DATA SUBJECT RIGHTS REQUEST FORM

Frontier Innovation Ltd., collectively with its subsidiaries and affiliated companies (“Company”, “we”, “us” or “our”) values privacy rights. As required under applicable law, and specifically the EU General Data Protection Regulations and the UK General Data Protection Regulation (collectively “GDPR”), and applicable US state-level privacy laws including without limitation the California Consumer Privacy Act ("CCPA") (all collectively shall be defined as “Data Protection Laws”), individuals are permitted to make certain requests and exercise certain rights regarding their Personal Data or Personal Information (as such terms are defined under Data Protection Laws) and depending on their jurisdiction.
 

In order to submit a request to exercise individual rights pursuant to the Data Protection Laws, please complete this form and send it to our privacy team at: office@frontierng.com.  

Upon receipt of your completed request, we will process it and respond within the timelines required under applicable Data Protection Laws. If additional information is necessary, we will contact you using the contact information you provided in this form. Information provided in connection with this request will be processed only for the purpose of processing and responding to your request. A verifiable request must provide enough information that allows us to reasonably verify you as the person about whom we collected personal data or an authorized representative of such a person. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.

For more information, please review our Privacy Policy or CCPA notice.

Note, certain deletion, correction and opt-out rights can be exercised by you independently. For example, depending on your interaction with us: (i) you can opt-out from receiving marketing emails from us by clicking the "unsubscribe” link within the email; (ii) you can opt-out from processing of Personal Data through our use of cookies, at any time, by using the cookie settings tool made available on our site. 

1. CONTACT INFORMATION:

Full           Name: ___________________________________________________________________________

Email        Address: ________________________________________________________________________

1. WHAT IS YOUR RELATIONSHIP WITH US?

• Website Visitor

• Newsletter Recipient

• Entrepreneur

• Investor

• Grower

• Business Partner

• Other ___________

Any other information that may help us to locate your Personal Data: ______________________________________________________________________________________________________________________________________________________________________

1. YOUR REQUEST:

Detailed below are various rights and requests granted under Data Protection Laws. Note that you might not be eligible to exercise all or part of the rights detailed below – this depends on your jurisdiction, our relationship, and our rights to refuse or retain data under applicable law. Where we are not able to provide you with the information for which you have asked or otherwise fulfil your request, we will endeavor to explain the reasoning for this and inform you of your rights.

A.CALIFORNIA RESIDENTS UNDER THE CCPA:

Note: Under the CCPA your rights only apply to the Personal Information collected 12 months prior to the request and you are not entitled to submit more than 2 requests in a 12-month period.

Please check the applicable right you are requesting to execute:

• Right to Know or Access;

• Right to Deletion (the right to delete is not absolute and in certain cases we will have the lawful right to maintain the Personal Data - see the “Notice re Deletion Right” below);

• Right to Data Portability (to obtain a portable copy of the Personal Data);

• Right to Non-Discrimination;

• Right to Rectification;

• Right to Opt-out from Sale or Share of Personal Information (*see additional information below);

• Right to Limit the Use and Disclosure of Sensitive Personal Information;

• Opt-Out of the Use of Automated Decision Making; or

• Other _______________________________________________________________________;

CCPA Opt-Out Rights:

The Right to Opt-out of Sale; Opt-Out of Sharing for Cross-Contextual Behavioral Advertising; can be executed without filling the form by:

• You can opt-out from cookies using our cookies setting tool, where you can further change your preferences at any time. We will also process any opt-out of sale/sharing preference signal that meets the requirements set forth in the CCPA and its regulations.  If you do not want to receive interest-based advertisements, you can limit the collection of certain information through your device settings. 

• California resident and wish to opt-out from having your data used for interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.

Please know that opting out of interest-based advertising does not mean that you will not receive advertising. You may still receive ads, but those ads may be less relevant to your interests.

