Consumer Privacy Policy and CA Notice at Collection
Last Updated: April 8, 2026
We review and update this Policy at least annually and whenever there are material changes to our data practices or applicable law.
Scope of Applicability
FrankCrum and its affiliated companies (collectively, "Company," "we," "our," or "us") respect your privacy and are committed to protecting your Personal Information through our compliance with this FrankCrum Consumer Privacy Policy and CA Notice at Collection (collectively, the "Policy"). This Policy explains how we collect, use, disclose, retain, protect, and otherwise process Personal Information ("PI") obtained through our websites, online services, applications, and other digital platforms (collectively, the "Site"), as well as through our products, services, and related business interactions, whether conducted online or offline (collectively, the "Services"). This Policy also describes your privacy rights and the choices available to you regarding our handling of your PI. This Policy applies to PI collected when you visit or use our Site; communicate with us by email, text message, or other electronic means; submit information through forms or applications; request information about our products or services; or otherwise interact with us in connection with our business operations.
We have adopted this Policy to demonstrate our commitment to protecting the privacy of individuals who visit or interact with our Site, including current and prospective clients, independent contractors, business partners, and other individuals whose PI we collect during our business activities.
This Policy also incorporates and serves as ourCalifornia Residents: Notice at Collectionand disclosures required under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (herein referred to as “CCPA”).
By accessing or using our Site or using our Services, you acknowledge this Policy and understand the collection and use of information as described herein. This Policy may change from time to time; please see Changes to Our Privacy Policy.
This Policy does not cover information collected from job applicants in connection with their employment applications or candidacy, nor does it apply to data related to FrankCrum Employees or Covered Employees.
Collection of Personal Information and Sensitive Personal Information
Based on your interactions, transactions, and use of our website, we collect - and have collected during the preceding 12 months - the following categories of PI about you. For each category, the chart identifies examples of PI, sources, business purposes, categories of recipients to whom we disclose PI, whether we sell or share PI, and retention criteria. In jurisdictions required by law, we limit our collection, use, disclosure, and retention of PI to what is reasonably necessary and proportionate to business purposes as disclosed in this Policy. The examples provided for each category are not intended to be an exhaustive list or an indication of all specific pieces of information we collect from or about you in each category, but rather the examples are to provide you with a meaningful understanding of the types of information that may be collected within each category.
Categories of Personal Information Collected and Source
Business Purpose
Third parties with whom Personal Information is disclosed, shared, or sold
Retention Criteria
Identifiers. e.g. contact information including first name, last name, alias, postal address, phone number, email address, account name, account ID Social Security number, government identification numbers, unique personal identifier, online identifier, Internet Protocol (“IP”) address.
For general website visitors, this category does not include Social Security numbers, government identification numbers, or account credentials through general website visitor interactions covered by this Policy.
Source: Automatically when you interact with our Site or use our Services, directly from you.
Advertising and Marketing.
Analytics and Insights.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Process, complete, and maintain records on transactions.
Providing and administering products and services.
Risk management and business continuity.
Security, fraud prevention, and identity verification.
Seek and process independent contractor arrangements.
System operations and maintenance.
To facilitate independent contractor relationships.
Verify and respond to consumer requests.
Disclosed:
Advertising, analytics, marketing, tracking, and retargeting providers.
Affiliated entities.
Communication services providers.
Consumer reporting agencies.
Corporate Clients.
CRM Provider.
Data brokers.
Financial institutions.
Government or public agencies.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Social media platforms.
Video content hosts and platforms.
Sold or Shared:
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
We share the data with these third parties for cross-context behavioral advertising.
Retained for so long as necessary to fulfill the purposes stated for this category, for the duration of our relationship, and for any additional period required or permitted by applicable legal, regulatory, contractual, security, fraud prevention, or recordkeeping obligations.
Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) ("California Customer Records"). e.g. name, signature, Social Security number, physical characteristics or description, photograph, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, membership in professional organizations, professional licenses and certifications, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
For general website visitors, this category does not include Social Security numbers, driver's license or state identification card numbers, passport numbers, financial account numbers, medical information, health insurance information, or employment-history information.
Some Personal Information included in this category may overlap with other categories.
Source: Directly from you.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Providing and administering products and services.
Risk management and business continuity.
Security, fraud prevention, and identity verification.
