FRM Client Portal Privacy Notice

Last Revision Date: March 1, 2018

Capitalized Terms are used in accordance to the definition posted in FRM’s Terms of Service located at

The Portal ( (the “Portal”) is a service made available from Financial Risk Mitigation, Inc. (“FRM”) to Subscriber. Subscriber has accepted and agreed to FRM’s Terms of Service or may have other written agreement governing the Terms of Service, including access to the Portal.  Users of the Portal are approved by Subscriber or by way of Subscriber’s implied consent for FRM to approve such Users for access to the Portal based on having the same email domain as the Subscriber, belonging to the same company as the Subscriber, belonging to an affiliate of the Subscriber, providing legal services to the Subscriber, or providing other services to the Subscriber.  Users of the Portal generally are employees, contractors, or agents of the Subscriber engaged in commercial transactions on behalf of the Subscriber.

Users are entitled to access the Portal as per the Terms of Service or other written agreements by and between FRM and the Subscriber. In the course of using the Portal, a User may provide their personal information.

Subsidiary, Affiliate, and Third-Party Websites. This privacy notice applies to this Portal only and only to a User’s personal information. To the extent the Portal permits a User to link to or otherwise access other websites, separate privacy policies may apply to those linked websites. Those separate privacy policies may contain terms different than those contained in this privacy notice, and a User’s access to and use of such linked websites are not governed by this privacy notice.

FRM expressly disclaims any and all responsibility for User’s access to and use of such linked websites, as well as, for any use of the information that User may provide, or any information that may be collected about User, at such linked sites.

Cookies. The Portal makes use of session cookies to provide for time zone offsets, session locale settings, session identification, and session termination. The Portal does not make use of persistent cookies.

Type of Personal Information. Using some sections of the Portal requires registration. The information required to register may include, legal name, work address, telephone number, mobile number, facsimile number, email address, company or employer, password, and selection of non-wallet-based challenge questions and answers.

FRM tracks User access to the Portal and its Content including dates and times of access, the IP address attempting access to the Portal, and the specific Content accessed.

FRM also tracks the browser attempting to access the Portal and operating system, but FRM generally does not try to tie back such information to the User’s account, except as may be required to provide technical support to a User to access the Portal.

Purpose of Collecting Personal Information. The purpose of collecting personal information is to authenticate the User’s identity as an entitled User of the Portal, to prevent unauthorized intrusion and access, and in the event of a compromise to understand the scope of the Content and systems that may have been compromised.

Personal information may also be used to deliver Content from the Portal to the User or to other Users associated with the same Subscriber.

Personal information of User may also be used for other general FRM marketing and record keeping purposes.

Disclosure of Personal Information. FRM treats your personal information as Confidential Information, subject to the exclusions noted above and the exclusions contained in 2(l) of the Terms of Service.

FRM may disclose and transfer your personal information during a merger or during the divestiture of company assets. However, FRM will require any acquiring organization to agree to protect the User’s personal information as Confidential information.

FRM may share your personal information with affiliated companies or with third party service providers to accomplish the purpose for which the information was collected in the first instance.

Cross Border Flow of Data. FRM is a United States Corporation with operations in many other countries. From whatever place a User provides personal information to this Portal (or from which information is collected), the User should expect that it will be processed in the United States. A User’s registration for the Portal constitutes a User’s consent for any cross-border data transfer resulting from such use.

Integrity, Protection and Retention of Your Personal Information. FRM makes uses of commercially reasonable security practices to safeguard User’s personal information and to protect unauthorized intrusions and access to a User’s personal information. FRM retains personal information of a User submitted on the Portal for a minimum of five (5) years from the date of the last transaction from the User, in accordance with the data retention policy established by the Subscriber, or for longer periods where such personal information may be needed to maintain legal agreements with FRM or fulfill other legal and regulatory obligations. Personal information maintained by FRM on a User during its life cycle is treated as Confidential Information.

Modification to privacy notice. FRM reserves the right to change the terms of this privacy notice at any time. Updated versions of this Privacy Notice will appear on or as a link on the Portal and are effective immediately upon posting. User is responsible for regularly viewing this privacy notice. Continued use of the Portal after such changes constitutes User’s consent to such changes.

Questions & Comments. If you have any questions, please email compliance@frm‐