Frontier Privacy Policy

Effective date: January 1, 2024

Frontier Distributing (“Frontier,” “we,” “us” or “our”) respects the privacy of our clients, our clients’ mailing recipients and visitors to our website. This Privacy Policy explains how we collect, use, disclose, retain and protect personal information.

This policy applies to our website and to personal information handled while providing mail preparation, addressing, processing, distribution, courier and related services.

1. Our role as a mailing service provider

Frontier provides mailing services on behalf of businesses and other organizations. To perform these services, our clients may provide us with limited information about their intended recipients, such as:

• Name;
• Residential or business mailing address;
• Postal code;
• Client-assigned reference or account number; and
• Mailing, delivery or processing instructions.

Frontier processes this information only as required to provide services to the client and according to the client’s instructions.

The client is responsible for ensuring that it has the legal authority to collect the information, provide it to Frontier and use it for the intended mailing. Frontier does not obtain mailing lists for its own marketing purposes and does not use client-supplied recipient information to advertise its own services.

2. Information collected directly by Frontier

We may collect personal information directly from clients, prospective clients, suppliers and website visitors, including:

• A person’s name and business name;
• Mailing address;
• Email address;
• Telephone number;
• Billing and transaction information;
• Information submitted through our contact form; and
• Technical information required for website operation, security and fraud prevention.

You should not submit sensitive personal information through our website contact form.

3. How we use personal information

Frontier may use personal information to:

• Prepare, address, sort, process and distribute mail;
• Complete courier, freight, customs or delivery services requested by a client;
• Verify or correct mailing information when authorized by the client;
• Communicate with clients and respond to inquiries;
• Prepare quotations, invoices and transaction records;
• Manage our business relationship with clients and suppliers;
• Maintain the security and proper operation of our website and systems;
• Investigate errors, complaints or suspected misuse;
• Meet legal, regulatory, accounting and record-keeping requirements; and
• Carry out other purposes that are identified when the information is collected or otherwise permitted by law.

We limit our collection, use and disclosure of personal information to purposes that a reasonable person would consider appropriate in the circumstances.

4. Consent and authority

When Frontier collects personal information directly, we obtain consent where required by law. Consent may be express or implied, depending on the nature of the information and the circumstances.

When Frontier receives a mailing list or recipient information from a client, we rely on the client to have obtained any consent or other lawful authority required for the mailing. Frontier uses that information only to provide the contracted services, unless another use is required or permitted by law.

5. Disclosure of information

Frontier does not sell or rent personal information or client mailing lists.

We may disclose limited personal information to:

• Canada Post, the United States Postal Service, couriers, carriers and delivery providers;
• Printers, mailing-production providers or other subcontractors needed to complete an authorized job;
• Technology, hosting, security or data-processing providers that support our operations;
• Government, customs, postal or law-enforcement authorities when disclosure is required or permitted by law; and
• Professional advisers or parties involved in a proposed business transaction, subject to appropriate confidentiality requirements.

We require service providers to use personal information only for the services they provide and to protect it appropriately.

6. Transfers and processing outside a province or Canada

Some mailing, delivery, technology or processing services may require information to be transferred to another province or, where necessary to complete an authorized cross-border service, outside Canada.

Personal information processed in another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to its courts, governments or law-enforcement authorities.

Frontier remains responsible for personal information under its control and uses contractual, organizational and other measures appropriate to the circumstances when information is handled by a service provider.

7. Retention and destruction

We retain personal information only for as long as reasonably necessary to:

• Complete the services requested by the client;
• Resolve mailing, delivery, billing or service issues;
• Meet contractual obligations; and
• Satisfy legal, accounting and record-keeping requirements.

Client-supplied mailing files and working copies are securely deleted or destroyed when they are no longer required, subject to our contractual and legal obligations. Printed materials containing personal information are securely destroyed when no longer needed.

An individual seeking information about a mailing list supplied by one of our clients may need to contact that client, because the client controls the list and determines its purposes.

8. Safeguards

Frontier uses reasonable physical, administrative and technical safeguards appropriate to the sensitivity and amount of information involved. These may include:

• Limiting access to employees and service providers who require the information for their work;
• Employee confidentiality and privacy requirements;
• Passwords, access controls, firewalls and other system protections;
• Secure transmission or storage methods where appropriate;
• Controlled handling of mailing files and printed materials;
• Secure disposal of electronic and paper records; and
• Procedures for responding to suspected privacy or security incidents.

No system can be guaranteed to be completely secure. If a privacy breach occurs, Frontier will investigate it and provide any notifications required by applicable law.

9. Website and contact-form information

When you use our website or contact form, we may receive the information you voluntarily provide, together with limited technical information such as your Internet Protocol address, browser information, date and time of access and security-verification results.

We use this information to:

• Respond to your message;
• Protect the website and contact form from spam, fraud and automated abuse;
• Diagnose technical problems; and
• Maintain the security of our systems.

Our contact form uses Cloudflare Turnstile as a security measure. Cloudflare may process limited device, browser and network information to determine whether a submission is being made by a person rather than an automated system. Cloudflare’s handling of information is governed by its own privacy policy.

We do not use contact-form information for unrelated marketing without consent.

10. Cookies and similar technologies

Our website and its security services may use cookies or similar technologies that are necessary for website operation, security and abuse prevention.

If Frontier later introduces advertising, behavioural tracking or non-essential analytics, this policy and the website’s consent controls will be updated as required.

11. Access and correction

Subject to applicable law, an individual may ask to:

• Learn whether Frontier holds personal information about them;
• Obtain access to that information;
• Understand how it has been used or disclosed; or
• Correct information that is inaccurate or incomplete.

We may need to verify the requester’s identity before responding. Legal exceptions may limit the information we can provide.

Where information was supplied and controlled by one of our clients, we may refer the request to that client or work with the client to provide an appropriate response.

12. Questions and complaints

Frontier has designated a Privacy Officer to oversee compliance with this policy and applicable Canadian privacy laws.

Questions, access or correction requests, and privacy complaints may be submitted through our Contact page. Please select or state that your message is for the Privacy Officer.

You may also write to:

Privacy Officer
Frontier Distributing
PO Box 1059
Fort Erie, Ontario, Canada
L2A 4K7

Please do not include unnecessary personal or sensitive information in your initial inquiry.

We will investigate privacy complaints and respond within a reasonable period. If a concern is not resolved, an individual may contact the Office of the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.

13. Changes to this policy

We may update this Privacy Policy to reflect changes in our services, practices or legal obligations. The current version will be posted on this page with its effective date. Material changes will be highlighted where appropriate.