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 Policy

FrankCrum and/or our affiliate companies (“Company,” “we,” “our,” or “us”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”). This Policy describes how we collect, process, retain, sell/share and disclose personal information when you interact with our websites and other online or offline services that link to or reference this Policy or by using our services. It also explains your privacy rights and how to exercise them. This Policy also incorporates our California Residents: Notice at Collection and disclosures required under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA”).

By accessing or using our Site or using our Services, you acknowledge this Policy and agree to the collection and use of information as described herein. This Policy may change from time to time (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 Internal Employees or Worksite Employees.

Please refer to the following policies if needed:

• Employee Privacy Policy and Notice at Collection
• Job Applicant Privacy Policy and Notice at Collection
• Worksite Employee Privacy Policy and Notice at Collection

California Residents: Notice at Collection

Collection of Personal Information and Sensitive Personal Information

Based on your specific transactions and interactions with us or our website, we will or may collect, and we have in the last 12 months collected the following categories of Personal Information about you. For each category of information, the categories of third parties and service providers to whom we have disclosed the information in the last 12 months are referenced below. In jurisdictions where required by law, we limit our collection of Personal Information to what is reasonably necessary and proportionate to provide or maintain the services you have requested or reasonably expect in the context of your relationship with us. 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.

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 Chart

 Sensitive personal information (“SPI”) is a subtype of personal information 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 Personal Information, the following are categories of SPI FrankCrum may collect from or about consumers: 

Categories of Sensitive Personal Information Collected or Processed

We process SPI only for the limited purposes permitted under Civil Code §1798.121(a):

• To perform the Services reasonably expected by an average Consumer who requests those Services.
  
• 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 personal information (the "right to know"), including the specific pieces of personal information 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 personal information.
  • The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
  • If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information 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 personal information, subject to any permitted redactions.
• Right to Delete and Right to Correct. You have the right to request that we delete any of your personal information 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 personal information 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 personal information 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 personal information 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 personal information at any time (the "right to opt-out"), including through a user-enabled opt-out preference signal under Cookie Preferences on our website. Similarly, the CCPA prohibits businesses from selling or sharing the personal information 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 personal information 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.

• To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information.
• 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 FrankCrum.
• To purposes that do not involve inferring characteristics about consumers.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information 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 personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified information about our Worksite Employee for any purpose, without restriction. When we collect, process, or disclose this aggregated or deidentified information, we will maintain and use it in deidentified form and will not attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

California Residents: Your Rights Under CCPA

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

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 under California law, 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.

Do We Sell Your Information?

We do not and will not sell or share your Personal Information in exchange for monetary consideration. However, we may sell or share some of your information to third parties for other valuable consideration, as noted in the table above.

We may sell or share your Personal Information for the following business or commercial purposes:

• Marketing Purposes
• Data Analytics Purposes

Other than these exceptions, we do not and will not disclose your Personal Information to any third party in exchange for monetary or other valuable consideration or share your Personal Information for cross-context behavioral advertising.

How to Exercise Your Rights

To exercise your rights described above, please submit a verifiable request to us by either:

• Visiting Your Privacy Choices
• Call our privacy toll-free line at 1-800-393-0815, Option 21.
• Email privacy@frankcrum.com
• Mailing Address: Attn: Privacy Team 100 S. Missouri Ave. Clearwater, FL 33756

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.  

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 personal information that we hold about you, or we may have destroyed, deleted, or made your personal information 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 personal information 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.

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 personal information 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 Cookie Preferences 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 Cookie Preferences .

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 personal information 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 to privacy@frankcrum.com or write to us at the address listed below. Please mention that you are making a “California Shine the Light” inquiry.

Sources of Personal Information

We may collect your personal information from the following sources:

• Directly from you (web forms, inquiries).
• Automatically through cookies, pixels, and similar technologies.
• From service providers, business partners, corporate clients, data brokers, public sources, and government entities.
• Through systems access (if applicable).
• Via physical locations (e.g., call recordings, badge logs, video surveillance).

To Whom We Disclose Personal Information

We will only share your information with the third parties listed below for the purposes described above unless otherwise noted at the point of collection:

• Advertising partners and analytics providers (e.g., Google Ads).
• 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.
• Consumer reporting agencies (where applicable).
• Consulting and investigation firms, including HR consultants, safety consultants, and workplace investigators.
• Corporate clients (meaning an entity, as opposed to a natural person, that purchases any of our services).
• Customer Relationship Management (CRM) Provider.
• Data brokers.
• Financial institutions and payment processors.
• Government agencies.
• IT, cybersecurity, and risk vendors.
• Marketing support vendors and vendors that support managing or hosting the website.
• Social media platforms (e.g., Facebook, LinkedIn).
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all FrankCrum’s assets.
• Transactional support vendors.

Trusted third-party agents and service providers who assist us in providing our website to you and are only permitted to use your information according to the purposes specified in their agreement with us. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

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 personal information, or they may collect information, including personal information, 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.

How we use Personal Information

We use information that we collect about you or that you provide to us, including any personal information, to:

• Advertising and Marketing
  • Provide interest‑based and targeted advertising.
  • Serve interest‑based advertising on desktop, mobile, and Connected Television devices.
    

• 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.
  • Verify, respond to, and retain your selections for privacy-related opt-out requests in accordance with applicable privacy laws.

• Communications and Service Delivery
  • Respond to inquiries and communicate with you regarding accounts, services, updates, notices, or other operational or service-related information.

• Credit, Background, and Identity-Related Checks
  • Conduct credit and background reference checks on clients for account review.

• Human Capital Analytics
  • Conduct internal analytics, including productivity and operational analysis to improve workforce processes and business performance.

