Table of Contents

1. Introduction 2. About Us 3. Jurisdiction and Governing Law 4. What Are Cookies? 5. Explicit Consent 6. Purpose of Data Collection 7. Why We Use Cookies 8. Types of Cookies Utilized 9. Specific Cookies Deployed and Data Captured 10. Data Utilization 11. Data Retention Periods 12. Data Anonymization 13. Third-Party Integrations 14. Cooperation with Law Enforcement 15. User Control and Cookie Management 16. Opt-Out Consequences 17. Data Sharing and Transfers 18. International Data Transfers 19. Legal Framework 20. California Notice 21. User Rights in Case of Prosecution 22. Data Subject Rights 23. Penalties for Non-Compliance 24. Updates and Notifications 25. Accessibility 26. Dispute Resolution 27. External Audits and Compliance 28. Data Encryption Methods 29. Geographical Considerations
30. Data Breach Protocol 31. User Rights 32. Contact Information 33. Ethical Guidelines 34. Transparency Reports 35. Grievance Redressal 36. Advanced Security Measures 37. Consent Mechanism 38. Data Processing Partners 39. Legal Obligations 40. Cookie Renewal 41. Source Protection 42. Data Retention and Deletion 43.InternationalLaws and Regulations 44. Accessibility Features 45. Contact for Accessibility Issues 46. Data Subject Rights  47. Penalties for Non-Compliance 48. Legal Recourse 49. Whistleblower Protection 50. Data Security Training 51. Data Security Audits 52. Data Breach Response Team 53. Data Processing Records 54. Review and Approval 55. Contact for Ethical Concerns 56. Final Provisions

1. Introduction

FrontPage Guardian, a subsidiary of FrontPage News Media, is committed to safeguarding your digital privacy. This comprehensive Cookie Policy outlines the types of cookies we use, the data they collect, and the security measures in place to protect this data. By using our website, sub-domains, webshop, and mobile applications, you consent to the practices described herein.

2. About Us

FrontPage Guardian is a multi-faceted organization with a diverse clientele. Our main office is located in Malaga, Spain, but our servers are strategically positioned in the USA, Mexico, and Asia. We offer various services, including a phone and web app that allow for different types of people searches. We also have access to some criminal databases, and as such, we store a wide range of personal information, including fingerprints and other data that can be found in criminal databases.

3. Jurisdiction and Governing Law

This Cookie Policy is governed by the laws of Spain. Our head office is located in Malaga, Spain, and all our contracts are drafted accordingly to Spanish laws.

4. What Are Cookies?

Cookies are small data files stored on your device when you visit our digital platforms. They enhance your user experience by remembering preferences, session information, and other vital metrics.

5. Explicit Consent

We obtain explicit consent from users during their first visit to our digital platforms. A pop-up window will appear, detailing the types of cookies used and the data collected. Users must agree to proceed.

6. Purpose of Data Collection

The data collected serves multiple purposes, including facilitating online donations, tracking user behavior for analytics, and enhancing the user experience by remembering preferences. It is also used for journalistic investigations and legal proceedings, especially in cases involving minors or organized crime.

7. Why We Use Cookies

Cookies serve multiple purposes, such as facilitating online donations, tracking user behavior for analytics, and enhancing the user experience by remembering preferences. They are essential for the functionality and improvement of our digital platforms.

8. Types of Cookies Utilized

Session Cookies: Temporary cookies are deleted when you close your browser. They facilitate functionalities like session continuity and login persistence.
● Persistent Cookies: Remain on your device beyond a single session, recognizing returning users and enabling content customization.
● Third-Party Cookies: Set by external organizations like Google Analytics and social media platforms, these cookies are used for tracking user interaction across multiple websites.

9. Specific Cookies Deployed and Data Captured

We use various types of cookies to collect a wide range of information:
● Google Analytics Cookies (_ga, _gid, _gat): Collects data on user interaction,vreferral source, page interaction metrics, device specifications, geolocation data,vand IP address.
● User Preference Cookies (ui-state, lang): Stores user interface states andvpreferences.
● Security and Authentication Cookies (csrftoken, auth_token): Maintains data integrity and confidentiality, including fingerprints and other data found in criminal databases.

