Privacy Policy

FrontRow, a Wyoming Company “we” “us” provides content creators (“Creators”) the tools needed (the “Service”) to create communities (“Community”) to have discussions, share content, courses, ideas, and merchandize with people and companies that join (“Members”) or follow their Community. Creators, Members and those who access a Community or the Service shall be collectively referred to as “Users.” 

In providing the Service, we collect information from Users, including the content, videos, communications, Contact Information (defined below) and personal information they share on the Service (“Data”). This Privacy Policy (this “Privacy Policy”) explains how we collect Data from Users and how we use and share that Data to create a customized experience for all Users. By using the Service, whether as a Creator, Member, or other User, you (“you”, “your”) agree to be bound by this Privacy Policy, as well as our Terms of Service. We reserve the right to modify this Privacy Policy, as well as our other policies–found at frontrow.cc (collectively (“Policies”)–from time to time without giving advance notice. If we change our Privacy Policy in a way that substantially lessens our commitments to you, we will provide notice to your registered email address. If you do not want FrontRow to use or share your Data, as set forth in this Privacy Policy, you should not use our Service.

1. Introduction. FrontRow is a SAAS company that works with content creators, providing them with apps, websites, and tv apps.  Our Service gives Creators a way to establish a Community. When a Creator creates a Community, they may invite other Members and Users to connect with them in the Community. Creators can customize their Community and use their Community to organize activities, have discussions, share content, offer courses, sell merchandise and more.

2. Data Storage and Retention. We securely store your Data with Snowflake, Inc., who uses Amazon Web Services, Inc., located at 125 Technology Dr, Irvine, CA 92618. We reserve the right to retain your Data as long as you maintain an Account (as defined in our Terms of Service) with us. When you close or delete your Account, we will delete all of your Data, including any videos or other content, within a reasonable time. We may retain your Data for any lawful business purposes.

We will retain deleted Data, such as videos or content, for a short period of time after deletion. We do this in the event the Data was removed by accident and you would like to reverse the deletion. If your Data has been made publicly available, it may be discoverable by search engines. We have no control over the sharing of your Data over search engines and it may remain discoverable by those search engines for a time or indefinitely.

3. Data Protection. We employ various standard means to protect your Data from unauthorized access, misuse or loss. These means include encryption, pseudonymization, and aggregation. Regardless of the means we have in place to protect your Data, no network, email, or online transmission is completely secure and full-proof. Accordingly, you share your Data at your own risk and should be careful what Data you decide to share and to protect your Data.

4. Privacy Choices. You have the right to decide what Data to provide us and how your Data is used. These choices include the following:

1. You may open or close an Account.
2. You may choose not to provide certain optional information requested during the Account or Profile (as defined in the Terms of Service) creation process. It should be noted that failure to provide mandatory information, like your name in email address, would prevent you from creating an Account.
3. You may choose not to participate in certain Communities with certain Creators.
4. You may change or correct any Data you provide to us. 
5. If you are a Creator, you can choose to post or take down your videos or content.
6. You can limit the use of cookies.
7. You can change your privacy settings.

5. Opt Out. To enhance your experience on our Service and to provide you with materials and services that may interest you, we, and Creators may send you marketing emails or messages. In addition to the above privacy choices, you may opt out of these email messages by clicking on the opt out link at the bottom of the message.

We may use network advertisers to serve advertisements on non-affiliated websites or other media (e.g., social networking platforms). This enables us and these network advertisers to target advertisements to you for products and services in which you might be interested. Ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, pixels, LSOs and other tracking technologies (defined below as “Cookies”) to measure the effectiveness of their ads and to personalize advertising content to you. These Cookies and other technologies are governed by each entity's specific privacy policy, not this one. We may provide these advertisers with information, including personal information, about you.

Users may opt out of many ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our website or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject Cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

6. Automatic decision-making. If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you. We do not engage in fully automated decision-making that has a legal or otherwise significant effect using User Data.

7. Disputes. If you have a dispute with a Creator or Member regarding your Data (“Member Disputes”), you should contact that Creator or Member directly. Member Disputes are private and we cannot control all interactions between Members. Notwithstanding, if you believe that a Creator or Member has violated your privacy rights you should contact us. 

