1. INTRODUCTION
This Privacy Policy explains how we collect your Personal Data (defined below) on those web sites of FirstLink that post or link directly to this Privacy Policy (collectively, the “Site”) and through offline means, how we use, disclose, and protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. FirstLink may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Any significant changes to the way we collect or use Personal Data will be highlighted on the homepage of the Site in advance. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was most recently revised.
For the purposes of this Privacy Policy, “FirstLink”, “we”, “us”, and “our” means FirstLink and its affiliates.
In some circumstances, you may have the option to decline to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.
This Privacy Policy shall also apply to any FirstLink mobile application and other forms of FirstLink online activity that reference this Privacy Policy. In such instances, the term “Site” shall include the applicable mobile application or other FirstLink online activity whenever that term is used herein.
2. COLLECTION OF PERSONAL DATA
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number (“Personal Data”). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so.
FirstLink requests Personal Data from you if the Site requires registration. The registration process requests that you provide Personal Data, such as your name, business email address, business address or country/jurisdiction location, business phone number, and company affiliation, and agree to the User Agreement presented at the time of registration.
FirstLink may receive Personal Data from social media platforms. For example, if you elect to use your social media credentials to log-in to your Site account, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your social media profile.
FirstLink may collect Personal Data voluntarily provided by you, including in emails, online forms, order and registration forms, surveys, promotion participation, online chats, phone calls, and through other means.
FirstLink may request Personal Data from our customers to comply with applicable anti-money laundering laws and other applicable laws.
On some of FirstLink Sites, including www.FirstLink.world you are able to maintain “portfolios,” where, if you are a registered user, you have the option to list financial instruments in which you have a special interest. To be useful, this information must be stored on the Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose them to any other person.
We may use third-party payment services (each, a “Payment Service”) to collect payments made through the Site. If you wish to make a payment through the Site, you may be directed to a webpage that is hosted by a Payment Service (or a Payment Service’s service providers) and not by FirstLink. Any Personal Data that you provide through a Payment Service page will be collected by the Payment Service and not by FirstLink, and will be subject to Payment Service’s privacy policy, rather than this Privacy Policy. FirstLink has no control over, and is not responsible for, a Payment Service’s use of information collected through a Payment Service page.
FirstLink collects information through various other means, including searches online, participation at conferences and events, individual introductions, from employers that enroll their employees in our services or provide services to us, and from selected third-party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.
3. USE OF PERSONAL DATA COLLECTED
We use Personal Data transparently and in compliance with applicable law, for legitimate business purposes, including the following:
3.1 Fulfillment of Requests
FirstLink may use Personal Data about you to deliver products and services to you, and to provide you with information about products and services you’ve ordered. We will engage in these activities to manage our contractual relationship with you and to fulfil our contractual obligations.
3.2 Marketing Communications
From time to time, in compliance with applicable laws, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If your employer is a FirstLink customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to FirstLink. We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. If you would prefer that we not send electronic marketing messages to you, please see the “Your Choices” section below.
3.3 Other Business Purposes
We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site, completing business transactions (for example, to confirm content requested is received by customers), development and delivery of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, receipt of services from you or your employer, conducting surveys and market research, and administering individual accounts.
3.4 Administrative Communications
FirstLink reserves the right to use Personal Data to send to you important information regarding the Site, products, services, your account status, the User Agreement, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site, products and/or services. Because this information may be important to your use of the Site, products and/or services, you may not opt-out of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.
3.5 Compliance with Law and Regulation
We may use Personal Data as necessary to comply with applicable legal and regulatory requirements such as sales tax collection, audits, etc.
FirstLink uses Personal Data for purposes compatible with those notified in this Privacy Policy and any other online or offline applicable privacy notice, and in accordance with applicable law. Where required by applicable law, we will only use Personal Data with your consent.