Last Updated: September 29, 2022


Please read these Terms of Service (the “Agreement”) carefully. Your use of the Service (as defined below) constitutes your consent to this Agreement.

This Agreement is between you and Front Financial, Inc. (“Front” or “we” or “us”) concerning your use of (including any access to) any mobile applications (“Apps”) and websites (“Sites”) through which we make our investment advisory service and/or our communication services available, collectively the “Service”). This Agreement hereby incorporates by this reference any additional terms and conditions posted by Front through the Service, or otherwise made available to you by Front.

This Agreement supplements the investment advisory agreement (“IAA”) you will be required to enter into in order to open an account with Front.  The terms and conditions of the IAA will supersede this Agreement to the extent that such terms and conditions conflict with any provisions of this Agreement.

For additional disclosures and information about Front and its investment advisory services, please review our Form ADV Part 2A: Front ADV Part 2 (2022) and our Form CRS: Form CRS (Front) 06.01.22.


Please note that the Service is currently made available as an “alpha” or “beta” program. Without limiting any other terms or conditions of this Agreement, please note that Front may, without notice, establish eligibility criteria for participation in the alpha or beta program, limit or revoke any individual’s participation in the alpha or beta program, and change or modify any features or functionalities of the Service.

  1. Changes. We may change this Agreement from time to time by notifying you of such changes by any reasonable means, including by posting a revised Agreement through the Service. Any such changes will not apply to any dispute between you and us arising prior to the date on which we posted the revised Agreement incorporating such changes, or otherwise notified you of such changes.

Your use of the Service following any changes to this Agreement will constitute your acceptance of such changes. The “Last Updated” legend above indicates when this Agreement was last changed. We may, at any time and without liability, modify or discontinue all or part of the Service (including access to the Service via any third-party links); charge, modify or waive any fees required to use the Service; or offer opportunities to some or all Service users.

  1. Jurisdictional Issues. The Service is controlled and operated from the United States, and is not intended to subject Front to any non-U.S. jurisdiction or law. The Service may not be appropriate or available for use in some non-U.S. jurisdictions. Any use of the Service is at your own risk, and you must comply with all applicable laws, rules and regulations in doing so. We may limit the Service’s availability at any time, in whole or in part, to any person, geographic area or jurisdiction that we choose. Front Financial only offers investment advisory services in the United States.
  2. Registration; Usernames and Passwords; Security. You may need to register to use all or part of the Service. We may reject, or require that you change, any username, password, or other information that you provide to us in registering. Your username and password are for your personal use only and should be kept confidential; you, and not Front, are responsible for any use or misuse of your username or password, and you must promptly notify us of any confidentiality breach or unauthorized use of your username or password, or your Service account. In addition, you are solely responsible for maintaining the security of your device and any credentials used in connection with your device. Do not provide any username or password (e.g., device or related “cloud” passwords, or any Front-issued usernames or passwords) to anyone. Do not enable any fingerprints other than your own for use with any device’s fingerprint authentication. Your device may also contain certain security features to protect against unauthorized use of the device and the Service; you agree not to disable or bypass any such features. You must ensure that the App has been permanently deleted from a device before selling or otherwise transferring such device.
  3. Rules of Conduct. In connection with the Service, you must not:

You are responsible for obtaining, maintaining, and paying for all hardware and all telecommunications and other services needed to use the Service.

5. Submissions. Service visitors may make available certain materials (each, a “Submission”) through or in connection with the Service, including on profile pages or on the Service’s interactive services, such as forums and messaging functionality, and including through the provision of account, transactions, or other financial information. Front has no control over and is not responsible for any use or misuse (including any distribution) by any third party of Submissions.


6. License. For purposes of clarity, you retain ownership of your Submissions. For each Submission, you hereby grant to us a worldwide, royalty-free, fully paid-up, non-exclusive, perpetual, irrevocable, transferable and fully sublicensable (through multiple tiers) license, without additional consideration to you or any third party, to reproduce, distribute, perform and display (publicly or otherwise), create derivative works of, adapt, modify and otherwise use, analyze and exploit such Submission, in any format or media now known or hereafter developed, and for any purpose (including promotional purposes, such as testimonials).

In addition, if you provide to us any ideas, proposals, suggestions, or other materials (“Feedback”), whether related to the Service or otherwise, such Feedback will be deemed a Submission, and you hereby acknowledge and agree that such Feedback is not confidential, and that your provision of such Feedback is gratuitous, unsolicited and without restriction, and does not place Front under any fiduciary or other obligation.