8. Other User’s Data. By using the Service, you agree that when you come in contact with other User’s Data, you agree to be bound by this Privacy Policy and any Applicable Laws (as defined in the Data Protection Addendum).

9. Data Collection. User Data is collected and used in various ways, depending on an individual User’s plan and the plan features they pay for (“Plan”), how they gain access to the Service, the information they decide to share in their Account and on their Profile (as defined in the Terms of Service). We collect Data in the following ways: a) Data you provide to us; b) Data we capture and c) Data collected by third parties.

10. Data You Provide to Us. When you, as a Creator or Members or other User create an Account with us, you are asked to provide information about you, including, but not limited to the following: 

1. Name, Email Address and Contact Information (collectively “Contact Information”). To set up an Account, you must provide your name and date of birth. An alias or Profile name can be created but we must have your legal name to set up an Account. We also require a valid email address so that we and any Creators you follow, can contact you and provide information regarding content, products or services that may interest you. You are responsible for keeping a valid email address up to date. We may also request other contact information, like a valid mailing address. We will not share your Contact Information with any third parties without your consent. If you set up an Account through a third party platform, like Facebook for example, you give us permission to access the profile you have with that third party, including any information on that profile, like your photo. The information and Profile you maintain with those third parties will become part of your Profile with us.

2. Financial Information. As part of the registration process, you may be asked to provide financial information, including a valid credit card (“Financial Information”). This Financial Information is used to pay for your Plan or any purchases you make through the Service. We will not share your Financial Information other than with third party credit card processors we may use to charge your Account.

3. Profile. When you create an Account you will be asked to create a Profile.  In your Profile you can identify topics of interest and create a brief bio. In your Profile settings you are able to determine what things to keep private, between you, us, and Creators, and what things to share with the public or your Community. We, and any Creator you follow or pay for access to, may use the information in your Profile to create a customized experience for you.

4. Privacy Choices. In your Account settings you can adjust your privacy settings.

5. User Activity: While using the Service, Users engage with Creators and others in Communities. In those Communities, Users and Creators may share thoughts, ideas, and feelings, content or other Data. Any information you share in a Community may become public knowledge. We make no representations about protecting any information or Data you make publicly available to Creators, Members, Users or Communities. If you send us a review, post content or respond to a survey, we collect your submission Data.

6. Capture Forms. You may submit Data through a capture form set up by the owner or processor of a video or content, including us or a Creator. This information will be shared with us and any applicable Creator.

11. Data We Capture. When you use our Service, regardless of whether you have an Account, there is certain Data that we collect automatically. When you use our Service, we can determine your approximate location from your IP address. We may use this information to connect you with Creators or Communities that are close to you or for our own analytics. We also collect Data regarding the date and time of your visits, the pages you visit, browser type, the content you clicked on, the content you liked or disliked, content you paused, played back or resumed, operating system, device information, platform, originating IP address, the full Uniform Resource Locator (URL) clickstream to, through and from our sites, including any search queries you entered to reach our Service. We may also collect Data regarding your search queries on our Service. We use this information to determine where Users spend their time on the Service, and the number of unique visitors in different sections and Communities on the Service. 

12. Third Party Data Collection. We engage third parties to help understand and analyze how people reach and use our Service. These third parties include, but are not limited to Rutterstack.com (a CDP-cloud provider) and BugSnag, and other reputable third parties, that may change from time to time. In some cases this Data is collected automatically but we may also choose to share this Data with these third parties. Additionally, Creators may use their own cookies or beacons or engage third parties to employ these tools to target ads to you when you are on the Service or when you visit other sites. By joining a Community, you agree that a Creator may employ these types of tools to advertise to you.

As part of your use of the Service, you may come in contact with third party links to websites (“Other Sites”). We cannot control the use of your Data on these Other Sites. While we may permit links to Other Sites on the Service, we do not endorse any of these Other Sites. Additionally, this Privacy Policy does not apply to Other Sites. To verify how your Data is being used on these Other Sites, you may review their privacy policy or other policies.