Seek and process independent contractor arrangements.
System operations and maintenance.
To facilitate independent contractor relationships.
Verify and respond to consumer requests.
Disclosed:
Affiliated entities.
Communication service providers.
Consumer reporting agencies.
Corporate Clients.
CRM Provider.
Financial institutions.
Government or public agencies.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Retained for the duration of our relationship and as needed for security, fraud prevention, and recordkeeping.
Protected classification characteristics under California or federal law ("Protected Classes"). e.g. age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, reproductive health decision-making, military and veteran status, or genetic information (including familial genetic information).
Source: None.
Not Collected.
Disclosed:
Not Disclosed.
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Not Applicable.
Commercial Information. e.g. information regarding Services provided, commercial/B2B interest information.
Source: Automatically when you interact with our Site or Services, directly from you.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Disclosed:
Affiliated entities.
Communication service providers.
Corporate Clients.
CRM Provider.
Law enforcement, courts, and attorneys (if required).
Sold or Shared:
Not soldfor monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Retained for the life of the account and for a reasonable period thereafter to comply with security and legal obligations.
Internet or other similar network activity. e.g. date and time of your visit to this website; webpages visited; links clicked on the website; session identifiers; browser ID; browser type and characteristics; device ID and characteristics or attributes; referring URLs; mobile phone make, model and serial number; mobile service provider; operating system; form information downloaded; domain name from which our site was accessed; search history; interaction-level telemetry; cookies; and internet or other electronic network activity information related to usage of Company networks, servers, intranet, or shared drives, as well as Company-owned computers and electronic devices, including system and file access logs, security clearance level, browsing history, search history, and usage history.
Source: Automatically when you interact with our Site.
Advertising and Marketing.
Analytics and Insights.
Business operations and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Risk management and business continuity.
Security, fraud prevention, and identity verification.
System operations and maintenance.
Disclosed:
Advertising, analytics, marketing, tracking, and retargeting providers.
Affiliated entities.
Communication service providers.
Data brokers.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Social Media platforms.
Video content hosts and platforms.
Sold or Shared:
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
We share the data with these third parties for cross-context behavioral advertising.
Retained only as necessary for security (e.g., logs), debugging, and analytics/advertising controls.
Geolocation data. e.g. physical location or movements, such as your zip code, the time and physical location related to use of our internet website or mobile application, or other information about your location or locations you visited. IP addresses are mapped to inferred geographic attributes.
Source: Automatically when you interact with our Site.
Advertising and Marketing.
Analytics and Insights.
Business operations and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Disclosed:
Advertising, analytics, marketing, tracking, and retargeting providers.
Affiliated entities.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Sold or Shared:
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
We share the data with these third parties for cross-context behavioral advertising.
Retained only as needed to provide/measure services and advertising controls, consistent with user preferences and our retention schedule.
Sensory data. e.g. your image when recorded or captured in surveillance camera footage or pictures of you taken on our premises or that you share with us; audio recordings of calls and virtual meetings as disclosed to you at the time of the call.
Source: At our physical locations, Directly from you.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Conduct workplace investigations.
Risk management and business continuity.
Disclosed:
Affiliated entities.
Communication service providers.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Security/call recordings are kept only as necessary for security, quality assurance, investigations, and compliance.
Professional or employment-related information. e.g. current or past job history.
Source: None.
Not Collected.
Disclosed:
Not Disclosed.
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Not Applicable.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) ("FERPA Information"). e.g. education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Source: None.
Not Collected.
Disclosed:
Not Disclosed.
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Not Applicable.
Form and other Electronic Submission Data. e.g. data submitted through the Site through forms and inquiries.
Source: Automatically when you interact with our Site, Directly from you.
Advertising and Marketing.
Analytics and Insights.
Business operations and service delivery.
Verify and respond to consumer requests.
Disclosed:
Advertising, analytics, marketing, tracking, and retargeting providers.
Affiliated entities.
Communication service providers.
CRM Provider.
IT, cybersecurity, and risk vendors.
Sold or Shared:
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
We share the data with these third parties for cross-context behavioral advertising.
Retained to fulfill the inquiries and records management.
Credit/Financing Application Data. e.g. information collected through financing or consumer reports.
For general website visitors, this category does not apply.
Source: Directly from you.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Credit and background reference check on client and officers for account review.
