General Data Protection Regulation (GDPR) Privacy Notice

The purpose of this Privacy Notice is to explain how Frontier Asset Management, LLC (“Frontier”, “we”, “us”, “our”) may process your Personal Data in connection with your relationship or interest in our firm. The term “process” here refers broadly to the collection, use, storing, amendment, sharing, or any other handling of your Personal Data.

It is important that you read this notice in full. It provides important information about your rights. It also explains how we will seek to protect your Personal Data in accordance with our legal obligations.

Frontier Asset Management, LLC
Frontier Asset Management, LLC is registered investment advisor based in Sheridan, Wyoming.
You may contact us at 50 East Loucks Street, Suite 201, Sheridan, WY 82801 USA.
If you have any questions about the contents of this notice, you can reach us at +001.307.673.5675 or  info@frontierasset.com.

What is Personal Data?
Under GDPR, “Personal Data” is broadly defined to include any information relating to an identified or identifiable natural person (the ‘Data Subject’).

Personal Data we process may include information such as your name, address, telephone number, personal and/or work email address, job title, and information about your financial circumstances, such as details of your net assets and investment portfolio. Personal Data does not include data from which you can no longer be identified such as anonymized aggregate data. In respect of your Personal Data that we process, you are the “Data Subject”.

Why Are We Collecting Your Personal Data and How Will We Use Your Personal Data?
The kinds of Personal Data we may collect include your contact details (such as your address, email address and telephone number) and information such as your job title. In addition, we collect the Personal Data you choose to provide to us, e.g., if you contact us by letter, telephone, email or any other means of electronic or personal communication. We will process your Personal Data if and to the extent applicable law provides a lawful basis for us to do so. We will therefore process your Personal Data only:

  1. if you have consented to us doing so;
  2. if we need it to perform the contract we have entered into with you;
  3. if we need it to comply with a legal obligation; or
  4. if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will include the providing of investment advisory services by us and administrative, legal, compliance or operational processes within Farallon.

We will use your Personal Data to deliver investment advisory services to you and/or the institution you work or act for. We may also use your Personal Data to inform you about our General Data Protection Regulation (GDPR)
services.

Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

We may collect Personal Data through our website, or directly by email, telephone, or through any
other interaction we may have with you.

What we may need from you.
We may need to request specific information from you to help us confirm your identity and enable your right to access Personal Data (or to exercise any of your other rights). This is another appropriate security measure so that Personal Data is not disclosed to any person who has no right to receive it.

Accuracy of information.
It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data changes during your relationship with us.

What Happens If You Do Not Provide Us With Your Personal Data?
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to provide all or some of our investment advisory services, to enter into a contract with you or to send you requested information.

Change of purpose, anonymization.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longe Personal Data.

Will We Share Your Personal Data With Anyone?
In certain circumstances, we and/or our authorised delegates may be required to share your Personal Data with regulators, courts, tax authorities, or other public institutions. We work with certain service providers as part of our day‐to‐day operations (our “delegates”). There may be circumstances in which we share your Personal Data with such delegates. In relation to any Personal Data processed by our Delegates, they will be acting as Data Processors.

How long will we retain your information?
We will retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.
In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Your Rights.
You have a number of rights in relation to any Personal Data we hold on you. If you would like to exercise any of your rights, please contact us at info@frontierasset.com.

  • You have a right to access any Personal Data we hold on you.
  • You have a right to correct any of your Personal Data which is inaccurate.
  • Under certain circumstances, you have a right to have to obtain a restriction on our processing of your Personal Data.
  • Under certain circumstances, you have a right to object to our processing of your data, where we have collected and processed your Personal Data for the purposes of our legitimate interests.
  • Under certain circumstances, you have a right to obtain the erasure of any Personal Data we hold on you. We will do our best to meet any such request, although it is possible that you may be restricted in your ability to exercise this right. This is because we may process your Personal Data to satisfy certain legal obligations, and we may be required to retain records which could prevent us from being able to erase your data. A request for erasure will need to be considered alongside any legal obligation we are bound by.

Where you have contacted us to exercise your rights, we will provide you with information on the actions we have taken in response.

Your Right to Complain.
If you ever have any concerns about the way we are processing your data, or if you are concerned that your data is not being adequately protected, you have the right to make a complaint about us to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, or, as the case may be, any other competent supervisory authority of an EU member state.

Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website.