FREMONT GROUP PRIVACY POLICY

LAST UPDATED:  June 1, 2021

Fremont Group  and its affiliated and related entities (together, “Fremont” “we,” us,” or “our”), is providing this Privacy Policy to describe how we collect, use, and disclose Personal Information from users on this website, and in our telephone, email or other communications with you (the “Services”). The words “user,” “you,” and “your” mean those who use this website, contact us by any methods, including telephone or via email, or otherwise interact with us, other than those who work for Fremont and those who engage us for services, whose privacy is governed by other specific privacy policies.  Fremont views privacy as an important part of the way we do business.

This Privacy Policy, along with our Terms and Conditions of Use, constitute an agreement between you and Fremont that conditions your interaction with our Services, where and as permitted by applicable law.  Please read this Privacy Policy carefully before using the Services or submitting Personal Information to us. By accessing or using our Services or otherwise communicating with us via telephone, email or otherwise, you acknowledge that you have reviewed and understand the provisions of this Privacy Policy.  

TABLE OF CONTENTS

PERSONAL INFORMATION WE COLLECT

We collect information when you interact with us in the course of our Services, for example, (1) when you visit and use our website, (2) when you email us or submit forms online, (3) when you call, text, or visit us, (4) when we engage you for Services or you solicit us to provide Services, or (5) when we are otherwise in communication with you.  

Certain of the information we collect may be “Personal Information,” by which we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a natural person, device, or household, such as a name, postal address, e-mail address, telephone number, and/or payment information.  Other information directly associated with Personal Information also may be considered Personal Information.  Information that is aggregated, de-identified, or anonymized is not considered Personal Information.  Publicly available information that is made available from federal, state, or local government records also is not considered Personal Information.

The Personal Information we collect varies depending on how you interact with us.

Personal Information You Provide to Us: You may provide the following types of Personal Information to us by email, by phone, in person, or otherwise, and such information may be Personal Information within the terms of this Privacy Policy:

  • Individual contact and identification information, including name, email address, postal address, or phone number.
  • Any other information you provide to us when you contact us that may be considered Personal Information.

Personal Information Collected Automatically When You Contact Us:  We may also collect Personal Information automatically depending on how you contact us, including when you visit our website, or when you call us.  For example, we may collect information such as:

  • IP address, device identifier, browser information, device information, operating system, language information, URL accessed, information about your use of our website, and dates and times of activity. 
  • General location information, including as derived from your IP address.
  • Phone number or email address that is automatically available to us when you call, text, or email us.  

Personal Information Collected from Job Applicants:  If you apply for a job with us, we may collect additional information in connection with your application.  This may include:

  • Additional contact information;
  • Username and password;
  • Work authorization status;
  • Resume, CV, cover letter, work experience, and education information;
  • Skills;
  • Professional and work-related licenses, permits, and certifications held; 
  • Reference-related information; and 
  • Any other information that is publicly available or that you elect to provide to us (e.g., current salary, expected salary). 

Such information may be collected from you directly, from your references, from a recruiter, from your prior employers, and from your places of education.  We will only use this information to evaluate your candidacy, including by processing your application, assessing your qualifications, corresponding with you, and complying with legal obligations.

HOW WE USE PERSONAL INFORMATION WE COLLECT 

  • We may use your Personal Information in accordance with this Privacy Policy to:
  • Respond to communications from you.
  • Measure and improve our business, services, and performance.
  • Perform analyses on the data and other Personal Information we have collected.
  • Provide, administer, and utilize our websites. 
  • Prevent potentially fraudulent, prohibited, or illegal activities.
  • Comply with legal requirements, or assert or defend a legal claim or defense.

We may disclose other purposes, or update this Privacy Policy, as described below, from time to time. 

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

Fremont does not sell your Personal Information to third parties and will not sell your Personal Information to third parties. 

We may, at times, disclose Personal Information we collect to the following categories of third parties, for the purposes identified above, or with your consent:

  • Our group of companies, affiliates, and related companies in accordance with this Privacy Policy.
  • With other persons with whom you have requested that we share Personal Information, or other persons with whom you have agreed we can share such Personal Information. 
  • In connection with the carrying out of our business activities, including investing, managing, financing and selling investments and providing services to our clients.
  • In connection with, or during the negotiation of, any investment activity or any merger, financing, acquisition, divestiture, or dissolution of any or all of our investments or all or a portion of our business.
  • If we believe that disclosure is reasonably necessary (a) to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce or comply with other applicable agreements or policies, (c) to protect our rights or property, or the security or integrity of our services, or (d) to protect us, users of our services or the public from harm or potentially prohibited or illegal activities.
  • With third parties to manage aspects of your relationship with us and aspects of our business, and to effectuate the uses of Personal Information described in the “How We Use Personal Information We Collect” section above, including third party service providers who access Personal Information about you to perform services on our behalf (including for financial or security reasons).
  • Third parties who may provide professional advice (for example, lawyers, bankers, accountants and/or consultants).

