Privacy Policy - Frontline Agency

Last updated: April 25, 2026

This Privacy Notice for Agence Frontline (doing business as Frontline Agency) (“we,” “us,” or “our“), describes how and why we might access, collect, store, use, and/or share (“process“) your personal information when you use our services (“Services“). This includes when you visit our website at https://frontlineagency.ca, utilize our proprietary CRM and SaaS platforms, interact with our AI-automated communication systems, or engage with us in other related ways.

QUEBEC LAW 25 & BILL 96 NOTICE: In compliance with applicable Quebec legislation, this Privacy Policy is available in both English and French. We adhere strictly to the transparent processing of personal data, including the appointment of a designated Privacy Officer and honoring the right to de-indexing.

If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, please contact us at privacy@frontlineagency.ca.

OUR ROLE: DATA CONTROLLER VS. DATA PROCESSOR
WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON?
WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?
ARTIFICIAL INTELLIGENCE, VOICE AGENTS & CALL RECORDING
SMS, TEXT MESSAGING & A2P 10DLC COMPLIANCE
CLOSED-LOOP TRACKING & COOKIES
HOW LONG DO WE KEEP YOUR INFORMATION?
CROSS-BORDER DATA TRANSFERS
HOW DO WE KEEP YOUR INFORMATION SAFE?
WHAT ARE YOUR PRIVACY RIGHTS? (INCLUDING QUEBEC LAW 25)
US STATE SPECIFIC PRIVACY RIGHTS
HOW CAN YOU CONTACT US?

1. OUR ROLE: DATA CONTROLLER VS. DATA PROCESSOR

To fully protect consumer data, it is important to understand Frontline Agency’s two distinct roles:

As a Data Controller: When you visit our website, apply for our services, or become a Frontline Agency client (Tiers 0 through 3), we act as the Data Controller. We decide how and why your personal information is processed.
As a Data Processor (SaaS & CRM Services): We provide an underlying CRM infrastructure, AI chatbots, and call-routing systems for our local business clients. When a consumer submits their information to one of our clients, we act purely as a Data Processor. We only process this data on our client’s behalf. If you are a consumer looking to delete or access data provided to a Frontline Agency client, you must contact that business directly.

2. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us:
We collect personal information that you voluntarily provide to us when you register on our Services, express interest in our products, or contact us. This includes:

Identifiers: Names, phone numbers, email addresses, IP addresses.
Commercial Information: Billing details, payment information (processed securely via Stripe), and service tier selections.
Audio and Electronic Data: Call recordings, voicemails, and AI conversational transcriptions (See Section 6).

Information automatically collected:
We automatically collect certain information when you visit, use, or navigate the Services. This includes:

Log and Usage Data: IP address, device information, browser type, date/time stamps, and system activity.
Device & Location Data: Information about your computer, phone, or tablet used to access the Services, and general location data based on IP address.

3. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for the following purposes:

To deliver and manage services: To set up your SaaS accounts, CRM automation stacks, and advertising campaigns.
To deploy AI Automations: To route missed calls, answer FAQs via SMS, and book calendar appointments automatically.
To optimize advertising (Closed-Loop Tracking): To send hashed conversion data back to ad networks to improve ad targeting for our clients.
To respond to user inquiries: To offer technical support for our systems.
To send administrative and marketing communications: According to your preferences, to send updates, billing notices, or promotional offers.

4. WHAT LEGAL BASES DO WE RELY ON?

If you are located in Canada (including Quebec), we process your information based on:

Express Consent: When you explicitly agree to our terms, opt-in to SMS messaging, or accept our AI call recording notices.
Implied Consent: When processing is strictly necessary to fulfill a contract you entered into with us (e.g., executing a marketing service agreement).
Legitimate Business Interests: To maintain the security of our infrastructure, prevent fraud, and conduct internal system analytics.

5. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?

We do not sell your personal data. We share your data strictly with third-party vendors, service providers, and contractors (“Processors”) who require access to perform work on our behalf. Categories include:

Hosting & CRM Infrastructure: GoHighLevel (GHL) and Google Cloud.
Telephony & Communications: Twilio / LeadConnector for SMS routing and call handling.
Payment Processors: Stripe for secure subscription and setup fee processing.
AI Infrastructure: OpenAI and custom API providers to power voice and text bots.
Ad Networks & Analytics: Google Ads, Meta Ads, and Local Services Ads (LSA) for lead generation and offline conversion tracking.

