PRIVACY POLICY

This Privacy Policy (“Policy”) governs the way 4Front Strategic Partners, LLC (“4Front”) collects, uses, maintains, and discloses information collected from users (each, a “User”), including but not limited to information collection from www.4frontsp.com and the LMS platform known as 4Front Academy (collectively, referred to as “Websites”), and this Policy applies to all products and services offered by 4Front.

4Front carries out all processing operations in compliance with United States federal and state laws, as well as the EU General Data Protection Regulation ("GDPR").

Users’ Rights as They Pertain to Personal and Business Information

Users have the right to know why an organization collects, uses or discloses their information. Users have the right to expect an organization to handle their information reasonably and to not use it for any other purpose other than the one to which Users have consented. Users have the right to know who in an organization is responsible for protecting information. Users have the right to expect an organization to protect their information from unauthorized disclosure. Users have the right to inspect the information an organization holds about them and make sure it is accurate, complete, and current. Users have the right to expect an organization to destroy their information when requested and when no longer required for the intended purpose. Users have the right to confidentially complain to an organization about how it handles their information. Users have the right to lodge a complaint about 4Front's practices with respect to their personal data with the supervisory authority of their country or EU Member State.

Information that is Collected

4Front collects information about Users when Users voluntarily provide this information, visit Websites, and/or when using 4Front’s services.

Personal Information

Personal information means any information which relates to or identifies an individual. 4Front may collect personal information from Users in a variety of ways, including, but not limited to, when Users visit Websites, register on Websites sites, place an order, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features, or resources available on Websites. Users may be asked for the following:

  • Contact information such as name, e-mail address, phone number, billing information, information inputted into open text fields.

  • Display name, job title, and other details pertaining to profile information to be displayed as part of 4Front’s services.

  • Business information, such as a company name, industry, company size, company contact information.

  • Content information about that may include viewed content and training interactions.

  • Contact information provided when seeking technical support, including summary of problems, and attachments that may be helpful in resolving an issue.

  • Information when visiting and interacting with Websites. This may include the links that are clicked, downloaded file attachments, and search terms.,

Users may visit Websites anonymously. 4Front will collect personal identification information from Users only if they voluntarily submit such information. Users can decline to supply personally identifiable information; however, declining may prevent User from engaging in certain website-related activities.

Non-Personal Information

4Front may collect non-personal information about Users whenever they interact with Websites. Non-personal identification information may include device information including connection type and settings, information about operating systems, browser type, IP address, URLs of referring/exit pages, and other similar information.

Web Browser Cookies

Websites may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to send an alert when cookies are being sent. If User chooses to do so, some parts of the Websites may not function properly.

Third-Party Websites

Users may find advertising or other content on Websites that link to the sites and services of 4Front’s partners, suppliers, advertisers, sponsors, licensors and other third parties. 4Front does not control the content or links that appear on these sites and is not responsible for the practices employed by websites linked to or from Websites. Additionally, these sites or services, including content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies, and 4Front is not responsible for the privacy practices of such other sites. Browsing and interaction on any other website, including other websites which have a link to Websites, is subject to that website’s own terms and policies, and this Policy applies solely to information collected by 4Front.

Google Analytics

4Front uses a tool called “Google Analytics” to collect information about the use of Websites. Google Analytics collects information such as how often Users visit a site, what pages they visit when a site is visited, and what other sites Users used prior to coming to Websites. 4Front uses the information received from Google Analytics only to improve Websites. Google Analytics collects only the IP address assigned to User on the date User visited Websites, rather than User’s name or other identifying information. 4Front does not combine the information collected by Google Analytics with personal information. Although Google Analytics plants a permanent cookie on User’s web browser to identify User, User will be a unique user the next time Websites are visited. The cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about visits to Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Users can prevent Google Analytics from recognizing them on return visits to Websites by disabling cookies on their browser. More information about Google Analytics Privacy Policy can be found at http://www.google.com/privacy.html.

Google Adsense

Some of the ads may be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to Websites and other sites on the Internet. DART uses “non-personal information,” and does NOT track personal information, such as name, email address, physical address, etc. Users may opt out of the use of the DART cookie by visiting the Google Ad and Content Network Privacy Policy at http://www.google.com/privacy_ads.html. Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings. Alternatively, Users may opt out of a third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

Other Ad Networks

If User has not opted out of third-party ad serving, the cookies of other third-party vendors or ad networks may also be used to serve ads on Websites. Users may visit those websites to opt out of the use of cookies for interest-based advertising (if the vendor or ad network offers this capability). Alternatively, Users can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

How Collected Information is Used

4Front may collect three types of information: personal, non-personal and anonymous. Users share this information so that 4Front may provide Users with the information and service that best meets their needs. 4Front may also use and disclose this information in order to:

  • Communicate with Users in a timely and efficient manner (e.g., respond to customer service requests).

  • Provide requested information on available products and services (e.g., requests, marketing communications, sales communication).

  • Act as required or authorized by law.

  • Sharing data with other data subprocesses as necessary to provide requested services.

  • Serve interest-based advertising and improve customer service by using information that is provided to respond to customer service requests.

  • Personalize User experience and understand how Users use the services and resources provided on Websites.

  • Make improvements Websites by using feedback provided on products and services.

  • Process payments for requested products and services.  