When sharing Personal Information with third parties, we generally require and expect that they only use or disclose your Personal Information as necessary to effectuate the purpose and uses described.

YOUR ACCESS AND CONTROL OVER PERSONAL INFORMATION

You may request to access, update, or in certain cases delete your Personal Information that we have collected, used, or disclosed.  You can do so by filling out this web form, or contacting us by telephone at 1-800-219-0170.

SECURITY

We take reasonable precautions, including physical, electronic, and procedural safeguards, to protect your Personal Information. We make reasonable efforts to maintain security on our systems.  Despite our efforts, we cannot guarantee that Personal Information may not be accessed, disclosed, or altered by breach of our safeguards.  We urge you to take adequate precautions to protect your Personal Information. 

To the maximum extent allowed by applicable law, you agree and acknowledge that Fremont will not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or Personal Information has been compromised, please notify us immediately using the contact information below.

LINKS TO OTHER SITES

Our websites may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our website and to read the privacy statements of any other linked sites that collect Personal Information.

DO NOT TRACK

“Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. Our website is configured to detect Do Not Track signals from a user’s computer and we do respond to Do Not Track requests. More information about “do not track” is available at www.allaboutdnt.org concerning such information. 

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically to account for changes in our collection, use, or disclosure of Personal Information and will post the updated policy on our website, with a “Last Updated” date at the top of this document.  If we make any material changes to this Privacy Policy, we will provide notice of such changes, as appropriate. 

CHILDREN

Our website is not designed nor intended to collect personal information from children under the age of 13, and we do not knowingly collect personal information from children under the age of 13.  If you are a parent or guardian and discover that your child or a minor under the age of 13 has posted, submitted or otherwise communicated Personal Information to our website without your consent, please contact us using the information below so that we may take appropriate actions to remove the minor’s Personal Information from our systems.

We do not sell the Personal Information of any individuals, including that of children under the age of 16. 

RIGHTS FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA), additionally affords rights to our users who are California residents.  For example, California residents may have a right, following a verifiable request, to 

(1) access—twice in a twelve-month period, free of charge for the twelve-month period prior to the request, the categories and specific pieces of Personal Information Fremont has collected about such resident, the categories of sources from which the Personal Information is collected, the business purpose for collecting the Personal Information, and the categories of third parties with whom Fremont has shared Personal Information; and 
(2) delete Personal Information under certain circumstances.  

Fremont further does not discriminate against our users on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

Such requests may be made as described in the “Your Access and Control Over Personal Information” and “Contact” sections, including by filling out this web form, or contacting us by telephone at 1-800-219-0170.  We will first acknowledge receipt of your request within 10 business days after receipt of your request.  We will provide a substantive response to your request within 45 calendar days after its receipt.  If we require more time (up to 90 days or the permitted timeframe), we will inform you of the reason and extension period in writing. 

Only you or an authorized agent (as described below) may make a verifiable consumer request related to your Personal Information. 

  • How to Authorize an Agent.  You may designate an authorized agent to submit your verified consumer request on your behalf, only if the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. 
  • How We Verify Your Request.  To respond to your request under the CCPA we must verify your identity or the authority of your authorized agent to make the request. We will only use the Personal Information provided in that context to verify your identity or the authority of your authorized agent to make the request. Making a verifiable consumer request does not require you to create an account with us.  To allow us to verify your request, we will require that you provide at least two pieces of Personal Information, including your email address and phone number, we already have in our possession. We will verify your consumer request by comparing the information you provide to information already in our possession, and take additional steps to minimize the risk of fraud. 

CALIFORNIA SHINE THE LIGHT

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year.  We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

CONTACT

If you have any questions regarding our Privacy Policy or need to access the policy in an alternative format due to a disability, please contact us at privacy@fremontgroup.com. If you would like to access, update, or delete your Personal Information, please contact us as provided in “Your Access and Control Over Personal Information” section above.