• 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 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 are not essential to the website functionality but serve some other unique purpose in three subcategories:
  • "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 called 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:
    • Encrypted login session identifiers (not passwords).
    • Masked or tokenized user identifiers.
    • Language or regional preferences.
    • Saved display or accessibility settings.
  • "Marketing" cookies (sometimes called 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.

• Operate, Maintain, and Improve Company Systems and Website
  • Facilitate the efficient and secure use of Company information systems.
  • Ensure compliance with Company information systems policies and procedures.
  • Debug, identify, and repair errors that impair intended website or system functionality.
  • Improve, optimize, and promote our website, including by analyzing information and creating aggregated or de‑identified data to maintain, measure, and enhance website performance and user experience.
  • Understand demographics and usage patterns of website visitors.

• Security, Fraud Prevention, and Incident Response
  • Detect, investigate, and respond to security incidents or potentially unauthorized access, use, or disclosure of Personal Information.
  • Protect against malicious, fraudulent, or illegal activity and prosecute those responsible.
  • Prevent identity theft.
    

Independent Contractors and Business-to-Business Purpose, to:

• 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.

The use of information we collect, whether connected to your personal information or not, helps us improve our website and delivers a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Recognize you when you return to our website.
• Speed up your searches.
• Store information about your preferences, allowing us to customize our website according to your individual needs and interests.

Notice of Right to Opt-Out of the Selling and Sharing of Your Information

Depending on the state where you reside, you may have the right to tell us not to sell or share your Personal Information. You have the full and free right to opt-out of our disclosure of your Personal Information 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: Click Your Privacy Choices to 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 call our toll-free privacy line at 1-800-393-0815, Option 21. for assistance and a representative will assist in meeting your needs.
• Visiting Your Privacy Choices
• Call our privacy toll-free line at 1-800-393-0815, Option 21.
• Emailing privacy@frankcrum.com
• Mailing Address: Attn: Privacy Team 100 S. Missouri Ave. Clearwater, FL 33756

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 may store or retrieve 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 personal information 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 Cookie Preferences which controls the collection of preferences on our website.

We make use of cookies under the following circumstances and for the following reasons:

• Essential Cookies

• Non-Essential Cookies

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:

• Google Analytics
• Meta/Facebook
• Your Privacy | ZoomInfo

Cookie Management

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.html for information on different ways to configure your browser’s cookie settings.

If you want to clear all cookies left behind by the websites you have visited, here are links where you can download three third party programs that clean out tracking cookies.

• https://www.adaware.com/ad-blocker/
• http://www.spybot.info/en/download/index.html
• http://www.webroot.com/consumer/products/spysweeper/

You may delete cookies from your web browser at any time or block cookies on your equipment, but this may affect the functioning of or even blocking the website. You can prevent saving cookies (disable and delete them) by changing your browser settings accordingly at any time. It is possible that some functions will not be available on our website when use of cookies is deactivated. Check the settings of your browser. Below you can find some guidance:

• Safari
• Opera
• Internet Explorer
• Google Chrome
• Mozilla

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 (except for Global Privacy Controls as explained above in the section of this policy on “Opt-Out Preference Signals”).

You can adjust your advertising preferences on mobile devices through your device settings. Below you can find some guidance based on your type of mobile device:

• Apple
• Android

DAA

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.

Email Tracking Notice

When you receive an email from us, we may use tracking technologies to gather certain information about your interaction with the email. Specifically, we may collect whether you open the email; the time and date when you open it; and the Internet Protocol (IP) address of the device used to open the email.

We use this information to help us understand how our emails are received and used, so we can improve content, deliverability, and relevance. This tracking is done automatically using a small, often invisible image (sometimes called a “tracking pixel” or “pixel”) embedded in the email or similar methods.

If you prefer not to have this information tracked, you may disable automatic image loading in your email client or use settings/tools that block tracking pixels. Additionally, unsubscribing from our email list will stop further emails (and thus tracking) from us.

Opt-Out Preference Signals

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 Personal Information about activities over time and across different websites or online services. We encourage users who have DNTs to use GPCs or UOOMs.

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.

U.S. Consumer Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal information, including:

• Access and Data Portability. You may confirm whether we process your personal information and access a copy of the personal information 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 personal information that we maintain, considering the information's nature and purpose of processing.
• Deletion. You may request that we delete personal information about you that we maintain, subject to certain exceptions under applicable law.
• Opt-Out of Using Personal Information for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal information 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.com with 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.

To exercise your rights, please submit a verifiable request to us by either:

• Visiting Your Privacy Choices
• Call our privacy toll-free line at 1-800-393-0815, Option 21. 
• Emailing privacy@frankcrum.com
• Mailing Address: Attn: Privacy Team 100 S. Missouri Ave. Clearwater, FL 33756

If you are a California resident, additional information applies to you. Please see above California Residents: Notice of Collection

How We Retain Your Personal Information

We maintain retention schedules aligned to legal, regulatory, tax, and contractual requirements and delete or de‑identify data when no longer needed. We keep the categories of personal information 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 Services, 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 personal information. At the end of the retention period, personal information 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 personal information to what is reasonably necessary and proportionate for the purposes described in this Policy or disclosed to you at the time of collection.

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 personal information record created 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 may disclose specific personal 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 personal information 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 personal information 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 personal information 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 personal information against unauthorized use, disclosure, and access.

Children's and Minors' Data

We do not knowingly sell or share the personal information of consumers under the age of 16. No one under 16 may provide personal information to or on the website. We do not knowingly collect personal information 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 personal information 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 personal information.

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.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in 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 in the form that is accessible to consumers with disabilities

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.