  • Process an order for a product or service that was placed by User or to update an order.  This information is not shared with outside parties except to the extent necessary to provide the requested service or product.

  • Run a promotion, contest, survey, or other website feature

  • Send Users information that they agreed to receive about topics that 4Front believes will be of interest to them.

  • Send periodic email communications. If User decides to opt-in to 4Front’s mailing list, they will receive emails that may include company news, updates, related product or service information, etc.

  • Respond to User inquiries, questions, and/or other requests.   

If at any time User would like to unsubscribe from receiving future emails, 4Front will include detailed instructions on how to unsubscribe at the bottom of each email.

Change of Purpose

4Front will only use personal information for the purposes for which it was collected, unless 4Front reasonably believes that the information is needed for another reason, and that reason is compatible with the original purpose. If 4Front needs to use User personal information for an unrelated purpose, 4Front will notify User and will explain the legal basis which allows 4Front to do so.

How Information is Protected

All employees and associates who are granted access to personal information understand the need to keep personal information protected and confidential. All employees and associates know they are to use the information only for the purposes intended.

4Front has adopted appropriate data collection, storage, processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of personal information, username, password, transaction information, and data stored on Websites.

Sensitive and private data exchanged between the Websites and Users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. Websites are also in compliance with PCI vulnerability standards to create as secure an environment as possible for Users.

Sharing Personal Information:

4Front does not sell, trade, or rent Users’ personal identification information to third parties. 4Front may share generic aggregated demographic information not linked to any personal identification information regarding visitors and Users with its business partners, trusted affiliates and advertisers for the purposes outlined above. 4Front may use third-party service providers to help operate its business, Websites, or administer activities on its behalf, such as sending out newsletters or surveys. 4Front may also share information with these third parties for limited purposes in which permission has been received.

Compliance with Children’s Online Privacy Protection Act (COPPA)

COPPA aims to protect the privacy of children under the age of 13 years-old by giving parents control over what information websites and online services can collect from their children. For this reason, 4Front does not collect or maintain information on Websites from anyone that 4Front actually knows is under the age of 13 years-old, and no part of Websites are structured to attract anyone under the age of 13 years-old.

Compliance with California Consumer Privacy Act of 2018 (“CCPA”) and California Consumer Rights Act of 2023 (“CPRA”)

CCPA and CPRA give certain consumers who reside in California (“California Consumers”) the right to know what categories of Personal and Sensitive Personal Information 4Front collects about them and how and for what purposes we use and share that information. “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal Information includes but is not limited to the categories of Personal Information identified below if such information identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular individual or household. “Sensitive Personal Information” means information that reveals an individual’s personal information and includes, but is not limited to, social security numbers, driver’s license numbers, state identification cards, passport numbers, account log-in, passwords, precise geolocations, racial or ethnic origins, religious or philosophical beliefs, or union membership.

4Front collects Personal and Sensitive Personal Information about California Consumers when a California Consumer is also a User who voluntarily provides this information, visits Websites, and/or is using 4Front’s services. Please note that, at this time, consumer rights under CCPA and CPRA to request access to and deletion of all such personal information that 4Front may hold, do not apply to such received information. Additionally, (i) 4Front does not have annual gross revenues of over $25 million, (ii) 4Front does not annually obtain Personal or Sensitive Personal Information of 100,000 or more California Consumers, households, and/or devices, and (iii) Company does not derive 50% or more annual revenue from selling California Consumers’ Personal Information. For these reasons, 4Front is not currently required to comply with CCPA and CPRA provisions.

Changes to Policy

This Policy supplements other notices and privacy policies and is not intended to override them. 4Front has sole discretion to update Policy at any time. Users are solely responsible for making sure that they are aware of the most recent version of Policy. When Policy is updated, a notification will be posted on the main page of Websites, and the Policy will be updated with a new date and revision number. Users are encouraged to stay informed by frequently checking Websites for Policy updates.

Disclaimer

4Front attempts to provide accurate information on Websites, but it assumes no responsibility for accuracy. 4Front may change the information on the site, or the products or services mentioned, at any time without notice. Content on Websites is provided "as is" and 4Front disclaims all warranties, express or implied. This includes but is not limited to implied warranties of merchantability or fitness for a particular purpose. It also includes any express or implied warranties arising from any course of dealing, usage, or trade practice.

Limitation of Liability

4Front is not liable for any direct, indirect, special, incidental, or consequential damages arising out of the use of material on Websites. This includes but is not limited to the loss of data or loss of profit, even if 4Front was advised of the possibility of such damages.

Privacy Choices

A User may withdraw consent at any time (subject to legal or contractual obligations and on providing 4Front with reasonable notice) by communicating to 4Front in writing. Please be aware that withdrawing consent may prevent 4Front from providing User with requested services. Please contact 4Front in writing at 3022 S Morgans Point Road, #307, Mt Pleasant, SC 29466 to withdraw consent.

Users have the right to file a complaint at any time with the supervisory authority of their country or EU Member State. However, 4Front would appreciate the opportunity to deal with any concerns before approaching a supervisory authority. Therefore, please contact 4Front in the first instance.

Contacting 4Front

Questions about this Policy should be sent to: info@4frontsp.com

This Policy was last updated on June 19, 2025, with revision number 003.