13. Cookies. Cookies are data from a site that is stored within your web browser that the site can retrieve at a later time (“Cookies”). Cookies are used to tell the server that a user has returned to a site, to aggregate web traffic and usage, to improve our Service, to deliver content which suits your interests, and for other lawful reasons. By using our Service, you also agree to our use of Cookies or other similar technologies.

We may also use web beacons to deliver or communicate with Cookies and other technologies to identify your device, app, or browser, like unique identifiers, pixels, JavaScript, LSOs, local storage and other tracking technologies (beacons, other technologies and Cookies shall be collectively referred to as “Cookies”). These web beacons, also known as GIFS, are used to track the journey of a user through our site and check what content a user has accessed.

Our Service uses, or may use, the following types of Cookies:

1. Necessary Cookies: Our site would not function properly without some necessary Cookies. These Cookies allow you to move through our Service and use its features, including basic things like page navigation, and logging in.

2. Preference Cookies: These Cookies help customize the User experience by allowing us to remember the preferences you have chosen like your language of preference and region.

3. Performance and Analytics Cookies: These Cookies help us understand how Users interact with our Service–meaning what pages Users visit and do not visit and where they spend their time. These Cookies collect and report anonymous Data which helps us improve our Service.

4. Marketing Cookies. These Cookies track your movement across sites in order to display advertisements that are relevant to you and your interests. We may share the information we collect from these Cookies with third parties.

5. Security Cookies. These Cookies help us to protect the security and integrity of the Service. We may share the information we collect from these Cookies with third parties.

You may opt out of any Cookies that are not necessary by “declining” Cookies. You can also delete Cookies on your computer or prevent Cookies from being placed on your browser. It should be noted that declining, deleting or preventing Cookies can lead to a less smooth and customized user experience, less relevant advertisements and may require manual entry of user preferences each time you use our Service.  

When using our Service, you will have access to links and advertisements from Other Sites. These Other Sites may use their own Cookies. We have no control over the Cookies used by these Other Sites. In order to understand how these Other Sites use your Data, you should see their privacy and/or Cookie policies.

14. Why We Use Your Data. We use your Data for many legitimate business purposes. Specifically including the following:

1. Customization and Improvement. We use your Data to verify Account usage. We use your Data to understand how you use our Service and, to the extent possible, to customize our Service to your needs. This includes Data regarding your search engine results or viewing choices so that we can suggest further videos, creators, courses, products and services that may interest you. We may also use your Data to fix any bugs or other problems that arise.

2. Communication. We use your Data to communicate with you regarding your Account and use of the Service. We also use your Data to allow others, including Creators, Members and other Users to communicate with you. 

3. Marketing. We use your Data to customize the types of advertisements you see while using the Service. We may use your Data to provide you with news and special offers and general information about other goods, services and events. We may now or in the future allow advertisers and corporate partners to post content on the Service and provide links to sites and content of third parties as a service to those interested in this information. We do not currently but may, after notice to Users, share your anonymized personal information with third parties for their direct marketing purposes. Creators may share your personal information with third parties for direct marketing purposes, to see whether they share your Data, you should review their privacy policy.

4. Conduct the Service. We use your Data to operate the Service–this includes, but is not limited to, loading the Service accurately for you, charging your Account and making you aware of offers and updates. This may include passing your Financial Information to third party Service Providers to fill any orders you have made. We use your Data to contact you about changes to the Service. We use your Data to allow you to participate in interactive features of the Service. We use your Data to provide customer service and to detect, prevent and address technical issues.

5. Business Purposes. We may use your Data for our own business purposes, including accounting, financial reporting, tax filings, business planning, or any other legitimate business purpose.

6. Security Purposes. We use your Data to prevent, detect or investigate security concerns on the Service, including fraud. We use your Data to comply with applicable laws, regulations, or industry standards.

15. Lawful Basis. Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your Data under the following lawful bases:

• Your consent;
• The performance of the contract between you and us;
• Compliance with our legal obligations;
• To protect your vital interests;
• To perform a task carried out in the public interest;
• For our legitimate interests, which do not override your fundamental rights and freedoms.

