Effective Date: May 1, 2020
INFORMATION WE COLLECT
We may collect different types of information about you, depending upon how you interact with us. This information may include personal information, financial information, demographic information, log-in information, Device information and information relating to aggregate data. Sometimes we collect combinations of all these types of information. In each case, when using the Frontdoor Applications, it is indicated on the Frontdoor Applications whether any personal or demographic data must be provided for you to access and use the Frontdoor Applications or participate in the contemplated transaction.
Connecting with the Frontdoor Applications and Information Provided by You
When You Register or Otherwise Contact Us. When you provide us with information in connection with a particular activity or otherwise provide your contact information to us, including your email address or telephone number in connection with that activity, you agree that such action establishes a business relationship with us. You expressly consent to receiving communications from Frontdoor through the information you provided to us. You also attest that you have the legal authority over any telephone number you provide to us and can provide us with the authorization to contact you. This means Frontdoor may contact you, in person or by recorded message, by e-mail, telephone or mobile telephone number (including use of automated dialing equipment), text (SMS) message, or any other means of communication that your wireless or other telecommunications device may be capable of receiving.
Financial Information. Financial information is information that you provide to us, including information relating to your investments in Frontdoor, if any, your bank account number, routing number, debit or credit card number and related billing information (collectively, the “Financial Information”). We require such Financial Information in order to provide investment opportunities and process certain transactions that you have requested. By submitting your Financial Information, you consent to our providing your Financial Information to those Authorized Third Party Service Providers as are reasonably necessary to support and process your transactions.
We ask that you do not enter Financial Information into your profile, except in the fields provided for that information.
Facebook. You may be given the option to link your Facebook account so that you can comment on the Frontdoor Applications or take advantage of other features of the Frontdoor Applications. When you comment on the Frontdoor Applications using your Facebook username and password and click “allow” on the Facebook permission authorization screen, we will automatically import all information that you allow to be imported from your Facebook profile based upon your privacy settings at Facebook, such as your location, your interests, etc. (collectively, “Permitted Facebook Profile Content”) and you give us permission to: (a) capture, store, use and display your Permitted Facebook Profile Content, including syncing access to such Permitted Facebook Profile Content when you are not using Frontdoor Applications and (b) share that information with other users. The authentication of your Facebook login credentials is conducted solely through Facebook.
Information Collected Through Technology
In addition to any Personal Information or other information that you choose to submit to us, we and our third-party service providers may use a variety of technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs to track and record certain information. As you use our Frontdoor Applications, your browser and devices communicate with servers operated by us, our business partners and our service providers to coordinate and record the activity and complete the interaction you have requested (“Usage Information”). We collect many different types of information from cookies and other technologies. For example, we may collect information from the devices you use to access our Frontdoor Applications, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. In addition, we collect your IP address or other unique identifier (“Device Identifier”) from your computer (or other device) used to access the Frontdoor Applications (each, a “Device”). A Device Identifier is a number that is automatically assigned to the Device used to access the Frontdoor Applications, and our computers identify your Device by its Device Identifier. We may also collect information about the website you were visiting before you came to our Frontdoor Applications and the website you visit after you leave our Frontdoor Applications, if this information is supplied to us by your browser. We may use this Usage Information for a variety of purposes, including to enhance or otherwise improve the Frontdoor Applications.
The information from cookies and related technology is stored in web server logs and also in web cookies kept on your Device(s), which are then transmitted back to our Site by your Device(s). These servers are operated, and the cookies managed, by us, our business partners or our service providers. For example, when you visit Frontdoor Applications, we and our service providers may place cookies on your Device(s). Cookies allow us to recognize you when you return to a Frontdoor Application and may track and target your interests in order to provide a customized experience. Cookies also help us detect certain kinds of fraud. A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Frontdoor Applications.
Some cookies contain serial numbers that allow us to connect your activity with Frontdoor Applications with other information we store about you in your profile or as related to your interactions with Frontdoor Applications. Some cookies are temporary, whereas others may be configured to last longer. “Session” cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases Session cookies once you exit your browser. “Persistent” cookies are more permanent cookies that are stored on your computers or mobile devices even beyond when you exit your browser. We use Persistent cookies for a number of purposes, such as retrieving certain information you have previously provided. “Flash” cookies, known as local shared objects, are data files placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device to personalize your visit. Our third-party service providers also may use Flash cookies to collect and store information. Flash cookies are different from standard browser cookies because of the amount of, type of, and way data is stored. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. You can choose to have your computer warn you each time a Persistent or Session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. However, cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies, please click https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies on your Device, some features of the Frontdoor Applications may not function properly. For instance, if cookies are disabled, you will not be able to log into the Site and therefore you will experience an anonymous user experience.
