Online Privacy Policy

Community Investors, Inc. dba FRONTSTEPS (“FRONTSTEPS,” “us,” “we,” or “our”) respects the privacy and security of our Authorized Users (defined below) and any personally identifiable information that we collect about you though your use of our websites, downloaded desktop applications and downloaded mobile applications (collectively, the “Services”). The following (our “Privacy Policy”) describes our privacy policy and practices with respect to that information. By your registration to use or use of the Services, you consent to our collection and use of your personally identifiable information and other information online by us in the manner set forth in our Privacy Policy. Authorized Users (alternatively, “you” or “Users”) are (i) verified residents of associations or management companies that have contracted for our Services or (ii) employees of the associations or management companies that have contracted for our Services.

Please read this policy carefully. We may change this policy from time to time, and we will post those changes on this page. Your continued use of the Services following the posting of any amendment will constitute your acceptance to that amendment. Please check back periodically.

This policy will notify you of:

1. What is “personally identifiable information”?;
2. What personally identifiable information do we collect about you through our Services?;
3. How does FRONTSTEPS collect PII?;
4. How does FRONTSTEPS use PII?;
5. Who do we share PII with?;
6. Our use of cookies: what they are and how we use them;
7. Other Websites; Links;
8. Consent to use of Third Party Providers;
9. Your choices as to collection, use and distribution of your PII;
10. How you can correct inaccuracies in or update your information?;
11. What security procedures are in place to protect the loss, misuse or alteration of PII?;
12. How do we protect children’s privacy?;
13. Transfer of Data Internationally;
14. General.

If you have any questions concerning our Privacy Policy, please contact us at
Customer Support
Community Investors, Inc., dba FRONTSTEPS
1290 Broadway Suite 1250
Denver, CO 80203
(800) 992-4384
[email protected]

What is “personally identifiable information?”

Personally identifiable information (“PII”) is information that can be used, alone or with other identifying information, to identify you as a unique individual, such as your name; home, email or other address; telephone number; birth date; and similar personal information.

What personally identifiable information do we collect about you through our Services?

Depending on the Services provided to you, we may collect the following PII in order to provide our Services:

Contact Information such as name, home address, email address, phone number

Access information such as username, password, license plate number, IP address

We do not collect financial information including billing information and billing address.

How does FRONTSTEPS collect PII?

As explained above, we collect personally identifiable information about you in connection with the provision of our Services.

Your association or its management company may give us Contact Information PII so we can verify that you are a resident, employee or otherwise permitted to use the Services. When you register to use Services, we will ask for Contact Information PII to confirm your identity as a person authorized to use the Services, and Access Information PII to create an account. You may also voluntarily provide additional PII when creating and using your account.

Other PII may be given to us by the association, its management company, or you in order to render the Services. For example, we may collect your name when assisting the association’s management company in compiling an electronic database of members of the association or posting an online directory of members. If you send an email message through our website, we will receive your email address and any other personally identifiable information you may include in that message.

Third Party Vendors (defined below) that we engage to provide some of the Services may also collect PII in connection with the performance of those Services. We require those contractors to adhere to privacy policies no less stringent than our Privacy Policy.

In the course of using the Services, you may provide personally identifiable information to others. For example, you might post a message to a message board or send an email to another member, your association or the association’s management company, that may contain personally identifiable information. We do not control the privacy practices or policies of any such person or entity, and they are not covered by this Privacy Policy.

How does FRONTSTEPS use PII?

We use your PII to provide the Services, and to help us improve our Services. We may share anonymous user information, or information that is “aggregated,” to better understand the users of our Services and enhance or improve our Services, but we will do so only in a manner that does not personally identify you. We may use your personally identifiable information to send you messages about the Services. We may share your PII with Affiliates or Third Party Vendors when required to provide Services.

Who do we share PII with?

We share PII with your association and the association’s management company, on whose behalf we are providing the Services. We also share the information with Affiliates and Third Party Vendors that may provide a portion of the Services. Our wholly owned affiliated companies (our “Affiliates”) have the same information rights to the PII that we have. However, we do not allow Third Party Vendors to use PII other than in connection with the provisions of the Services without your express consent. Third Party Vendors include parties who help us with specialized services, including customer support, email and text message deployment, business analytics, marketing, suppression list management, and data processing.

We may share your personally identifiable information in connection with a substantial business transaction, such as the sale of FRONTSTEPS, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

We may disclose personally identifiable information to any third party if required to do so by law or regulation, or if we believe in good faith that such disclosure is necessary to:

(a) comply with a judicial proceeding, court order, or other legal process;

(b) enforce the Terms of Service;

(c) respond to claims that any content of any portion of the Services violated the rights of third parties; or

(d) protect the rights, property, or personal safety of FRONTSTEPS, other users of our Services or the public.

Our use of cookies: what they are and how we use them?

A cookie is a small data file that a web server sends to your web browser (your computer’s hard drive) so it can be later read by the web server. We use cookies to help us identify you so that you are able to use Services that are restricted to authorized users. We may also use cookies for purposes such as tracking website or Services use, length and nature of use, number of members, traffic patterns and other business purposes. We may do this in an anonymous fashion (in a manner that does not attempt to personally identify the user); however, once you have registered to use our service, you are no longer anonymous to us when you use our Services.

