Privacy Policy Last Updated: April 2, 2024

New Frontier Markets, LLC (“Company,” “New Frontier Markets,” “we,” or “us,” or “our”) operates this website and any mobile applications on which it is posted (the “Site”) and cares about your privacy and recognizes the importance of protecting your personal information. This Privacy Policy (“Policy”) describes the kind of information we may collect during your visit to the Site. By accessing the Site, you agree to our collection and use of personal information as described in this Policy and in our Terms of Use https://nfm.exchange/termsofuse.

Our Services
New Frontier Markets provides a marketplace where project developers (“Sellers”) can offer voluntary carbon offset credits (“VCOCs”) for sale to institutional or retail purchasers (“Buyers”).

New Frontier Markets is based in and operates in the United States. Our Site is intended for U.S. residents only. By using our Site and submitting your personal information to New Frontier Markets, you acknowledge and agree that your personal information may be stored and processed in the United States. If you access our Site from outside of the United States, you acknowledge and agree that your personal information may be transferred to, processed, and stored in the United States.

Personal Information We May Collect and Your Role on the Site
We collect your personal information when you visit our Site, download and interact on any of our mobile applications, request information about our services, register to be on a contact or mailing list, submit comments, or otherwise interact with the Site, email us, call us, or when you voluntarily provide information to us through the Site. We may also collect your personal information from third parties that interact with you directly on our behalf.

The information we collect varies by role and you may be required to provide basic account information to use all the features of the Site.

The information we collect may include personal information such as your name, email address, address of your business/property, location of a project, your home or billing address, or telephone number. We may also collect records of VCOCs you purchased or considered, projects you reviewed, and payment information, as well as recordings of calls to our customer service line (for quality assurance purposes). In addition, certain personal or business information may be required for your transactions or projects to be maintained on a carbon offset registry, including full legal name, and in some instances date of birth and/or government-issued ID numbers.

We may also collect personal information from you automatically when you visit our Site. This information may include your IP address, your device and browser type, information about your interaction with our Site, and advertisements.

How We May Use Your Personal Information
We use your personal information to provide you with the information you request or to fulfill the transactions you offer and make on the Site. We may also use personal information to perform know-your-customer validations, contact you from time to time to provide customer support, required notices, advertisements and marketing promotions, and offers about projects, products, or services we think may be of interest to you, including our own or those of our affiliates.

We also use personal information about your use of our Site to monitor and improve our Site; for internal business analysis; to prevent fraud or activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others.

How We May Share Your Personal Information
We may share your personal information with carbon offset registries and service providers that help us operate our business, including through payment processing, verifying Buyer or Seller information, managing user information and providing customer service, facilitating scheduling, facilitating email communications, providing security services and cloud-based data storage, hosting our Site and assistance with other IT-related functions, advertising and marketing (including sending communications on our behalf), providing analytics information, and providing legal and accounting services, among other business functions.

We utilize third-party payment processors or financial institutions to complete transactions and to perform know-your-customer validations.

We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our or others’ rights, property, or safety, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity, or other restructuring.

Cookies and Analytics
We may use cookies, pixel tags, web beacons, and other similar tracking technologies (“tracking technologies”) to automatically collect information through the Site. Tracking technologies are small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our Site. We may use these tracking technologies to help identify irregular behavior, prevent fraudulent activity and improve security, as well as to make it possible for you to save your preferences and help us understand how you interact with the Site.

We also allow third parties to use tracking technologies on the Site for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests, and to assist in determining if you require assistance or are having problems navigating on our Site. Some of these third parties are our service providers that may use certain technologies to record your interactions with the Site, including without limitation, your keystrokes, mouse clicks, screen touches, and information about when, how, and from where you accessed the Site. This information is used to help us manage our Site and provide a good user experience. Other third parties use the tracking technologies to collect information about how you interact with our Site and other websites or mobile applications and advertisements across the Internet to provide advertising that is tailored to your interests and which may appear on our Site or on other websites, mobile applications, or platforms.

You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at allaboutcookies.org.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting our website. For information about Google’s privacy practices, please refer to the Google Privacy Policy.

Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.

California Shine the Light California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of personal information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year. We do not disclose personal information to third parties for their direct marketing purposes.

Personal Information of Minors
Our Site and services are not directed to minors under the age of 18 and we do not knowingly collect the personal information of minors under 18.

How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer, or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

Other Websites and Social Media Buttons
Our Site may contain links to other websites or social media buttons. We are not responsible for the privacy practices or the content of those websites or social media platforms. This Policy applies only to our business and the personal information we collect.

Changes to This Policy
We will review and update this Policy as required to keep current with rules and regulations, new technologies, and security standards. We will post those changes on the website or update the “last updated” date of the Policy.

Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at (267) 738-1752.

Contact Us
If there are any questions regarding this Policy, or to request a copy of this Policy in another format, you may contact us using the information below.

New Frontier Markets LLC
c/o Frontier Carbon Solutions Services LLC
3625 North Hall Street, Suite 760
Dallas, TX 75219
Attention: Legal Department
Email: legal@nfm.exchange