Pixel tags and web beacons are tiny graphic images placed on the Frontdoor Applications or in our emails that allow us to determine whether you have performed specific actions. When you access the Frontdoor Applications or open email messages, the pixel tags and web beacons generate a notice of that action to us, or our service providers. These tools allow us to measure response to our communications and improve the Frontdoor Applications and promotions.
We also use embedded scripts which are programming codes designed to collect information about your interactions with the Frontdoor Applications, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Frontdoor Applications and is deactivated or deleted thereafter.
We use HTML5, another form of collection, in our apps for the iPhone or iPad (and any other Apple iOS device). HTML5 is another form of collection, tracking and storage that does not rely on traditional browser cookies. Like Flash cookies, HTML5 cookies can be used to track users across website but are not stored in browsers’ cookie files. To our knowledge there is currently no known way for a user of a mobile device to remove HTML5 tracking and storage.
In many cases, the information we collect using cookies and other tools is used in non-identifiable ways, without any reference to Personal Information. For example, we use information we collect about Frontdoor Application users to optimize certain offerings and understand traffic and usage patterns. In other cases, we associate the information we collect using cookies and related technologies with Personal Information. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
Information You Provide About a Third Party
If you send someone else a communication from the Frontdoor Applications, such as sending an invitation to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. If that person becomes a customer or registers with us, their information will be treated in the same manner as all other customers or registered users. Please be aware that when you use any send-to-a-friend functionality on the Frontdoor Applications, your e-mail address may be included in the communication sent to your friend.
Information We Collect from Third Parties
We acquire information from other trusted sources to update or supplement the information you have provided or that we collected automatically, such as information to validate or update your address or other demographic and lifestyle information. We use this information to help us maintain the accuracy of the information we collect, to target our communications so that we can inform you of products, services and offers that may be of interest to you and for internal business analysis or other business purposes.
Third Party Analytic Technologies
If you wish to exercise choice with respect to collection and use of the data by these third-party tools, you may visit: http://www.aboutads.info/choices/.
Some of the analytic and tracking tools we use are Google Analytics and Google Analytics Advertising. The Google Analytics Advertising features we use may include the following:
- Google Display Network Impression Reporting;
- Google Analytics Demographic and Interest Reporting; and
- Integrated services that require Google Analytics to collect data via advertising cookies and anonymous identifiers.
If you wish to manage your Google accounts, you may visit: https://www.google.com/settings/u/0/ads/authenticated
If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
HOW WE USE AND SHARE YOUR INFORMATION
We use your information (including your Personal Information), subject to applicable laws, for the following purposes:
- to allow you to register and create an account and profile on the Frontdoor Applications (and elsewhere);
- to share your information (including for marketing and other purposes) with our affiliates and subsidiaries, where we consider appropriate;
- to deliver, provide and process payment for a transaction you have requested;
- to enable you to provide us with feedback;
- to administer promotions you enter into such as a contest or sweepstakes;
- to allow your participation in our Communications Services (where available on the Frontdoor Applications);
- to allow your participation in any surveys;
- to prevent transactional fraud and other illegal activity and to protect the rights, property and safety of us, you and others’
- to alert you to changes and updates in our Frontdoor Applications’ policies, or offerings;
- to send you communications (including targeted marketing and promotional offers) that may be of interest to you, such as emails or text messages about Frontdoor and its affiliates and subsidiaries and their products or services;
- to customize, measure and improve products, services, content and advertising, including generating internal reports about the use of our Frontdoor Applications;
- to personalize your overall experience with Frontdoor;
- for testing, research and development;
- to respond to law enforcement requests and as required by applicable law, court order or governmental regulations;
- in connection with a merger, acquisition, divestiture, restructuring, reorganization, dissolution or other transaction involving some or all of our assets that include your information;
- for certain other purposes disclosed at the time you provide your information;
- to provide investor and career related services; and
Transactional Communications. We may send you notices from time to time relating to your investments, account, orders and other transactional matters. These communications may include securities materials, confirmations, invoices or other notifications. You may not opt out of receiving these communications, as they are not promotional in nature. ‘
Authorized Third Party Service Providers. We may use third party service providers (“Authorized Third Party Service Providers”) to help us operate our business and the Frontdoor Applications or administer activities on our behalf. We may share your information with these Authorized Third Party Service Providers.
