Commerce Catalysts

Privacy Policy

We take your privacy very seriously. Please read this privacy policy (“Policy”) carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. When we offer goods and services to individuals in the United Kingdom, we are subject to the United Kingdom General Data Protection Regulation (UK GDPR), which is substantially similar to the EU GDPR. The EU GDPR and UK GDPR are referred to collectively as the GDPR. However, please note that as a general rule, we do not process or store personal information about EU or UK residents. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.

We, Us, Our
Front Row, which is comprised of the following group companies: FB Select d/b/a Fortress Brand, Skinner, LLC, d/b/a School House, Taylor & Pond Corporate Communications LLC, Finc3 Marketing Services GmbH, BizMut Marketing GmbH and our product subsidiary Catapult.

Our representative
Alex Michail
amichail@frontrowgroup.com

Personal information
Any information relating to an identified or identifiable individual.

Special category personal information
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.

Sensitive Personal Information
Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, and biometric information.

Biometric Information
An individual's physiological, biological, or behavioral characteristics, including information pertaining to an individual's deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

If a category of information is identified as “Collected” below, we may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, consistent with the examples set forth below:

Examples of Personal Information

Identifiers
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. Collected: YES

Personal information, including the categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, physical characteristics or description, address, telephone number, education, employment, or employment history. Collected: YES

Accounts
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. Collected: NO

Characteristics of protected classifications under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: NO

Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: NO

Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: NO

Internet or other electronic network activity information.
Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. Collected: NO

Geolocation data.
Physical location or movements. Collected: NO

Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information. Collected: NO

Professional or employment-related information.
Current or past job history or performance evaluations. Collected: NO

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: NO

Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: NO

Special Categories of Personal Data pursuant to the GDPR.
Racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; processing of biometric information for the purpose of uniquely identifying a consumer; health or medical information; Sex life or sexual orientation. Collected: NO

If you do not provide personal information required to provide products and/or services to you, it may delay or prevent us from providing those products and/or services to you.

We collect personal information from the following categories of sources:

  • You, directly in person, by telephone, text, or email, and/or our website [and apps];
  • Third party with your consent (e.g., your bank);
  • Third party vendors who provide services to us;
  • Indirectly from cookies, web beacons, etc. on our website and in our emails;
  • Our IT and security systems, including:
  • Door entry systems and reception logs
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems; and [any other relevant systems].

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.


A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we may use (process) your personal information for and our reasons for doing so:

What we use your personal information for:

To provide products and/or services to you.
For the performance of our contract with you or to take steps at your request before entering into a contract.

To prevent and detect fraud.
For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.

Conducting checks to identify our customers and verify their identity and/or authorization; screening for financial and other sanctions or embargoes; other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulations.
To comply with our legal and regulatory obligations.

Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies.
To comply with our legal and regulatory obligations.

Ensuring business policies are adhered to, e.g., policies covering security and internet use.
For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you.

Operational reasons, such as improving efficiency, training, and quality control.
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.

Ensuring the confidentiality of commercially sensitive information.
For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations.

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures.
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price.

Preventing unauthorized access and modifications to systems
For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you and to comply with our legal and regulatory obligations.

Updating [and enhancing] customer records
For the performance of our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations, and for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products.

Statutory returns.
To comply with our legal and regulatory obligations.

Ensuring safe working practices, staff administration and assessments
To comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.

Marketing our services [and those of selected third parties] to:
- Existing and former customers.
- Third parties who have previously expressed an interest in our services.
- Third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers

[Credit reference checks via external credit reference agencies]
For our legitimate interests or those of a third party, i.e., to ensure our customers are likely to be able to pay for our products and services.

External audits and quality checks
For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards and to comply with our legal and regulatory obligations.

Please note that the above table does not apply to special category personal information, which we do not process and would only process with your explicit consent.

We may use your personal information to send you updates (by email, text message, telephone, or mail) about our products and/or services, including exclusive offers, promotions or new products and/or services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it with other organizations outside the Front Row group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at [Privacy@frontrowgroup.com];
  • Using the “unsubscribe” link in emails or “STOP” number in texts; or 
  • Otherwise updating your marketing preferences, where applicable.


We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

We routinely share personal information with:

  • Our affiliates, including companies within the Front Row group;
  • Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts;
  • Third parties approved by you;
  • Credit reporting agencies;
  • Our insurers and brokers;
  • Our banks.


We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers where appropriate to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party unless for a legitimate business purpose under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract.

We do not sell personal information. In the preceding 12 months, we have shared or disclosed for a business purpose the following categories of personal information:

  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, , or other similar identifiers);
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, , address, telephone number, , education, employment, employment history, ;
  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
  • Professional or employment-related information; and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.


We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we may delete or anonymize it.

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

  • The categories of personal information we have collected about you, including sensitive personal information;
  • The categories of sources from which the personal information is collected;
  • The categories of third parties to whom we disclose personal information, if any; and
  • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared; and
  • The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose.

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, please reach out to us at privacy@frontrowgroup.com.

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

  • Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;
  • To perform the following services: 

(1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; 

(2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; 

(3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and 

(4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business; and

  • As authorized by further regulations.

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, please email us at privacy@frontrowgroup.com.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Delete your personal information from our records; and
  • Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information;

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

Right to Be Informed

The right to know or be notified about the collection and use of your personal information.

Right to Access

The right to be provided with a copy of your personal information (the right of access)

Right to Rectification

The right to require us to correct any mistakes in your personal information

Right to be Forgotten

The right to require us to delete your personal information—in certain situations

Right to Restriction of Processing

The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data

Right to Data Portability

The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations

Right to Object

The right to object:

  • At any time to your personal information being processed for direct marketing (including profiling)
  • In certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests

Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

If you would like to exercise any of your rights as described in this Policy, you can do so by emailing us at [ privacy@frontrowgroup.com.

  • Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
  • If you choose to contact us directly, you will need to provide us with:
  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.
  • We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
  • Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

  1. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
  • With our offices outside the EEA;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or
  • Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: [United Kingdom].

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA: United States. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. To obtain a copy of those clauses please contact us.

If you would like further information, please contact us (see “How To Contact Us” below).

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We hope that we  can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred..

This Policy was published and last updated on July 7 2023, and completely supersedes and replaces our previous privacy policies.

We may change this privacy notice from time to time–when we do, we will inform you via our website or other means of contact such as email where appropriate.

Please contact us by mail, email or telephone if you have any questions about this Policy or the information we hold about you.

Our contact details are shown below:
31 Howard Street, 2nd Floor, New York, NY 10013
Privacy@frontrowgroup.com
917-750-0764

Our Data Protection Officer's contact details:
Bjoern Sjut
bsjut@frontrowgroup.com

If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).