10. Data Utilization

We use the collected data for:
● User behavior analysis
● Targeted content delivery
● User experience enhancement
● Compliance with legal obligations
● We never sell or give out information to anyone who is not part of our company or sister companies.

11. Data Retention Periods

Data collected through cookies is retained as follows:
● Google Analytics Data: 26 months
● User Preferences: 12 months
● Security Data: Indefinitely, for legal compliance.

12. Data Anonymization

When applicable, data used for reporting or selling stories is anonymized to protect the
identities of individuals involved.

13. Third Party Integrations

We collaborate with third-party services like Google Analytics and social media plugins to augment our data analytics capabilities. These services have their own cookie policies, which we recommend reviewing for additional information.

14. Cooperation with Law Enforcement

We may share information with law enforcement agencies for the purpose of prosecuting criminal activities, especially those involving minors or organized crime, as per the wishes of the person(s) who provided the tip.

15. User Control and Cookie Management

Users can control and/or delete cookies at any time. They can also opt-out where legally possible. However, we are required by law to retain certain information for specific periods.

16. Opt-Out Consequences

Users who opt-out may lose some functionalities, such as saved preferences and session continuity.Users who opt-out may lose some functionalities, such as saved preferences and session continuity.

17. Data Sharing and Transfers

Data captured through cookies may be shared within the FrontPage News Media network for analytics and improvement of services. All cross-border data transfers adhere to legal frameworks and are conducted through secure channels.

18. International Data Transfers

Given the global nature of our operations, data may be transferred across international borders. We employ stringent security measures, such as end-to-end encryption and secure tunneling protocols, to ensure the integrity and confidentiality of data during transit

19. Legal Framework

We operate in compliance with the General Data Protection Regulation (GDPR) for European users and the California Consumer Privacy Act (CCPA) for residents of California, among other jurisdiction-specific laws.

20. California Notice

In accordance with the California Consumer Privacy Act (CCPA), residents of California have specific rights regarding their personal information. This section serves as the California Notice and provides additional details about how we collect, use, and disclose personal information.

21. User Rights in Case of Prosecution

Users have the right to be informed if their data is used in a legal case. They can also request access to, correction, or deletion of their personal data stored through cookies.

22. Data Subject Rights

Users have the right to request access to, correction, or deletion of their personal data stored through cookies. To exercise these rights, please contact us at privacy@frontpageguardian.org.

23. Penalties for Non-Compliance

Users who do not comply with our Cookie Policy will not be able to use our services. We reserve the right to limit or terminate access to our platforms for non-compliance.

24. Updates and Notifications

We reserve the right to modify this Cookie Policy at our discretion. Users will be notified of any changes through our website or via email.

25. Accessibility

Our website is available in English and Spanish and is accessible to people with hearing, vision, or other impairments. For any queries or concerns, you can contact us via email at policy@frontpageguardian.org or phone at +34 123 54 747.

26. Dispute Resolution

Any disputes arising out of this Cookie Policy will be resolved in accordance with Spanish law and will be subject to the jurisdiction of the courts in Malaga, Spain.

27. External Audits and Compliance

FrontPage Guardian undergoes periodic third-party audits to ensure compliance with data protection laws and cybersecurity standards. Our data handling practices are certified under ISO/IEC 27001:2013 and other relevant certifications.

28. Data Encryption Methods

We employ advanced encryption algorithms, such as AES-256 and RSA, to secure your data.

29. Geographical Considerations

Our servers are located in the USA, Mexico, and Asia. Data protection laws may vary by jurisdiction, and we comply with all local regulations.

30. Data Breach Protocol

In the event of a data breach, we will notify affected users within 72 hours, in compliance with GDPR guidelines.

31. User Rights

We reiterate our users’ rights to manage, access, and control their personal data, including data collected through cookies, emphasizing our commitment to user empowerment and privacy.

32. Contact Information

For any queries or concerns regarding this Cookie Policy, please contact our Data Protection Officer at dpo@frontpageguardian.org.

Contact for Legal Queries

For legal concerns related to this Cookie Policy, please contact our Legal Department at legal@frontpageguardian.org.