16. Data Sharing. We may share your Data with, and make your Data available to, Creators, Members, Users or third parties. This section explains with whom we share your Data and the situations in which the Data may be shared.

1. Your Actions. We allow you to share your Profile and Data, including videos, comments, and other content, according to your use on our Service, based on your privacy settings.

2. Messages and Searches. Other Users will be able to search for you and communicate with you based on your location, Profile, and Community membership(s).

3. Creators. When you join a Community, the Creator of that Community will have access to your name and contact information. In order to facilitate Member interaction, a Creator has access to your usage activity in their Community. They can see the comments you make and can see the reaction of other Members to your comments. By joining a Community, you consent to Creators communicating with you either through the Service or outside of the Service. Creators are required to comply with this Privacy Policy, our Terms of Service and other Policies, but may have additional policies and conditions of their own. 

4. Aggregated Data. We may aggregate your Data and use it to more accurately describe our business to our third party service providers, business partners, investors, or for any other lawful purpose.

5. Service Providers. We engage multiple third parties to help us operate our Service. We may share your Data with third party Service Providers (defined below) that help us operate the Service. These third party Service Providers, include, but are not limited to, hosting services, payment processors, email service providers, shipment vendors, content delivery networks, and more (collectively “Service Providers”). When we share your Data with these third parties Service Providers, we only provide the Data they need to perform the function they are hired to do. These third party Service Providers have agreed to abide by this Privacy Policy and by our Data Protection Addendum (or one of similar). The third party Service Providers we work with are listed below including a link to their privacy policy:

1. Amazon Web Services, Inc.

1. Privacy Policy: https://aws.amazon.com/privacy/?nc1=f_pr

1. Bugsnag, Inc.

1. Privacy Policy: https://smartbear.com/privacy/

1. RudderStack, Inc.

1. Privacy Policy: https://www.rudderstack.com/privacy-policy/

1. Stripe, Inc.:

1. Privacy Policy: https://stripe.com/privacy

1. Snowflake, Inc.

1. Privacy Policy: https://www.snowflake.com/privacy-policy/

6. Legal Disclosures. We may share your Data if legally required to do so, or if we believe we are legally required to do so. This includes any official requests we received from government authorities or parties to a legal proceeding, including but not limited to a warrant, subpoena, court order, or other requests. We may share your data if we believe a person’s life may be at risk or to report suspected crimes like content suspected of exploiting minors. We may disclose your Data to prevent fraud. We may also disclose your Data if there are legal claims against us or one of our Users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we will provide the Data to the affected Creator or User, including any of your communications to us. We may disclose your Data to protect our property rights, or the legal rights of our affiliates, customers or third party Service Providers, or to protect against potential legal liability. 

17. Children’s Privacy. You must be at least 16 years of age or the age of majority in the state or country where you live, whichever is greater, to create or participate in a Community. If you want to use the Service for commercial purposes you must be 18 years or older. If a parent or guardian allows a child that does not comply with these requirements to use their Account, that parent or guardian is responsible for monitoring and supervising the child’s use of the Service. We do not knowingly collect information on Users that are under the above-stated ages.

18. EEA Privacy Rights. If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information below.

Frontrow is based in the United States but we provide our Service in other countries. In using our Service outside of the United States, your Data will be transferred to and processed in the United States. In such cases, the laws of the United States may not be as comprehensive or protective of those in your county. Pursuant to GDPR, we can transfer your Data from your country to the United States based upon the legal basis of “legitimate business purpose” because without transferring your Data to the United States we could not provide the Service and would not be able to fulfill our contractual obligations to you.

To better understand your rights as a resident of the EEA see our GDPR Privacy Notice.

19. CCPA Privacy Rights. If you are a resident of California, you have the right to access the Personal Information we hold about you (also known as the ‘Right to Know’), to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. To better understand your privacy rights as a resident of California, please see our California Privacy Notice.

If you would like to designate an authorized agent to submit these requests on your behalf, please contact us at the address above.

20. How to Reach Us. If you have any questions, complaints or inquiries regarding your privacy please contact us at:

FrontRow

c/o Data Protection Officer

30 N. Gould St., Ste. R, Sheridan, WY 82801

greg.lyle@frontrow.cc