Disclosed:
Affiliated entities.
Communication service providers.
Consumer reporting agencies.
Financial institutions.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Retained as required for credit decisions, audit, and regulatory compliance.
Financial and Payment Information. e.g. billing contact details, payment records, bank account or wire transfer information, credit card or other payment method details (where provided for payment), and other information necessary to process payments for legal services or related expenses including information necessary to process reimbursements, retainers, or client matter expenses.
For general website visitors, this category does not apply.
Source: Directly from you.
Business operations and service delivery.
Communications and service delivery.
Comply with Legal, Regulatory, and Recordkeeping Obligations.
Engage the Services of independent contractors and compensate them for Services.
Disclosed:
Affiliated entities.
Communication service providers.
Financial institutions.
IT, cybersecurity, and risk vendors.
Law enforcement, courts, and attorneys (if required).
Transactional support vendors.
Sold or Shared:
Not sold for monetary or other valuable consideration.
Not shared for cross-context behavioral advertising.
Retained for the life of the account and for a reasonable period thereafter to comply with security and legal obligations.
Inferences drawn from other Personal Information. e.g. website analytics, audience measurement, personalization, marketing effectiveness analysis, and service improvement.
Source: Automatically when you interact with our Site.
Analytics and Insights.
Business operations and service delivery.
Disclosed:
Advertising, analytics, marketing, tracking, and retargeting providers.
Sold or Shared:
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers.
We share the data with these third parties for cross-context behavioral advertising.
Retained to ensure analytics/advertising controls pursuant to our schedule and user choices.
What Sensitive Personal Information We Collect
Of the above categories of PI, the following are categories of Sensitive Personal Information we collect:
Identifiers.
California Customer Records.
Financial and Payment Information.
Credit/Financing Application Data.
Please Note: The Company does not knowingly collect SPI from general website visitors. In certain circumstances, independent contractors and clients may provide SPI, such as government-issued identification numbers, Social Security numbers, financial information, or tax-related information, in connection with onboarding, payment processing, identity verification, or legal compliance requirements.
Personal Information does not include:
Publicly available information from government records.
Information that a business has a reasonable basis to believe is lawfully made available to the public by the consumer or from widely distributed media.
Information made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience.
De-identified or aggregated information.
Sensitive Personal Information Categories
Sensitive Personal Information (“SPI”) is a subtype of PI consisting of the specific information categories listed in the chart below. Importantly, the CCPA only treats this information as SPI when we collect or use it to infer characteristics about a consumer. Of the above categories of PI, the following are categories of SPI we may collect from or about consumers:
Sensitive Personal Information Category
Collected to Infer Characteristics?
Retention Criteria
Government identifiers. e.g. as your Social Security number (SSN), driver's license, state identification card, or passport number
No
N/A
Complete account access credentials. e.g. usernames, account logins, account numbers, or card numbers combined with required access/security code or password.
No
N/A
Precise geolocation. e.g. GPS data from a consumer's mobile device that can provide its location in a geographic area, with an approximate radius of 1,850 feet.
No
N/A
Racial or ethnic origin.
No
N/A
Citizenship or immigration status.
No
N/A
Religious or philosophical beliefs.
No
N/A
Union membership.
No
N/A
Mail, email, or text messages not directed to the Company.
No
N/A
Genetic data.
No
N/A
Neural Data. e.g. information generated by measuring a consumer's central or peripheral nervous system's activity that is not inferred from nonneural information.
No
N/A
Unique identifying biometric information.
No
N/A
Health information.
No
N/A
Sex life or sexual orientation information.
No
N/A
Children's Personal Information (under age 16).
No
N/A
We process SPI only for the limited purposes permitted under CCPA:
To perform the Services reasonably expected by an average Consumer who requests those Services.
To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted PI.
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
To ensure the physical safety of natural persons.
For short-term, transient use.
To perform Services on behalf of Company.
To purposes that do not involve inferring characteristics about consumers.
California Residents: Notice at Collection
Your Rights Under CCPA - If you are a California resident, the CCPA grants you the following rights regarding your PI:
Right to Know and Data Portability Requests. You have the right to request that we disclose certain information to you about our collection and use of your PI (the "right to know"), including the specific pieces of PI we have collected about you (a "data portability request"). Our response will cover the 12-month period preceding the request, although we will honor requests to cover longer periods that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:
The categories of:
Personal Information we collected about you; and
sources from which we collected your PI.