You represent and warrant that you have all rights necessary to grant the licenses granted in this section, and that your Submissions, and your provision thereof through and in connection with the Service, are complete and accurate, and are not fraudulent, tortious, or otherwise in violation of any applicable law or any right of any third party. You further irrevocably waive any “moral rights” or other rights with respect to attribution of authorship or integrity of materials regarding each Submission that you may have under any applicable law under any legal theory.

7. Monitoring. We may (but have no obligation to) monitor, evaluate, alter, or remove Submissions before or after they appear on the Service, or analyze your access to or use of the Service. We may disclose information regarding your access to and use of the Service, and the circumstances surrounding such access and use, to anyone for any reason or purpose.

8. Your Limited Rights. Subject to your compliance with this Agreement, and solely for so long as you are permitted by Front to use the Site, you may view one (1) copy of any portion of the Site to which we provide you access under this Agreement, on any single device, solely for your personal, non-commercial use. The App is licensed (not sold) to end users. Subject to your compliance with this Agreement, and solely for so long as you are permitted by Front to use the App, we hereby permit you, on a limited, non-exclusive, revocable, non-transferable, non-sublicensable basis, to install and use the App on a mobile device that you own or control, solely for your personal, non-commercial use. If you fail to comply with any of the terms or conditions of this Agreement, you must immediately cease using the App and remove (that is, uninstall and delete) the App from your mobile device.

9. Front’s Proprietary Rights. We and our suppliers own the Service, which is protected by proprietary rights and laws. Our trade names, trademarks and service marks include FRONT, FRONT INVESTMENT and FRONT FINANCIAL INC., and any associated logos. All trade names, trademarks, service marks and logos on the Service not owned by us are the property of their respective owners. You may not use our trade names, trademarks, service marks or logos in connection with any product or service that is not ours, or in any manner that is likely to cause confusion. Nothing contained on the Service should be construed as granting any right to use any trade names, trademarks, service marks or logos without the express prior written consent of the owner.

10. Confidentiality. You acknowledge that your use of the Service may make available to you confidential and proprietary information of Front (“Confidential Information”). Confidential Information includes the terms of this Agreement and the features and functionality of the Service, as well as any technology, know-how, products, potential products, marketing concepts, financial information, partners, potential partners, business plans, and Feedback. You agree not to use any Confidential Information for your own or for any other purpose, except in order to use the Service as expressly authorized under this Agreement. You agree to hold the Confidential Information in strict confidence and not to disclose such Confidential Information to any third party. You agree to take all reasonable measures to protect the confidentiality of any Confidential Information, and to avoid the unauthorized disclosure or use of any Confidential Information.

11. Third Party Materials; Links. The use of the Service is dependent upon certain third-party products and services. The Service may make available access to certain third-party products, services and offers, as well as other information, products, services and other materials made available by third parties, including Submissions, or allow for the routing or transmission of such materials, including via links. Additionally, you may choose to link one or more of your Connected Services as discussed below. All such third-party products, services and material are referred to as “Third Party Materials.”

We neither control nor endorse, nor are we responsible for, any Third Party Materials, including the accuracy, validity, timeliness, completeness, reliability, integrity, quality, legality, usefulness or safety of Third Party Materials, or any intellectual property rights therein. Certain Third Party Materials may, among other things, be inaccurate, misleading or deceptive. Nothing in this Agreement shall be deemed to be a representation or warranty by Front with respect to any Third Party Materials. We have no obligation to monitor Third Party Materials, and we may block or disable access to any Third Party Materials (in whole or part) through the Service at any time. In addition, the availability of any Third Party Materials through the Service does not imply our endorsement of, or our affiliation with, any provider of such Third Party Materials, nor does such availability create any legal relationship between you and any such provider.


Please note that certain Third Party Materials may include data made available by Polygon.

Front uses YouTube API Services, which are governed by the YouTube Terms of Service (ToS), to show video content in the application. Front does not use any user-related data from the YouTube API. The Front app stores only “Non-Authorized Data” and all data that is more than 30 days old is deleted.