When users or other visitors visit a web site that we manage, our web servers automatically record certain information and retain it in the web servers’ logs. This information may include your IP address, domain name, browser type, date and time of the visit and similar information.

Other Websites; Links‍

Our website and software may include links to third party advertisements and promotions. We will not provide any personally identifiable information without your express consent in relation to these linked advertisements and promotions. In addition to such third party advertisements and promotions, certain websites of FRONTSTEPS affiliates and other third-party websites are accessible through our website. These third-party websites have their own privacy and data collection policies and practices, and we encourage you to read the privacy policies of any such third party. FRONTSTEPS IS NOT RESPONSIBLE FOR ANY ACTIONS OR PRIVACY POLICIES OF SUCH THIRD PARTIES. FRONTSTEPS DOES NOT ENDORSE, RECOMMEND, OR COMMENT ON THE SUITABILITY OF ANY THIRD-PARTY PRODUCT OR SERVICE. YOU SHOULD CHECK THE APPLICABLE PRIVACY POLICIES OF THOSE THIRD PARTIES WHEN PROVIDING PERSONALLY IDENTIFIABLE INFORMATION ON LINKED WEBSITES.

Consent to Use of Third Party Providers

In addition to the specific third parties noted in this Privacy Policy, we may also contract with other third parties to provide various services to FRONTSTEPS relating to our website and Services on an outsourced basis rather than performing the services ourselves. By using our online Services, you consent to us providing your information (including personally identifiable information) to these third-party providers for the purpose of enabling the third-party provider to provide these outsourced services to FRONTSTEPS. In addition, you consent to the collection, maintenance, and processing of your information by FRONTSTEPS and these third-party providers.

What are your choices regarding the collection, use and distribution of your PII?

You have the right to revoke your consent to FRONTSTEP’s use of PII at any time. However, if such proposed collection, use or transfer of PII is a condition of our provision of any of the Services, your refusal to grant permission may result in your inability to use all or a portion of the Services.

By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, if you choose to reject all cookies or if you enable other software that prevents cookies from operating, you will be unable to use the Services.

How can you correct inaccuracies in or update your information?

PII may be contained in an online database maintained in connection with provision of the Services. All authorized users of the Services may access their PII through their profile page, in order to review correct any inaccuracies. Certain personally identifiable information, such as the address of the “unit” that you own, cannot be changed without verification by your association or its management company. We are not responsible for the accuracy of association or management company provided information contained in such online databases.

We may maintain our own separate databases in order to provide the Services, to which you will not have online access. For example, we may maintain one or more databases of members of an association who are entitled to become and remain users of the Services. Such databases may contain information furnished by the association, its management company and/or members, or otherwise collected as set forth in this Privacy Policy. If you wish to ask us about the personally identifiable information that we may have collected about you and that is not available to you online, you should email us at [email protected].  We will use commercially reasonable efforts to comply with your request, and to update and/or correct any personally identifiable information that is contained within such databases.

What security procedures are in place to protect the loss, misuse or alteration of PII?

Access to the Services, including access to databases containing personally identifiable information, is password protected. Any personal information that you have posted in any portion of the Services (e.g. a message board) should be accessible only by the association, the association’s management company, other members and other Authorized Users of the Services. It is the responsibility of each User to protect such user’s password. Do not divulge it to anyone. Log off your computer or close your browser window to ensure that others cannot access your password.

We use industry-standard software, hardware and other measures, to protect the confidentiality, security and quality of information we collect, and to protect it from unauthorized access or disclosure or accidental loss, alteration or destruction. Due to the nature of the internet and computer security, we cannot warrant or guarantee that security will never be breached.

How do we protect children’s privacy?

You must be 18 years of age or older to register to use the Services. We do not knowingly collect personally identifiable information from children under the age of 13. If such information is inadvertently or unknowingly collected, it is our policy to destroy or delete it upon discovery.

Transfer of Data Internationally

FRONTSTEPS is headquartered in the United States. Users who access our Services internationally, please be aware that information you provide to us or that we obtain as a result of your use of our Services may be collected in your country and subsequently transferred to the United States in accordance with applicable law. The privacy and data protection laws in the United States may not be equivalent to such laws in your country of residence. By using our Services or providing us with your information, you consent to the collection, international transfer, storage, and processing of your information.

General

FRONTSTEPS reserves the right to make changes or updates to this Privacy Policy at any time and for any reason. Continual use of the Services will serve as acceptance of the current Privacy Policy. We encourage you to return to the Privacy Policy occasionally to review any updates.

This Privacy Policy is governed by the internal substantive laws of the State of Colorado, without regard to its conflict of laws principles. Jurisdiction for any disputes, controversies, or claims arising under, in connection with, or out of this Privacy Policy shall lie exclusively with the state and federal courts located in Denver, Colorado. If any provision of this Privacy Policy is found to be invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Privacy Policy, which shall remain in full force and effect. WHERE ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES SHALL FRONTSTEPS HAVE ANY LIABILITY WHATSOEVER FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, OR SPECIAL DAMAGES ARISING OUT OF THIS ONLINE PRIVACY POLICY, HOWEVER OCCASIONED. FRONTSTEPS’ liability arising from this Privacy Policy will not exceed the greater of $100 or the total amount you have paid us for Services in the past 12 months.