Electronic and Direct Mail Promotional Offers. Frontdoor and its affiliates and subsidiaries may send you promotional emails and direct mailings regarding special offers about products or services that may be of interest to you. If you do not want to receive emails or direct mail regarding special promotions or offers you may opt-out as provided in the CHOICE AND OPT OUT section below.
Telemarketing. If you have given us your telephone number when making an inquiry or registering with us, we may use the telephone number you provided to reach out to you, including to: (a) follow up on your communication and (b) market to you other products or services. If you would prefer not to receive marketing phone calls from us, you may opt-out as provided in the CHOICE AND OPT OUT section below.
Third Party Tracking and Advertising. We may allow third-party companies to serve ads or collect certain anonymous information when you visit the Frontdoor Applications. These companies may use non-personally identifiable information (i.e., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Frontdoor Applications and other websites in order to provide advertisements about goods and services that may be of interest to you. These companies typically use a cookie or third-party web beacon to collect this information. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept the cookies used to track your activities, you can go to www.networkadvertising.org.
Feedback. All comments, feedback or materials submitted by you to us, including feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (collectively, “Feedback”), shall be received and treated by us on a non-confidential and unrestricted basis. Frontdoor will be free to use, display, perform, distribute, copy, adapt, and promote, in any medium now known or later developed, without compensation to you, the Feedback along with all ideas, concepts, know-how, techniques or methodologies contained in such Feedback, for any purpose whatsoever, including without limitation, developing, offerings incorporating such Feedback. You agree that in submitting Feedback, such Feedback will not violate any right of any third party, including any confidentiality, copyright, trademark, privacy or other personal or intellectual property or proprietary rights, and will not cause injury to any person or entity. You further agree that no Feedback you submit will contain libelous or otherwise unlawful, threatening, abusive or obscene material, or contain viruses, commercial solicitations, or any form of “spam”.
Sale or Transfer of Business or Assets. In the event that we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, personally identifiable information (including all Personal Information) of our customers and visitors to our Frontdoor Applications may be one of the assets sold or merged in connection with that transaction. In addition, information about our customers and registered users may also be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.
ACCESS TO YOUR INFORMATION
CHOICE AND OPT OUT
To opt-out of marketing communications or to request to be added to our Do Not Call List, or our Do Not Mail List, you may use one of these convenient methods:
Electronic Promotional Offers. If you do not want to receive emails regarding special promotions or offers, you may: (a) click the unsubscribe link in the footer of any email or (b) contact our Privacy Coordinator at the address set forth below.
Direct Mail Promotional Offers. If you do not want to receive promotional offers through direct mail, you may contact our Privacy Coordinator at the address set forth below.
Telemarketing. If you do not want to receive marketing phone calls, you may: (a) ask to be placed on our Do Not Call list when you receive a call from us or (b) contact our Privacy Coordinator at the address set forth below.
If you receive marketing communications from Frontdoor or one of its affiliates or subsidiaries you must opt-out individually from each of the brands from which you are receiving brand-specific marketing communications.
Please note that even if you opt out of receiving promotional electronic or direct mail offers, we may continue to send you notifications by email or direct mail that are related to non-promotional communications.
IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Security. We maintain physical, electronic and procedural safeguards to protect the confidentiality and security of information transmitted to us. To guard your information delivered to us electronically, the Frontdoor Applications use Secure Sockets Layer (SSL). SSL encrypts your credit card number, name and address so only we are able to decode your information. Unfortunately, however, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your information, to the extent permitted by law, we do not guarantee or warrant the security of any information you transmit to or from the Frontdoor Applications, and you do so at your own risk. We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.
Children’s Privacy. The Frontdoor Applications are generally intended for general adult audiences and are not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Frontdoor Applications. If we later obtain actual knowledge that a user who has provided Personal Information is under 13 years of age, we will take steps to remove that user’s Personal Information from our systems.
Office of the General Counsel
Attn: Privacy Coordinator
150 Peabody Place, Suite 300
Memphis, TN 38103