The business or commercial purpose for collecting your PI and, if applicable, selling or sharing your PI.
If applicable, the categories of persons, including third parties, to whom we disclosed your PI, including separate disclosures identifying the categories of your PI that we:
disclosed for a business purpose to each category of persons; and
sold or shared to each category of third parties.
When your right to know submission includes a data portability request, a copy of your PI, subject to any permitted redactions.
Right to Delete and Right to Correct. You have the right to request that we delete any of your PI that we collected from you and retained, subject to certain exceptions and limitations (the "right to delete"). Once we receive your request and confirm your identity, we will delete your PI from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action. You also have the right to request correction of PI we maintain about you that you believe is inaccurate (the "right to correct"). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct PI that our review determines is inaccurate and notify our service providers to take appropriate action.
Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes. You have a right to ask businesses that use or disclose your SPI to limit those actions to just the CCPA's Permitted SPI Purposes listed above (the "right to limit"). As we do not use or disclose SPI beyond the CCPA's Permitted SPI Purposes, we do not currently provide this consumer right.
Personal Information Sales or Sharing Opt-Out and Opt-In Rights. You have the right to request that businesses stop selling or sharing your PI at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal under on our website. Similarly, the CCPA prohibits businesses from selling or sharing the PI of consumers it knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer's parent or guardian for consumers under age 13 (the "right to opt-in").
ADMT Rights. ADMTs are technologies that process PI and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision. We do not currently use ADMT to make significant decisions about consumers, so we do not provide ADMT access, opt-out, or appeal rights.
Right to non-discrimination. You have the right not to be discriminated against or retaliated against for exercising any of your privacy rights under the CCPA.
The right to designate an authorized agent to submit one of the above requests on your behalf. See below how you can designate an authorized agent within Section: Verification Process and Authorized Agents.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please reach out to privacy@frankcrum.com. We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all the PI that we hold about you, or we may have destroyed, deleted, or made your PI anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2022, unless providing a longer timeframe would be impossible or involves disproportionate effort.
For data portability requests, we will select a format to provide your PI that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Notice of Rights of California Residents to Limit the Use of Your Sensitive Personal Information
We do not use or disclose your SPI for purposes that give rise to a right to limit the use and disclosure of your SPI under CCPA. Because we do not use SPI for purposes that trigger the right to limit as defined by CCPA a “Limit the Use of My Sensitive Personal Information” link is not applicable currently. If our practices change, we will provide that link and update this Policy.
Notice of Rights to Opt-out of Profiling, Automated Decision Making, and Targeted Advertising
We sell certain information (not for monetary consideration but for other valuable consideration) to data analytics vendors, behavior analytics vendors, social media platforms, video content hosts and platforms, Ad Trackers, and other marketing, tracking, and retargeting vendors or providers and we share the data with these third parties for cross-context behavioral advertising (as listed above).
We do not engage in profiling for decisions that have legal or similarly significant effects on you as a consumer. We also do not use automated decision-making to make such significant decisions on this Site. Where required by applicable law, consumers may contact us using the request methods described in this Policy to inquire about rights that may apply to their PI. If our practices change, we will update this Policy and provide any required notices, rights, or opt-out mechanisms.
Verification Process and Authorized Agents
If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf.
To do so, you must either:
execute a valid, verifiable, and notarized power of attorney; or
provide other written, signed authorizations that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that you have authorized them to act on your behalf.
Response and Timing for Privacy Requests
We will process privacy requests in accordance with applicable law and within the timeframes required by the laws that apply to your request. We may take steps to verify your identity and authority before fulfilling certain requests, and we may request additional information where necessary to do so.
Where permitted or required by law, we may deny a request in whole or in part, including where an exemption applies or where we are unable to verify the request. If we deny your request, we will explain the basis for the denial to the extent permitted by law.
Where applicable law provides an appeal right, we will describe how to appeal a denial in our response.
Response and Timing on Rights to Opt-Out
In response to your request to opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use PI provided from your request to comply with the request. We will also notify our service providers, contractors, and certain other downstream recipients of your request to opt-out and instruct them to both:
Comply with your request.
