GDPR Privacy Notice

Last Updated: November 9, 2023

The European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”) gives natural persons residing in the European Economic Area (EEA) and United Kingdom (UK) (“EEA Residents”) more control over how their personal data (“Data”) is collected, processed, and maintained by organizations.  As a Data Processor (as defined in GDPR), FrontRow, a Wyoming corporation “we” “us” support Creators (as defined in our Privacy Policy), considered Data Controllers (as defined by GDPR),  in staying compliant with GDPR. This GDPR privacy notice (“Notice”) is intended both to help Creators comply with GDPR and assist EEA Residents that use our Service (as defined in our Privacy Policy) in understanding their rights with respect to their Data. Any terms not defined in this Notice are defined in our Privacy Policy.

1. Data Processing Addendum. A key feature in remaining compliant with GDPR is working with vendors and third party service providers that are also in compliance with GDPR. Accordingly, we require that all of the vendors and third party service providers that handle any customer Data enter into our Data Processing Addendum (“DPA”), or an agreement of similar form. If you, as a Creator, determine that you are a “controller” under the terms of the GDPR, you should have anyone handling your customer Data enter into a DPA. This DPA sets forth standards that those handling Data must use to comply with GDPR. We have provided a DPA for you to use with vendors and third party service providers. 

2. Privacy Policy and Settings. As a Member or User of our Service (as those terms are defined in the Privacy Policy), you will provide us with some of your personal Data. You are not statutorily required to provide personal Data in order to use the Service. But without providing some personal Data, we cannot verify your identity. Additionally,  without some Data, you would not be able to order products, and the Service may be less efficient and customized. 

For more information about how we collect and use your data or your customer’s Data, you can see our Privacy Policy. It also explains our legal basis for collecting the Data, how to opt out of such collection, and cookies or marketing, how we collect Data from Users and how we use and share that Data to create a customized experience for all Users. Any term not defined herein is defined in our Privacy Policy. 

3. GDPR Rights. GDPR affords EEA Residents the following rights:

  • Right to Access: The right to request access to any Data that we collect pertaining to you and request copies of such Data. There may be a small fee associated with the request of copies of the Data, depending on the size and complexity of the request.
  • Right to Rectification: The right to request rectification of any Data that we collect pertaining to you or completion of incomplete personal Data.
  • Right to Data Portability: Under certain conditions set forth in GDPR, the right to request that the Data we have collected from you be transferred to another organization or directly to you.
  • Right to Erasure: The right to request that we erase your personal Data which we have collected, including pseudonymised Data.
  • Right to Restrict Processing: Under certain conditions set forth in GDPR, you may have the right to request that we restrict the processing of your personal Data.
  • Right to Object to Processing: The right to object to our processing of your personal Data. An objection may prevent processing even where consent is not the lawful basis for processing. 
  • Right to Withdraw Consent: The right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. If you are a User of our Service, you can withdraw consent from any Creator you have signed up with.
  • Right to Lodge Complaint: The right to lodge a complaint with the Supervisory Authority. Should you wish to file a complaint regarding your GDPR rights or if you feel we have not addressed any concerns you have in a satisfactory manner, you can contact the Information Commissioner’s Office regarding your concerns. You can initiate your complaint by going to https://ico.org.uk/make-a-complaint/.

For more information regarding the GDPR at https://gdpr.eu/.

4. Contact Us. For more information regarding how we handle your Data or how we handle EEA Residents rights under GDPR, please see our Privacy Policy or contact us at:

FrontRow

c/o Data Protection Officer

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

greg.lyle@frontrow.cc