Ethical Guidelines

We adhere to stringent ethical guidelines, especially concerning the protection of sources and minors.

34. Transparency Reports

We publish periodic transparency reports detailing requests from law enforcement or other agencies for user data.

35. Grievance Redressal

Users may file complaints or seek clarifications by contacting our Grievance Redressal Officer at grievances@frontpageguardian.org.

36. Advanced Security Measures

We employ advanced encryption algorithms, real-time monitoring, and intrusion detection systems. Our servers are located in secure facilities in the USA, Mexico, and Asia, and we adhere to stringent data protection laws.

37. Consent Mechanism

Upon first visiting our website, users will be presented with a detailed consent mechanism, outlining the types of cookies used, the data collected, and the purposes for which the data will be used. Users must actively consent to the use of cookies and can renew their consent annually.

38. Data Processing Partners

We receive tips and store some data via secure channels like TOR and SecureDrop. These platforms serve as our data processing partners and are subject to their own stringent security measures.

39. Legal Obligations

In cases where the tipster wishes for us to assist in legal proceedings, we collect evidence and cooperate with authorities. We also undertake our own prosecutions for larger issues like organized crime or pedophile networks.

40. Cookie Renewal

Users will be prompted to renew their cookie consent annually to ensure continued compliance with our Cookie Policy.

41. Source Protection

All tips are stored on servers without internet connections to prevent unauthorized access. We do not disclose any sensitive information about our sources and are protected by various laws to keep our sources confidential.

42. Data Retention and Deletion

We adhere to strict data retention policies, keeping data only for as long as is necessary for the purposes outlined in this policy. Users have the right to request the deletion of their data, subject to legal obligations that may require us to retain certain information for specific periods.

43. International Laws and Regulations

Numerous international laws and regulations that protect the privacy of our sources bind us. These laws enable us to resist subpoenas and other demands for information that could compromise the safety and anonymity of our tipsters.

44. Accessibility Features

Our digital platforms are designed to be accessible to people with disabilities. We comply with the Web Content Accessibility Guidelines (WCAG) to ensure that our website is accessible to people with vision, hearing, and other impairments.

45. Contact for Accessibility Issues

For any accessibility related queries or concerns, please contact our Accessibility Officer at accessibility@frontpageguardian.org.

46. Data Subject Rights

Users have the right to legal recourse if they believe their data protection rights have been violated. We provide information on how to seek redress and enforce rights under applicable laws.

47. Penalties for Non-Compliance

Failure to comply with this Cookie Policy may result in the user being unable to access our services. We reserve the right to limit or terminate access to our platforms for non-compliance

48. Legal Recourse

Users have the right to legal recourse if they believe their data protection rights have been violated. We provide information on how to seek redress and enforce rights under applicable laws.

49. Whistleblower Protection

We offer robust protection for whistleblowers and sources, ensuring their anonymity and safety. This is in line with our ethical guidelines and international laws that protect the confidentiality of journalistic sources.

50. Data Security Training

All our employees undergo rigorous data security training to ensure they are well-versed in the best practices for data protection and confidentiality.

51. Data Security Audits

We conduct regular internal and external audits to assess the effectiveness of our data security measures. These audits help us identify any vulnerabilities and take corrective action promptly.

52. Data Breach Response Team

We have a dedicated team responsible for managing data breaches. In the event of a breach, this team will take immediate action to contain the breach, assess the impact, and notify affected parties in compliance with legal requirements.

53. Data Processing Records

We maintain detailed records of all data processing activities, including the categories of data processed, the purpose of the processing, and any third parties involved in the processing.

54. Review and Approval

This Cookie Policy is subject to periodic review and approval by our legal team to ensure it remains compliant with current laws and regulations.

55. Contact for Ethical Concerns

For ethical concerns related to our data practices, users can contact our Ethics Committee, which oversees adherence to ethical standards and addresses concerns with integrity and fairness.

56. Final Provisions

This Cookie Policy is an integral part of our Terms of Service and Privacy Policy. By using our services, you agree to comply with all the terms outlined in this policy.

For any further questions or clarifications, please contact us at policy@frontpageguardian.org or call us at +34 123 54 747.