6. ARTIFICIAL INTELLIGENCE, VOICE AGENTS & CALL RECORDING

Our Tier 3 and add-on Services deploy sophisticated AI Products, including bilingual AI Voice Receptionists and automated SMS agents.

Call Recording & Transcription: Calls handled by our AI receptionists are recorded and transcribed in real-time to facilitate natural language processing, schedule appointments, and maintain service quality. All callers are greeted with an AI disclosure and call-recording warning where legally mandated.
Data Usage: Transcriptions and audio data are used strictly to execute the desired service (e.g., booking a quote) and to train the specific client’s bot for better accuracy.

7. SMS, TEXT MESSAGING & A2P 10DLC COMPLIANCE

We provide proprietary SMS automation (e.g., “Missed Call Text-Back”). By opting in to receive SMS messages from us or our systems:

Standard message and data rates may apply.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors strictly to provide support services (like Twilio for text routing) is permitted.
You may opt out of SMS communications at any time by replying “STOP” or “UNSUBSCRIBE”.

8. CLOSED-LOOP TRACKING & COOKIES

We use cookies, web beacons, and pixels to gather information and secure our Services.

Offline Conversion Tracking: For Tier 2 and Tier 3 clients, we utilize closed-loop tracking. We may securely hash (anonymize) data collected inside our CRM and send it to ad networks (Google/Meta) to train their algorithms to find higher-quality leads.
For detailed preferences on how we use tracking technology, please refer to our Cookie Notice: https://frontlineagency.ca/cookies.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information only for as long as necessary to fulfill the purposes outlined in this policy (such as active SaaS subscriptions), unless a longer retention period is required by law (e.g., tax or accounting regulations). When we have no ongoing legitimate business need, we securely delete or anonymize your data.

10. CROSS-BORDER DATA TRANSFERS

Because we utilize enterprise-grade US-based software infrastructure (such as GoHighLevel, AWS, and Twilio), your data may be transferred to, processed, and stored on servers located outside of Canada or Quebec. By using our Services, you consent to this cross-border transfer. We ensure our partners comply with strict data protection standards (such as SOC 2 compliance).

11. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented robust technical and organizational security measures—including SSL encryption, secure API protocols, and restricted access sub-accounts—designed to protect your personal information. However, no electronic transmission over the internet can be guaranteed to be 100% secure.

12. WHAT ARE YOUR PRIVACY RIGHTS? (INCLUDING QUEBEC LAW 25)

Depending on your region, including Canada and Quebec, you have specific rights over your personal data:

Right to Access and Portability: Request a copy of the personal data we hold about you.
Right to Rectification: Request corrections to inaccurate data.
Right to Erasure (Right to be Forgotten): Request the deletion of your data.
Right to De-indexing (Quebec): Request that your personal information cease to be disseminated or that hyperlinks associated with your name be de-indexed.
Right regarding Automated Decision-Making: To be informed if decisions are made solely by automated AI processes and to request a human review.

To exercise these rights, submit a request to our designated Privacy Officer at privacy@frontlineagency.ca.

13. US STATE SPECIFIC PRIVACY RIGHTS

If you are a resident of California, Colorado, Virginia, or other states with recognized privacy frameworks, you have rights regarding your personal information. Unlike generic policies, Frontline Agency transparently acknowledges the processing of the following data categories in the preceding twelve (12) months:

Category	Examples	Collected
A. Identifiers	Real name, phone number, email address, IP address.	YES
B. Personal Information (CA Law)	Name, contact info, financial/billing information.	YES
C. Protected Classifications	Gender, age, date of birth, race, marital status.	NO
D. Commercial Information	Transaction history, service tier purchases, SaaS billing details.	YES
E. Biometric Information	Fingerprints and exact voiceprints.	NO
F. Internet / Network Activity	Browsing history, interactions with our websites and advertisements.	YES
G. Geolocation Data	Device location (IP-based).	YES
H. Audio, Electronic, Sensory Data	Call recordings, voicemails, and AI bot audio processing.	YES
I. Professional / Employment Info	Business contact details to provide B2B services.	YES
J. Education Information	Student records.	NO

Sale of Data: We do not sell your personal data. We only share it with service providers for operational delivery.

14. HOW CAN YOU CONTACT US?

Frontline Agency takes data privacy and Law 25 compliance seriously. If you have questions about this notice or wish to exercise your data rights, contact our designated Privacy Officer:

Data Protection / Privacy Officer
Frontline Agency
Email: privacy@frontlineagency.ca
Website: https://frontlineagency.ca

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