12. Connected Services; Communication Tool.  You may use the Service to communicate with the accounts you connect. You acknowledge and agree that your use of such communication tools is at your instruction and that we do not provide brokerage services. For each third party account or wallet you connect to the Service (your “Connected Services”), you represent and warrant that you have all rights and consents necessary to connect to and access your Connected Services through the Service, including the right to provide your account login credentials and/or wallet addresses to Front for each Connected Service. You hereby authorize Front to send and receive communications and Third Party Materials between the Service and your Connected Services.  Front does not store the account login credentials and/or wallet addresses for your Connected Services.  If you disconnect a Connected Service, Front will no longer have access to such Connected Service.  If you delete our App, Front will no longer have access to any of your Connected Services.

You acknowledge and agree that: (i)  we do not charge any transaction-based compensation for your use of the Service as a communications tool; (ii) the Connected Services may charge you commissions or other fees for effecting transactions pursuant to your instructions conveyed through the Service; (iii) your customer funds, securities or other digital assets, which may be held in your Connected Services accounts or wallets, are not transmitted through or handled by the Service; (iv) neither Front nor the Service solicits trades for your Connected Services; (v) you are responsible for all trading instructions you convey through the Service;  (vi) to the extent you send encrypted communications between the Service and your Connected Services, Front does not read your encrypted communications and (vii) any transactions effected pursuant to your instructions will be executed by the Connected Service and not by Front.

We do not control and are not responsible for any Connected Services including, without limitation, the accuracy, validity, timeliness, completeness, reliability, integrity, quality, legality, usefulness or safety of Connected Services, or any intellectual property rights therein. Certain Connected Services may, among other things, be inaccurate or misleading and we do not have any control over any Connected Services. Nothing in this Agreement shall be deemed to be a representation or warranty by Front with respect to any Connected Services. We have no obligation to monitor Connected Services, and we may block or disable access to any Connected Services (in whole or part) through the Service at any time. In addition, the availability of any Connected Service through the Service does not imply our endorsement of, or our affiliation with, any provider of such Connected Service.  Generally, Connected Services will be third parties that are not affiliated with Front.  We will disclose to you any affiliation or compensation arrangement we may have with any Connected Service. Any relationship you have with a Connected Service will be governed by the terms agreed upon between you and any such Connected Service.

You understand and agree that Front will not be responsible for, and Front undertakes no responsibility to monitor Connected Services or the actions you take to communicate with the Connected Services through the Service. You acknowledge that linking any of your Connected Services to the Service is your choice, and therefore you agree that Front shall have no obligation and incur no liability in connection with the conduct of your Connected Services or your communications to your Connected Services. You rely upon Connected Services at your own risk.

13. Promotions. Any sweepstakes, contests, raffles, surveys, games or similar promotions (collectively, “Promotions”) made available through the Service may be governed by rules that are separate from this Agreement. If you participate in any Promotions, please review the applicable rules as well as our Privacy Policy. If the rules for a Promotion conflict with this Agreement, the Promotion rules will govern.


15. You are responsible for your own investment decisions.  As set forth in more detail in the IAA, Front provides only non-discretionary investment advice. 

You acknowledge and agree that: (i) the Service may include certain information taken from stock exchanges and other sources from around the world; (ii) Front does not guarantee the accuracy, completeness, or timeliness of the Service, or any information, facts, views, opinions, statements or recommendations available through the Service; (iii) the provision of certain parts of the Service is subject to the terms and conditions of other agreements to which Front is a party, including, without limitation, the IAA; and (iv) the information available through the Service is not intended for use by, or distribution to, any person or entity in any jurisdiction or country where such use or distribution would be contrary to any law, rule or regulation. Accordingly, notwithstanding anything to the contrary, neither Front nor any Affiliated Entity shall be liable, directly or indirectly, to you or any other person for any: (a) inaccuracies or errors in or omissions from the Service including quotes and financial data; (b) delays, errors, or interruptions in the transmission or delivery of the Service; or (c) loss or damage arising therefrom or occasioned thereby, or by any reason of nonperformance.

While we try to maintain the timeliness, integrity and security of the Service, we do not guarantee that the Service is or will remain updated, complete, correct or secure, or that access to the Service will be uninterrupted. The Service may include inaccuracies, errors and materials that violate or conflict with this Agreement. Additionally, third parties may make unauthorized alterations to the Service. If you become aware of any such alteration, contact us at [email protected] with a description of such alteration and its location on the Service.