Forward the request to their own downstream recipients, if applicable.
We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.
You can confirm that we processed your request to opt-out by going to our website and clicking where we will have a toggle button showing what Cookies are active. However, you may change your mind and opt back in at any time by re-toggling your .
Other California Privacy Rights
The California Civil Code permits California residents with whom we have an established business relationship to request that we provide you with a list of certain categories of PI that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an email toprivacy@frankcrum.com or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.
Additional Categories or Other Purposes
We will not collect additional categories of PI or use the PI we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your PI for a new or unrelated purpose.
Mailing Address: Attn: Privacy Team 100 S. Missouri Ave. Clearwater, FL 33756
Sources of Personal Information
We collect your Personal Information from the following sources:
Automatically through our Site(s) and utilizing Service(s) (e.g. session, security logs, cookies, pixels, analytics, and similar technologies.).
Company systems, networks, software applications, and databases you log into with the Company, including from vendors the Company engages to manage or host such systems, networks, applications or databases.
Directly from you, such as when you complete forms, request information, communicate with us, or otherwise provide information.
Service providers, vendors, third-parties, and business partners, including those that support our operations.
Via physical locations (e.g., call recordings, badge logs, video surveillance).
Publicly available sources.
To Whom We Disclose Personal Information
We disclose PI only to the categories of recipients listed below for business and commercial purposes:
Advertising, analytics, marketing, tracking, and retargeting providers (e.g., Google Analytics).
Affiliated entities.
Business transaction recipients, such as a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets.
Communication service providers that facilitate, manage, and send/receive communications on our behalf via email, text/SMS, phone, or that record, transcribe, summarize, or process phone calls and video meetings.
Consulting and investigation firms (e.g. HR consultants, safety consultants, and workplace investigators).
Consumer reporting agencies and similar data providers (where applicable).
Corporate clients (meaning an entity, as opposed to a natural person, that purchases any of our services).
Government or public agencies (as required by law).
IT, cybersecurity, privacy, risk and other operational vendors that support our systems and services (e.g. internet services providers).
Law enforcement, courts, and attorneys.
Marketing support providers (e.g. Website host).
Social media platforms (e.g., Facebook, LinkedIn).
Transactional support vendors.
We contractually require service providers, contractors, and other recipients that process PI on our behalf to keep it confidential and use it only for the limited purposes for which we disclose it to them, unless otherwise permitted or required by law.
These third parties may use tracking technologies to collect information about you when you use our website. The information they collect may be associated with your PI, or they may collect information, including PI, about your online activities over time and across different Site, apps, platforms, and other online Services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the provider responsible directly.
Reasons Why We Collect, Use, Retain, and Disclose Personal Information
We may collect, use, and disclose your PI for any of the following business and commercial purposes:
Advertising and Marketing. Provide and serve interest based and targeted advertising across desktop, mobile, and Connected Television (CTV) devices. Engage in marketing and sales activities.
Analytics and Insights. To analyze usage trends; perform internal analytics; and understand the demographics and usage patterns of website visitors. Understand and track website usage, improve website performance, analyze trends, and enhance the user experience.
Business Operations and Improvement. To evaluate and improve our overall business operations; manage relationships with vendors, service providers, and contractors supporting recruitment activities; and debug, identify, and repair errors in our systems.
Comply With Legal, Regulatory, and Recordkeeping Obligations. Comply with applicable state and federal labor, employment, tax, benefits, workplace safety, and related laws. Maintain required business, tax, employment, and compliance records and comply with record‑retention requirements. Evaluate, assess, and manage the Company’s business relationships with vendors, service providers, and independent contractors.
Communications and Service Delivery. Respond to inquiries and communicate with you regarding accounts, services, updates, notices, or other operational or service‑related information.
Consumer Requests. Verify, respond to, and retain your selections for privacy‑related opt‑out requests in accordance with applicable privacy laws.
Corporate Transactions. To evaluate or participate in corporate transactions, such as mergers or acquisitions, where Consumer information may be reviewed or disclosed subject to appropriate confidentiality protections.
Provide Support Business Operations and Business Relationships. Evaluate, assess, and manage the Company’s business relationships with vendors, service providers, clients, and independent contractors.
Operate, Maintain, and Improve Company Systems and Website. Facilitate the efficient and secure use of Company information systems. Debug, identify, and repair errors that impair intended website or system functionality.
