PRIVACY POLICY

1. Scope
Forefront Communications Group, Inc. (“us”, “we”, or “our”) operates https://forefrontcomm.wpengine.com (the “Site”) This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. Forefront’s websites, mobile applications, and other offerings are collectively called “Services.” This Privacy Policy explains the types of information we may collect, how we may use and disclose the information once it is collected, and, where applicable, how you can stop us from collecting, using, disclosing or continuing to hold your information. We want to ensure that in using the Services, you understand the terms of this Privacy Policy, including any subsequent changes made to the Privacy Policy, and are aware of the privacy choices available to you.

2. Personal Information We Collect
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

• Account Creation. We may collect information in order for us to create an account for you, such as name, email address, phone number, and business information such as company name and job title.

• Usage Information. We may collect information related to your interactions with our Services such as trade information and other activities such as name, account information, or information about the trade such as the amount traded.

• Your Communications with Us. We may collect personal information, such as name, email address, phone number, or mailing address when you request information about our Services, request customer or technical support, apply for a job or otherwise communicate with us.

• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public”, unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address ), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. [In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you.]
• Cookies, Pixel Tags/Web Beacons, and Other Technologies . We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See Section 5 below to understand your choices regarding these Technologies.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services, such as Google Analytics. For more information, please visit Google Analytics’ Privacy Policy..
• Social Media Platforms. Our Services may contain social media buttons. These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
• Information Collected from Other Sources. We may obtain information about you from other sources, including your name and email address from our customers, in order to create an account for you.

3. How We Use Your Information
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Processing applications if you apply for a job, we post on our Services; and
• Allowing you to register for events.
B. Administrative Purpose
We use your information for various administrative purposes, such as:
• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading or enhancing our Services;
• Developing new products and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our agreements and policies; and
• Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

4. How We Disclose Your Information
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our company affiliates, for our administrative purpose including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”)as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. Your Privacy Choices and Rights
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
• Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• “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 or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for those debives.
• The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
• Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
• Request Restriction of or Object to ourprocessing of your personal information when processing is noncompliant;
• Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
• Request data portability and receive an electronic copy of personal information that you have provided to us;
• Be informed about third parties with which your personal information has been shared.
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.

6. Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. International Data Transfers
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. Retention of Personal Information
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. Supplemental Notice for California Residents
This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Forefront has collected about them and whether Forefront disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Third Parties Information is Disclosed to for a Business Purpose
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in this Policy.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, Forefront does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth below.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, and phone number.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth below. We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

10. Supplemental Notice for Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at info@forefrontcomms.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A.

11. Children’s Information
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

12. Other Provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

13. Contact Us
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: info@forefrontcomms.com