in a business or professional context.

Appeals. If we decline to take action on your request, you may appeal by replying to our decision or emailing legal@frontierbiomed.com with the subject line “Privacy Appeal.” We will respond to your appeal within the time required by law. If you are not satisfied with the result, you may contact your state attorney general.

This Section supplements this Policy for California residents and serves as our notice at collection under the California Consumer Privacy Act (CCPA).

Categories, sources, purposes and recipients. In the preceding twelve (12) months, we collected the following categories of personal information, as described in the CCPA, from the sources in Section 1, for the purposes in Section 3: identifiers; customer records information under California Civil Code section 1798.80(e); commercial information; professional or employment-related information; internet or other electronic network activity information; approximate geolocation; and sensitive personal information (account login credentials and, for sole proprietors, a Social Security number used as a tax identification number). We disclosed each of these categories for a business purpose to the categories of recipients in Section 4. We keep each category for the periods in Section 6.

No sale or sharing. We do not sell or share personal information, as those terms are defined in the CCPA, and we have not done so in the preceding twelve (12) months. We do not have actual knowledge that we sell or share personal information of consumers under sixteen (16) years of age.

Sensitive personal information. We use and disclose sensitive personal information only for the purposes permitted by the CCPA regulations, and not to infer characteristics about you.

De-identified information. Where we de-identify information, we maintain and use it in de-identified form and do not attempt to re-identify it, except as permitted by law.

Shine the Light. We do not disclose personal information to third parties for their own direct marketing purposes.

Accessibility. This Policy is available in an accessible format on request to legal@frontierbiomed.com.

We do not sell covered information as defined in Nevada Revised Statutes Chapter 603A. Nevada residents may submit a request directed to the sale of covered information to legal@frontierbiomed.com.

The Platform is for licensed professionals and businesses. It is not directed to children, and we do not knowingly collect personal information from children under thirteen (13), or from anyone under eighteen (18) through account registration. If we learn that we have collected personal information from a child under thirteen (13), we will delete it. If you believe a child has provided us with personal information, contact us at legal@frontierbiomed.com.

The Platform is intended for use in the United States, and information is stored and processed in the United States.

We may update this Policy from time to time. We will post the updated Policy on the Platform with a new effective date, and if we make material changes, we will notify account holders by email or through the Platform before the changes take effect.