Security, Fraud Prevention, and Incident Response. Detect, investigate, and respond to security incidents or potentially unauthorized access, use, or disclosure of PI. Protect against malicious, fraudulent, or illegal activity and prosecute those responsible. Prevent identity theft.
Independent Contractors and Business-to-Business Purpose(s). Engage the Services of independent contractors and compensate them for Services.Evaluate, make, and communicate decisions regarding an independent contractor, including decisions to hire and/or terminate. Grant independent contractors’ access to secure Company facilities, systems, networks, computers, and equipment, and maintain information on who accessed such facilities, systems, networks, computers, and equipment, and what they did therein or thereon. Implement, monitor, and manage electronic security measures on independent contractor devices that are used to access Company networks and systems.
Notice of Right to Opt-Out of the Selling and Sharing your Information
Depending on the state where you reside, you may have the right to tell us not to sell or share your PI . You have the full and free right to opt-out of our disclosure of your PI to any third parties where the disclosure constitutes “selling” or “sharing” as defined by specific state laws.
You may exercise your right to opt-out without fear of discrimination for doing so. To opt-out of our selling and sharing of your information, meaning we will not disclose your information to third parties for any monetary or other valuable consideration, you can do any of the following: ClickYour Privacy Choicesto be taken to an online opt-out submission form.
You can use a Global Privacy Controls ("GPC") signal. FrankCrum will process opt-out preferences from GPC signals, which are in formats commonly used and recognized by businesses, such as an HTTP field header, as requests to opt-out of sale or sharing. The GPC signal opt-out will only apply to the browser you are using on your device; it will not apply to other browsers and/or devices to which GPCs are not activated or to offline sales.
If you are unable to submit an opt-out through any of the above methods, please email privacy@frankcrum.com and we will assist in meeting your needs.
You can have an authorized agent submit a request on your behalf. To submit an opt-out through use of an authorized agent, you must provide that agent with written permission signed by you to submit an opt-out on your behalf, except when using an opt-out preference signal.
A request to opt-out need not be a verifiable consumer request. However, we may deny a request to opt-out if we have good faith, reasonable, and documented belief that a request to opt-out is fraudulent. If we deny your request to opt-out, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.
Use of Cookies, Pixels, and Other Tracking Technologies
Our website stores or retrieves information on your browser, mostly in the form of cookies. A cookie is a small piece of data (text file) that a website - when visited by a user - places on the user’s device to remember information about the user, such as the user’s language preference or login information. This type of cookie is set by us and is referred to as a “first-party cookies.” Our website uses first-party cookies primarily to make the website work as you expect it to. For example, we use the information we collect through first-party cookies to allow you to navigate between pages efficiently, analyze how well our website is performing, and understand the content that you spent most of your time reviewing. We use first party cookies for website functionality and measurement, and we use third-party cookies and tracking technologies (such as advertising or analytics pixels) to support interest based and cross context behavioral advertising including advertising platforms, analytics providers, and retargeting partners. We also incorporate cookies and similar technologies, such as pixels, tags, and web beacons, from outside our website’s domain (“third-party cookies”). Third-party cookies gather information to enable our vendors to provide a range of services to us, including targeted advertising and measuring the success of our advertising campaigns.
Cross‑context behavioral advertising means targeted advertising based on PI obtained across businesses, websites, applications, or services with which the consumer interacts. Below is a detailed list of the categories of first and third-party cookies we use on our website. You can prevent the collection of data by non-essential performance, functionality, and marketing cookies by clicking on our which controls the collection of preferences on our website.
We make use of cookies under the following circumstances and for the following reasons:
Provide you with services available through the website and enable you to use some of its features.
Authenticate users and prevent fraudulent use of user accounts.
Identify if users have accepted the use of cookies on the website.
Compile data about website traffic and how users use the website to offer a better website experience.
Understand and save visitor preferences for future visits, such as remembering your login details or language preference, providing you with more personal experience, or avoid having to re-enter your preferences every time you use the website.
Track your browsing habits to enable us to show advertising which is more likely to be of interest to you, including advertising by third parties on our website.
