FIRSTLINE COMPLIANCE, LLC PRIVACY POLICY

CALIFORNIA PRIVACY RIGHTS

Effective March 22, 2020

 

Your privacy is important to FIRSTLINE COMPLIANCE, LLC (“Company”), so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information.

Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions.

1. COLLECTION AND USE OF PERSONAL INFORMATION

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with Company or an affiliated company. Company and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information Company may collect and how we may use it:

  • When you create a user ID, purchase a product or service, connect to our services, contact us including by social media or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, credit card information and profile information where the contact is via social media.

  • We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Company is subject, for the performance of a contract to which you are party, in order to protect your vital interests, or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Company or a third party to whom it may be necessary to disclose information. If you have questions about this legal basis you can contact us.

  • The personal information we collect allows us to keep you posted on Company’s latest service announcements, industry updates, and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by updating your preferences or by emailing info@firstlinecompliance.com.

  • We may use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

  • We may use your personal information, including date of birth, to verify identity, assist with identification of users. For example, we may use date of birth to determine the age of Company ID account holders.

  • From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Company, you may not opt out of receiving these communications.

  • We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Company’s products, services, and customer communications.

  • If you apply for a position at Company or we receive your information in connection with a potential role at Company, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how Company handles candidate personal information at the time of application.

2. SOURCE OF YOUR PERSONAL INFORMATION WHERE THEY ARE NOT COLLECTED FROM YOU

We may have received your personal information from other persons if that person has shared their content with you using Company services or invited you to participate in Company services or forums. We may also validate the information provided by you when creating a user ID with a third party for security and fraud prevention purposes.

If you are a potential candidate for employment with Company, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy. If you did not provide us your personal information directly, we will inform you of the source when we first contact you regarding your candidacy. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

3. COLLECTION AND USE OF NON-PERSONAL INFORMATION

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a Company service is used so that we can better understand customer behavior and improve our products, services, and advertising.

  • We may collect information regarding customer activities on our website, and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.

  • We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.

  • With your explicit consent, we may collect data about how you use your device and applications in order to help app developers improve their apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

4. COOKIES AND OTHER TECHNOLOGIES

Company’s websites, online services, interactive applications, email messages, chat functions and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Ads that are delivered by Company’s advertising platform may appear in Company news. If you do not wish to receive ads targeted to your interests from Company's advertising platform, you can choose to opt your user ID out of receiving such ads regardless of what device you are using. If you enable Limit Ad Tracking on your mobile device, third-party apps cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads in the App Store or News based on context like your search query or the channel you are reading. In third-party apps, you may see ads based on other information.

Company also uses cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Company more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Company Online Store. Knowing your country and language helps us provide a customized and more useful shopping experience. Knowing your contact information, hardware identifiers, and information about your computer or device helps us personalize your operating system, set up your service, and provide you with better customer service.

If you want to disable cookies and you’re using the Safari web browser, go to Safari preferences and then to the privacy pane to manage your preferences. On your Company mobile device, go to Settings, then Safari, scroll down to the Privacy & Security section, and tap on “Block Cookies” to manage your preferences. For other browsers, check with your provider to find out how to disable cookies. Please note that certain features of the Company website will not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Company may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Company website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

5. DISCLOSURE TO THIRD PARTIES

At times Company may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help Company market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Company does not sell personal information, and personal information will never be shared with third parties for their marketing purposes.

6. SERVICE PROVIDERS

Company shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Company operates.

7. OTHERS

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Company to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

8. PROTECTION OF PERSONAL INFORMATION

Company takes the security of your personal information very seriously. Company online services protect your personal information during transit using encryption. When your personal data is stored by Company, we use third party computer systems with limited access housed in facilities using physical security measures.

When you use some Company services, applications, or post on a Company forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

9. INTEGRITY AND RETENTION OF PERSONAL INFORMATION

Company makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

10. YOUR PRIVACY RIGHTS

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your Company ID account page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Company is not required to retain it by law or for legitimate business purposes.

We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.

11. CALIFORNIA

The California Consumer Privacy Act provides California consumers with the right to obtain from Company information about the personal information about you that we collect, use, and disclose. You can exercise your rights through an authorized agent by contacting us at info@firstlinecompliance.com.

If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from Company.

An additional privacy disclosure for California consumers may be found at the end of this document.

12. NEVADA

You have the right to opt-out of the sale of your personal information. Company does not sell your personal information.

13. CHILDREN

We understand the importance of taking extra precautions to protect the privacy and safety of children using Company products and services. Children under the age of 18, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own Company IDs, If we learn that we have collected the personal information of a child under 18, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their Family Sharing account or child’s Company ID, they may contact us through one of the options provided at the bottom of this page.

14.   THIRD‑PARTY SITES AND SERVICES

Company websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

15. OUR COMPANYWIDE COMMITMENT TO YOUR PRIVACY

To make sure your personal information is secure, we communicate our privacy and security guidelines to Company employees and strictly enforce privacy safeguards within the company.

16. PRIVACY QUESTIONS

If you have any questions or concerns about Company’s Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at info@firstlinecompliance.com.

When a privacy question or question about personal information received in response to an access/download request is received we will respond in a reasonable timeframe allowed by law. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts receive a response within seven (7), days wherever possible - providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. You may at any time refer your complaint to the relevant regulator in your jurisdiction if you are unsatisfied with a reply received from us. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.

Company may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy.

Firstline Compliance, LLC

Contact: info@firstlinecompliance.com

 

 

CALIFORNIA PRIVACY DISCLOSURES

1. CALIFORNIA PRIVACY RIGHTS

California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising one of their California privacy rights. Company does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.

Company provides notice of our privacy practices in our Privacy Policy. The Privacy Policy includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether Company discloses that personal information and if so, the categories of third parties to whom it is disclosed. More information about how Company handles personal information in connection with specific Company services is presented in service-specific notices at or before your first use of the service and is available at all times on your Company device.

California consumers with a user account can exercise their rights directly or through an authorized agent by logging in to your user account or emailing info@firstlinecompliance.com. If you are a California consumer without a user account and you or your authorized agent would like to exercise your privacy rights, requests may be made to info@firstlinecompliance.com. If you do not have a user account, Company will ask you for information which we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your transaction or relationship with Company, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights. If we delete your personal information, we will both render certain personal information about you permanently unrecoverable and also deidentify certain personal information.

2. DO NOT TRACK

Company does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on Company’s websites such as a social feature or a stock ticker may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Company website from a certain IP address. Third parties cannot collect any other personally identifiable information from Company’s websites unless you provide it to them directly.

3. NOTICE FOR MINORS

This service is not intended for, and not available to children under the age of 18.  At any time you can delete or remove content you have posted using the deletion or removal options within our services.  If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact our Company Support team directly here: info@firstlinecompliance.com.  Although we offer deletion capability for our services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.

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