Authorized Agent:

You may submit the request by an Authorized Agent as detailed in our CCPA Notice. A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

Response Framework:

We will aim to complete CCPA verifiable consumer requests as soon as reasonably practicable and consistently within the 45-days timeframe mandated by the CCPA. If we require additional time, we will inform you of the reason and extension period in writing. In some cases, our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

B.OTHER US STATE LAWS:

Please provide your state of residency under which you wish to exercise your privacy rights (a verifiable address):  _________________________________________________________________

Please select the applicable right you wish to exercise (note that not all rights may apply in every jurisdiction and availability may vary based on the specifics of each case):

• Right to Confirm if the Data is Being Processed and to Access That Personal Data;

• Right to Deletion (the right to delete is not absolute and in certain cases we will have the lawful right to maintain the Personal Data - see the “Notice re Deletion Right” below);

• Right to Data Portability (to obtain a portable copy of the data);

• Right to Correct Inaccuracies;

• Right to Opt-Out of the Processing of Personal Data for the Purposes of: Targeted advertising; Sale for personal data; or Profiling used for decisions that produce legal or similarly significant effects on a consumer; or  

• Right to Non-Discrimination; or

• Other:_________________________________________________________________________.

Response Framework & Appeal:

We aim to respond to all authenticated consumer requests within the timeframe mandated by law (usually 45 days). If you have an account with us, you may be required to use this account to submit your request. Should we be unable to authenticate your request using commercially reasonable efforts, additional information may be requested to authenticate your identity and your request. If we cannot authenticate your request, we will be unable to grant it. If we refuse to act on a request, you have the right to appeal against our decision, and our response will detail the specifics of your option to appeal as further elaborated in our Privacy Policy. If the appeal is denied by us, you may have the right to file a complaint with the relevant state Attorney General. We will provide you with a written explanation of our decisions detailing your rights and further options.

Authorized Agent:

Please note you may designate an authorized agent on your behalf to exercise your right to opt out detailed above. You may designate such authorized agent by way of, among other things, a technology, including, but not limited to, an Internet link or a browser setting, browser extension or global device setting, indicating your intent to opt out of such processing (all as detailed under Opt-Out Rights Section above).

In each relevant case, we will delete or de-identify Personal Data not subject to one of these exceptions and applicable law from our records and will direct our processors to take similar action.

C.EU, UK, EEA AND OTHER JURISDICTIONS:

Please provide your country of residency under which you wish to exercise your privacy rights (a verifiable address):  _________________________________________________________________

Please check the applicable right you are requesting to execute:

• Right to be Informed to the Processing of Personal Data;

• Right to Access to Your Personal Data;

• Right to Rectification and Amendment;

• Right to Deletion / Erasure (the right to delete is not absolute and in certain cases we will have the lawful right to maintain the Personal Data);

• Right to Restrict Processing of Personal Data;

• Right to Data Portability (to obtain a portable copy of the data);

• Right to Object to the Processing of Personal Data;

• Right to Withdraw Consent;

• Right to Object to Marketing; or

• Rights Related to Automated Decision-Making and Profiling;

• Other:_________________________________________________________________________.

1. GENERAL NOTICE REGARDING DELETION: 

Deletion Rights are not absolute - we may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) debug products to identify and repair errors that impair existing intended functionality; (4) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) comply with the law or legal obligation; (6) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

1. VALIDATION, REPRESENTATIVE & CONFIRMATION

The verifiable request must provide enough information that allows us to reasonably verify whether you are the person about whom we collected Personal Data or an authorized representative. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information or Personal Data relates to you.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Substantiate the request - please provide additional information about your request: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

Representatives: (only complete if you are acting as the representative for a data subject)

Please Note: We may still need to contact the data subject where proof of authorization or identity is required.

Representative’s Name:

Relationship to data subject:

Email:

I confirm that I am the authorised representative of the named data subject:

Representative’s Name: ____________________

Signature: __________________

Confirmation:

Data Subject Name

Signature

Date

Thank you for filling in the form, please send it to: office@frontierng.com. We will process the request within the time frame under the applicable Data Protection Law, we reserve the right to extend the aforementioned period by the time specified in the Data Protection Laws if the request is complex or numerous or we require additional information.

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