Essential Cookies
Essential cookies are necessary for the website to function properly and cannot be switched off in our systems. They are usually only set in response to a website visitor’s request for services, such as a visitor setting up their privacy preferences, logging in, or filling in forms. You can set up your browser to block or alert you about these cookies, but blocking these cookies will prevent the website from working correctly or might prevent the website from working at all.
Non-Essential Cookies
Non-Essential cookies are not essential to the website functionality but serve some other unique purposes:
"Performance" cookies (sometimes referred to as "analytics" cookies) collect information about how visitors interact with our website. These cookies may collect online identifiers such as IP address or device information, which are used in aggregated or anonymized form to improve website performance, for example:
Pages visited.
Links clicked within the website.
General traffic patterns.
Traffic sources.
"Functional" cookies (sometimes referred to as "preference" cookies) enable enhanced functionality and personalization, such as remembering your preferences and past choices on the website through secure authentication tokens. For example, functional cookies can collect:
"Marketing" cookies (sometimes referred to as "tracking" or "advertising" cookies) can track browsing behavior, content viewed, and interactions to support targeted advertising and cross-context behavioral advertising. This can include:
Links the user follows.
Ads the user clicks.
Browsing behavior across websites.
IP address and device information.
Information on Some of the Cookies in Use on our Site
For information on some of the cookies we use on our site and apps, please review the policies from some of our vendors:
You can control and manage cookies associated with your browser. If you are interested in controlling and managing cookies from your browser including any set by our website, please refer to http://www.allaboutcookies.org/manage-cookies/index.htmlfor information on different ways to configure your browser’s cookie settings.
Opt-out preference signals provide consumers with a simple and easy-to-use method by which to exercise the right to opt-out of the selling and sharing of their information. Global Privacy Controls (“GPC”) or Universal Opt-Out Mechanism (“UOOM”) are user-enabled opt-out preference signals which can communicate a user’s “Do Not Sell or Share” request on behalf of the person or device. We will process opt-out preferences from GPC and UOOM signals which are in formats commonly used and recognized by businesses, such as an HTTP field header. We will treat a consumer’s use of GPCs or UOOMs as a valid request to opt-out of the selling and sharing of information for that browser. We currently do not connect browser use to consumers and, as such, you will need to use GPCs or UOOMs on all browsers in which you access our website and use our opt-out form to opt-out of offline sales.
Do Not Track ("DNT") is a privacy preference that users can set if they do not want web services to collect information about their online activity. We do not respond to DNT signals or other mechanisms (except for GPCs and UOOMs) that provide a choice regarding the collection of PI about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs or UOOMs.
Digital Advertising Alliance
Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (“DAA”) which maintains self-regulatory programs along with websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising visit the DAA’s opt-out portal available at http://optout.aboutads.info/. To opt-out data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering found here: https://youradchoices.com/appchoices.
Non-Participant Opt-Out Options
Some of our vendors do not participate in the DAA self-regulatory program for online behavioral advertising or have developed their own processes for allowing consumers to opt-out: https://branch.app.link/optout.
Some devices and apps do not have access to web-based browser cookie opt-outs. To learn more about the advertising opt-outs provided by your mobile device’s operating system (like iOS and Android) or the device manufacture, click here.
Notice of Right to Opt-Out of Profiling, Automated Decision Making, and Targeted Advertising
Depending on your state of residence, you may have the right to opt out of targeted advertising and selling of your data. You may submit a request to exercise this right by clicking Your Privacy Choices or emailing privacy@frankcrum.com. Please see Section: Automated Decision-making, Profiling, and AI for more details on our Company practices.
U.S. Consumer Privacy Rights
Depending on your state of residency, you may have certain rights related to your PI, including:
Access and Data Portability. You may confirm whether we process your PI and access a copy of the PI we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information, and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your PI that we maintain, considering the information's nature and purpose of processing.
Deletion. You may have the right to request that we delete PI we maintain about you, subject to applicable exceptions, including where retention is required or permitted for compliance or recordkeeping purposes.
Opt-Out of Using Personal Information for Targeted Advertising, Profiling, and Sales. You may request that we do not use your PI for these purposes.
Appeal. Appeal our decision regarding your privacy rights request (where required by law). Unless otherwise required by state law, your appeal rights apply to any denied request, and we will provide a written outcome within the period required by your state of residence. If we deny your request, you may appeal by emailing privacy@frankcrum.comwith the subject line Privacy Rights Appeal.
Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.
Contact Us
To exercise your rights, please submit a verifiable request to us by either:
Mailing Address: Attn: Privacy Team 100 S. Missouri Ave. Clearwater, FL 33756
How We Retain Your Personal Information
We maintain retention schedules aligned with legal, regulatory, tax, and contractual requirements and delete or de‑identify data when no longer needed. We keep the categories of PI described in this Policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Site, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain PI . At the end of the retention period, PI will be deleted, destroyed, or deidentified. We align retention to data minimization and reasonable expectations for each purpose, and we honor opt‑outs for at least 12 months before seeking reauthorization.
Data Minimization
We limit our collection, use, and retention of PI to what is reasonably necessary and proportionate for the purposes described in this Policy.
External Links
Our website contains links to other websites. We are not responsible for the privacy practices or the content of such websites. To help ensure the protection of your privacy, we recommend that you review the Policy of any website you visit via a link from our website. If you access our website through a mobile device, your device or browser may prompt you to grant permission for features such as location, push notifications, or camera access. You can revoke these permissions at any time through your device settings.
Client Passwords
The PI record created within MyFrankCrum can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties.
Automated Decision‑Making, Profiling, and AI
We do not use automated decision‑making systems, including machine learning or AI tools to make decisions that produce legal or similarly significant effects about you. This includes decisions relating to eligibility for, or access to, credit, employment, housing, financial services, essential or federally regulated services, or other outcomes that could meaningfully affect your rights or opportunities. If any automated output could influence how we present content or offer to you on the website, those outputs operate within pre‑defined parameters and are either reviewed or overseen by people or constrained so they do not produce legal or similarly significant effects.
We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. If we ever begin using profiling in a way that implicates additional rights (for example, under the laws of states that provide opt‑out rights for certain profiling), we will update this Policy and provide any required opt‑out mechanisms.
If we materially change how we use automated decision‑making, profiling, or AI—including if future law requires additional disclosures, access, appeal, or opt‑out rights for such processing—we will update this Policy and provide any required tools, disclosures, and instructions at or before the time those changes take effect.
Compliance With Law and Safety
We disclose specific PI and/or SPI based on a good faith belief that such disclosure is necessary to comply with or conform to the law or that such disclosure is necessary to protect our employees or the public.
How We Protect Your Personal Information
We use commercially reasonable administrative, physical, and technical measures designed to protect your PI from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your PI transmitted to, through use, or in connection with the Services. Email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of PI is at your own risk. The safety and security of your information also depend on you. You are responsible for taking steps to protect your PI against unauthorized use, disclosure, and access.
Children's and Minors' Data
We do not knowingly sell or share the PI of consumers under the age of 16. No one under 16 may provide PI to or on the website. We do not knowingly collect PI from children under 16. If you are under 16, do not use or provide any information on this website or through its features, create an account, or provide any information about yourself, including your name, address, telephone number, email address, or any username or screen name. If we learn that we have collected or received PI from a child under 16 without the required consent, we will delete that information. If you believe we might have information from or about a child under 16, please contact us at privacy@frankcrum.com.
International Visitors
Our website is intended only for U.S. audiences; individuals outside the U.S. should not submit PI.
Communications
We may contact you with marketing information that may be of interest to you. You may opt out of receiving any or all these marketing communications from us by following the Your Privacy Choices link or instructions provided in any email we send or by contacting us. Please note that we may still send you transactional, administrative messages, or product updates related to the Service even after you have opted out of receiving marketing communications.
Acknowledgment of this Policy
By accessing or using our Site(s) or using our Service(s), you acknowledge that you have read and understand this Policy.
Changes to Our Privacy Policy
We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. The date the Policy was last updated is identified at the top of the page. We will notify you of changes to this Policy by updating the "last updated" date and posting the updated Policy on the Services. We may email or otherwise communicate reminders about this Policy, but you should check our Services periodically to see the current Policy and any changes we have made to it.
Consumers With Disabilities
This Policy is available in formats accessible to Consumers with disabilities. If you need this Policy in an alternative format, please contact us using the contact information below.
Contact Information
To exercise your rights or ask questions or comment about this Policy or our privacy practices, contact us at: privacy@frankcrum.com or via our toll-free number: 1-800-393-0815, Option 21