FRONTIER — PRIVACY NOTICE
Last Updated: May 19, 2025
Introduction
Welcome to the website (the “Site”) of Frontier Digital Holdings, Inc. and its affiliates (collectively, “Frontier,” “we,” “us” and/or “our”). The Site is operated by Frontier from the State of Florida and provides information about Frontier and the products and services we offer (the “Services”). Your interactions with Frontier are governed by our Terms of Use. This Privacy Notice explains how we collect, use, disclose, and safeguard certain information—primarily personally identifiable data (“Personal Data”)—obtained from visitors to the Site, individuals who contact us, and users of our Services (“you,” “your”). It does not cover: Employees, job applicants, or independent contractors of Frontier; Individuals acting as representatives of entities with which we do business; or The information-handling practices of any third party (e.g., service providers, portfolio companies) whose sites or services may be linked from ours. We encourage you to review the privacy notice of every external site you visit; Frontier is not responsible for the content, safety, or privacy practices of third-party sites or services.
Information We Collect
Data Collected Automatically: When you access the Site, our servers log information your browser sends, such as: (a) IP address, browser type, and device identifiers; (b) Approximate device location; (c) Date/time of your visit and pages viewed; and (d) Files accessed and time spent on each page. We do not link IP addresses to identified individuals, so these sessions remain anonymous. We—and certain third-party providers—use cookies and similar tracking technologies to collect information about your browsing activity across time and different websites. For example, we use Google Analytics, which collects only the IP address assigned to you on the date of your visit and does not receive your name or other identifiers from us. Our Site currently does not respond to “Do Not Track” signals. By using the Site, you consent to this automatic collection.
Data You Voluntarily Provide: We also collect information you choose to give us—such as when you fill out a form, email us, or attend a Frontier event. This may include Personal Data (e.g., name, email address, employer). If you interact with public blockchains in connection with our Services, note that on-chain data (including wallet addresses) is public and generally not treated as Personal Data. By voluntarily providing Personal Data, you consent to its use as described in this Notice and its transfer to Frontier’s offices and authorized third-party service providers in the United States or other jurisdictions.
Children: The Site is not directed to children under 13, and we do not knowingly collect Personal Data from anyone in that age group. If you believe a child has provided us Personal Data, please contact us so we can delete it.
How We Use & Disclose Information
Frontier does not sell your Personal Data. We use, share, and otherwise process information, including Personal Data, to: (a) Operate and improve the Site and Services (e.g., analyze usage to enhance features); (b) Market our Services to you; (c) Comply with our Terms of Use, legal obligations, or regulatory inquiries; (d) Protect legal rights, detect and prevent fraud or security issues, and ensure the safety of Frontier, our users, and the public; and (e) Perform other functions permitted by law. We may aggregate or de-identify data for research, analytics, or other lawful purposes and share such data with third parties. Typical disclosures may include: (a) Related Companies. Affiliates within the Frontier group for purposes consistent with this Notice; (b) Service Providers; (c) Vendors that perform services on our behalf (e.g., cloud hosting, mailing, auditing, legal services) and receive only the data needed for their work; (d) Business Transfers. In connection with mergers, acquisitions, or similar corporate events; and (e) Legal Requirements. When required or permitted to satisfy applicable law, court order, or legitimate law-enforcement request.
Data Protection
We employ commercially reasonable physical, electronic, and procedural safeguards to protect Personal Data. Nevertheless, no Internet or email transmission is ever 100 % secure, so you should take care in what information you send us electronically. We limit access to Personal Data to personnel who need it to provide Services and maintain appropriate security measures, but we cannot guarantee absolute security.
Rights of Individuals in Various Jurisdictions
Privacy rights differ by jurisdiction. Subject to applicable law, you may have the right to: (a) Access the Personal Data we hold about you; (b) Request correction or deletion of inaccurate or irrelevant Personal Data; (c) Opt out of marketing communications; and (d) Raise questions or concerns about our privacy practices. To exercise these rights, contact us using the details below. We will respond in accordance with applicable law.
Changes to This Privacy Notice
Our business and Services may evolve, and we may update this Privacy Notice accordingly. We will post any changes here and revise the “Last Updated” date at the top. Your continued use of the Site or Services after changes become effective constitutes acceptance of the revised Notice.
Contact Us
If you have questions about this Privacy Notice or our privacy practices, please email IR@frontier.investments or write to:
Frontier Digital Holdings, Inc
Attn: Legal & Compliance – Privacy
201 Clearwater Drive, Suite 1703
West Palm Beach, FL 33401 USA