16. Limitation of Liability.To the fullest extent permitted under applicable law: (a) Front will not be liable for any indirect, incidental, consequential, special, exemplary or punitive damages of any kind, under any contract, tort (including negligence), strict liability or other theory, including damages for loss of profits, use or data, loss of other intangibles or loss of security of Submissions (including unauthorized interception by third parties of any Submissions), even if advised in advance of the possibility of such damages or losses; (b) without limiting the foregoing, Front will not be liable for damages of any kind resulting from your use of or inability to use the Service or from any Third Party Materials or Connected Services, including from any Virus that may be transmitted in connection therewith; (c) your sole and exclusive remedy for dissatisfaction with the Service, any Third Party Materials or any Connected Service is to stop using the Service; and (d) the maximum aggregate liability of Front for all damages, losses and causes of action, whether in contract, tort (including negligence) or otherwise, shall be the total amount, if any, paid by you to Front solely for the right to use the Service. All limitations of liability of any kind (including in this section and elsewhere in this Agreement) are made for the benefit of both Front and the Affiliated Entities, and their respective successors and assigns.  Nothing in this Agreement shall constitute a waiver or limitation of any rights or privileges that you may have under any applicable federal securities laws.

The foregoing limitation on liability will have no application to any claims brought under an IAA.

17. Indemnity. To the fullest extent permitted under applicable law, you agree to defend, indemnify and hold harmless Front and the Affiliated Entities, and their respective successors and assigns, from and against all claims, liabilities, damages, judgments, awards, losses, costs, expenses and fees (including attorneys’ fees) arising out of or relating to (a) your use of, or activities in connection with, the Service (including all Submissions); and (b) any violation or alleged violation of this Agreement by you.  Nothing in this Section shall waive or limit the rights and privileges available to you under the federal securities laws. 

18. Termination. This Agreement is effective until terminated. Front may terminate or suspend your use of the Service at any time and without prior notice, for any or no reason, including if Front believes that you have violated or acted inconsistently with the letter or spirit of this Agreement. Upon any such termination or suspension, your right to use the Service will immediately cease, and Front may, without liability to you or any third party, immediately deactivate or delete your username, password and account, and all associated materials, without any obligation to provide any further access to such materials.  The following Sections shall survive any expiration or termination of this Agreement: 4, 6, 10, 11, 12, 14, 15, 16, 17, 18, 19, 23, and 24.

19. Governing Law; Arbitration. This Agreement is governed by and shall be construed in accordance with the laws of the State of California, U.S.A., without regard to its principles of conflicts of law, and regardless of your location. You agree to exclusive jurisdiction of the federal and state courts located in the City and County of San Francisco, California, U.S.A., and waive any jurisdictional, venue or inconvenient forum objections to such courts.

20. Filtering. We hereby notify you that parental control protections (such as computer hardware, software or filtering services) are commercially available that may assist you in limiting access to material that is harmful to minors. Information identifying current providers of such protections is available from Please note that Front does not endorse any of the products or services listed on such site.

21. Information or Complaints. If you have a question or complaint regarding the Service, please send an e-mail to [email protected] You may also contact us by writing to Front Financial Inc., 1 Ferry Building (Suite 201), San Francisco, CA 94111. Please note that e-mail communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your e-mail correspondence with us. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

22. Export Controls. You are responsible for complying with United States export controls and for any violation of such controls, including any United States embargoes or other federal rules and regulations restricting exports. You represent, warrant and covenant that you are not (a) located in, or a resident or a national of, any country subject to a U.S. government embargo or other restriction, or that has been designated by the U.S. government as a “terrorist supporting” country; or (b) on any of the U.S. government lists of restricted end users.

23. Miscellaneous. This Agreement does not, and shall not be construed to, create any partnership, joint venture, employer-employee, agency or franchisor-franchisee relationship between you and Front. If any provision of this Agreement is found to be unlawful, void or for any reason unenforceable, that provision will be deemed severable from this Agreement and will not affect the validity and enforceability of any remaining provision. You may not assign, transfer or sublicense any or all of your rights or obligations under this Agreement without our express prior written consent. No waiver by either party of any breach or default under this Agreement will be deemed to be a waiver of any preceding or subsequent breach or default. Any heading, caption or section title contained herein is for convenience only, and in no way defines or explains any section or provision. All terms defined in the singular shall have the same meanings when used in the plural, where appropriate and unless otherwise specified. Any use of the term “including” or variations thereof in this Agreement shall be construed as if followed by the phrase “without limitation.” This Agreement, in conjunction with the IAA, including any terms and conditions incorporated herein, is the entire agreement between you and Front relating to the subject matter hereof, and supersedes any and all prior or contemporaneous written or oral agreements or understandings between you and Front relating to such subject matter. Notices to you (including notices of changes to this Agreement) may be made via posting to the Service or by e-mail (including in each case via links), or by regular mail upon your direct request to Front. Without limitation, a printed version of this Agreement and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to this Agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. Front will not be responsible for any failure to fulfill any obligation due to any cause beyond its control. By agreeing to these terms of service, you give your consent to receive all notices and disclosures electronically via email, link, or via posting to the Service.

24. Apple-Specific Terms. In addition to your agreement with the foregoing terms and conditions, and notwithstanding anything to the contrary herein, the following provisions apply with respect to your use of any version of the App compatible with the iOS operating system of Apple Inc. (“Apple”). Apple is not a party to this Agreement and does not own and is not responsible for the App. Apple is not providing any warranty for the App except, if applicable, to refund the purchase price for it. Apple is not responsible for maintenance or other support services for the App and shall not be responsible for any other claims, losses, liabilities, damages, costs or expenses with respect to the App, including any third-party product liability claims, claims that the App fails to conform to any applicable legal or regulatory requirement, claims arising under consumer protection or similar legislation, and claims with respect to intellectual property infringement. Any inquiries or complaints relating to the use of the App, including those pertaining to intellectual property rights, must be directed to Front in accordance with the “Information or Complaints” section above. The license you have been granted herein is limited to a non-transferable license to use the App on an Apple-branded product that runs Apple’s iOS operating system and is owned or controlled by you, or as otherwise permitted by the Usage Rules set forth in Apple’s App Store Terms of Service, except that the App may also be accessed and used by other accounts associated with you via Apple’s Family Sharing or volume purchasing programs. In addition, you must comply with the terms of any third-party agreement applicable to you when using the App, such as your wireless data service agreement. Apple and Apple’s subsidiaries are third-party beneficiaries of this Agreement and, upon your acceptance of the terms and conditions of this Agreement, will have the right (and will be deemed to have accepted the right) to enforce this Agreement against you as a third-party beneficiary thereof; notwithstanding the foregoing, Front’s right to enter into, rescind or terminate any variation, waiver or settlement under this Agreement is not subject to the consent of any third party.

25. Third-party influencers will be compensated by Front Financial for producing posts and for clients referred. Investing involves risks.  There is always the risk of loss when you invest in securities. No investment tool or financial planning strategy can guarantee profit or protection against losses. Past performance is no guarantee of future results.

26. The Front Financial Good for your portfolio and TOP PICK  represent our general views. The stocks included in Good for your portfolio and Top pick have not been selected to address the investment objectives or financial circumstances of any individual investor. You should consider your personal objectives and circumstances and obtain appropriate advice before making any investment decisions. The Good for your portfolio, Top pick and any other securities identified on this post, the App or the Sites are a partial list of potential investments. A full list of our previous Top picks and other investment recommendations made during the past 12 months will be furnished without charge upon request sent to [email protected]. It should not be assumed that recommendations made in the future will be profitable or will equal the performance of any securities referenced in this post.

27. As noted, some of these profiles/ portfolios may not be managed directly by the identified individual/entity and the content is sourced directly through public resources. The named individual/entity is not affiliated nor endorsing Front Financial, Inc.

28. “Trending” stocks are not a recommendation to buy nor sell, nor a guarantee of future performance. “Trending” stocks are determined by the most interest and activity on the Front App.

29. For Front contests and rewards programs that award prizes of monetary value, Front is not responsible for any taxes related to these reward programs. Tax forms might be needed as per state and federal regulations. See Front contest terms and conditions and Front referral program terms and conditions for more information.

30. For Front Prime subscribers: All subscription prices are subject to change and are not guaranteed. Introductory pricing subject to change. The list of stocks provided in the App have not been selected to address the investment objectives or financial circumstances of any individual investor. Securities identified represent a partial list. A full list of investment recommendations made during the past 12 months will be furnished without charge upon request sent to [email protected]. Past performance is no guarantee of future returns. It should not be assumed that recommendations made in the future will be profitable or will equal the performance of any securities referenced in this post. Investing involves risk and possible loss of principal capital. Further information can be found on

Service © 2021 Front Financial, Inc. unless otherwise noted. All rights reserved.

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