First Orion UK Limited, also doing business as PrivacyStarTM, is a business dedicated to using technology and data to benefit both consumers and businesses. First Orion helps consumers by providing greater transparency about who is calling them and why. We also help consumers manage the calls they receive that are likely to be a phone scam or are calls they do not want. For all First Orion offerings, the privacy of individuals is a priority and we are committed to safeguarding it.
First Orion will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679, as adopted into law of the United Kingdom in the Data Protection Act 2018.
Conducting General Business
Whilst conducting business with First Orion UK Limited, you may provide personal information (name, address, email, telephone number, fax number, etc.) to us. By providing telephone, fax and email details, you consent to First Orion contacting you using that method. You have the right at any time to request a copy of the personal information we hold on you. Should you wish to receive a copy of this, or would like to be removed from our database, please contact us as described at the end of this policy.
What information we collect from our Websites and how we may use it
We may collect your personal information via any First Orion Website to help us deliver a better level of user experience on the site, such as your name, mailing address, phone number, email address, contact preferences, and information relating to an inquiry or support issue. This enables us to give you convenient access to our Websites and helps us keep you posted on the latest product announcements, software or service updates, special offers, and events that you might like to hear about. It also allows us to respond to any concerns you may have voiced on the site or with our customer service department.
What information we collect from our First Orion Engage App and how we may use it
When you download the First Orion Engage App, we collect your phone number and use it for identity validation purposes. On an ongoing basis, we use your phone number to deliver an enhanced caller ID letting you know who is calling and why. We also collect information about your device to properly deliver the enhanced message in a compatible format.
You will need to allow First Orion to access your Contact List so the App can create a contact for incoming calls that display enhanced caller ID information about who is calling and why. We do NOT export any information outside the App from your contacts for any purpose. Once the enhanced call is delivered, the contact is deleted.
What information we collect from our Call Protect Solutions (including TPS) and how we may use it
First Orion is committed to helping consumers avoid nuisance and illegal call activity. To do this, we collect aggregated data about your calls, and use that in a crowd powered data engine to identify such activity.
We also provide you with the ability to report nuisance and illegal calls to the relevant regulators via the TPS App, supporting enforcement activity. You must register for the TPS, as you will not be able to file complaints to the TPS unless you meet the registration requirements. The TPS may require your telephone number, your email address, and your postcode. This data that you provide is shared with the TPS in a secure manner.
The personal data First Orion collects is relevant to your interaction with us when you use the App. This information includes the telephone number, the dates, times and durations of calls made to your phone so the various features you have chosen, such as sending calls to voicemail, can be provided. We also collect information as to whether the caller was in your contact list, but WE DO NOT take contact information from your device. All information is used to improve the functionality of our App. All of your personal data is stored in an aggregated form with other user’s data, meaning that your data cannot be traced back to you.
If you voluntarily choose to provide complaint information which may include personal information, this information may be provided to the TPS, Information Commissioner’s Officer (“ICO”), Ofcom and ActionFraud to aid in their enforcement activities. We may also use anonymised complaint information to better understand trends and improve the functionality of our App.
To enable support activity, we may request personal data as part of this process, such as your name, phone number, email address, and information relating to the inquiry or support issue to allow us to respond effectively.
Our Legal Basis for Processing
The table below shows a list of processes as part of the TPS Protect service and the legal basis and type of data used in each process.
|Processing Purpose||Legal Basis||Type of Data|
|Register for TPS & pass data to TPS system||· Contract
· Legitimate Interest
|· Registration Data|
|File a complaint||· Contract
· Legitimate Interest
|· Complaint Data
|Identify & assign a Trust Score and Category for use in App features such a Block List & Approve List.||· Legitimate Interest||· Aggregated call data (including phone number, call duration, date, & time
· Flag if number is in your contact list
|Assist you in support and troubleshooting activities.||· Legitimate Interest||· All information provided during support and troubleshooting activities.|
When we disclose your information
To help regulators or agencies such as the ICO, Ofcom and ActionFraud in their enforcement activities, your personal data may be shared with them, and they are responsible to safeguard it. Complaint data provided through TPS Protect is processed securely to the TPS via MIQ Solutions. Registration data provided through TPS Protect is processed securely to the TPS via Acxiom.
At times, we may be required by law to disclose your personal data. We may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, disclosure is necessary. If First Orion is involved in a business transaction, such as a merger, acquisition or sale of all or a portion of its assets, your personal data will likely be among the business assets transferred. You will be notified via prominent notice on our Website, and within the App, of such change in ownership as well as any choices you may have regarding your personal information.
The information we collect will only be used to provide an easy way to help you and others block unwanted calls without compromising your privacy. Your phone number and details about the calls you get will never be shared with a third party without your knowledge and consent. Your contacts are YOUR contacts! Unlike other apps, we never share or sell your personal contact list. Your contact list is only used by the app to aid and enhance your experience with incoming calls on your device.
What information we collect from third parties and how we may use it
First Orion may obtain information about you and about your phone number from third parties and combine it with information we already have about you to improve the user experience and the functionality on our Websites, Apps, in-network solutions and business services.
For how long do we hold your data?
The limited personal information you voluntarily provide for TPS registration within TPS Protect is shared with the TPS. First Orion holds this limited personal information provided for your TPS registration information for 48 hours, provided subject to satisfactory processing by the TPS via Acxiom.
The personal information for complaints is stored for three months on our secure servers to assist us in identifying nuisance and fraudulent calls and may support the TPS, ICO, Ofcom and ActionFraud in their enforcement activities.
Any personal information provided in tickets during support activity process is retained for three months, and then deleted.
Where information we collect is processed
All information related to TPS Protect that you provide to us is stored on our secure servers. These are hosted in Amazon Web Services (AWS) in Ireland. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or our Apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Apps and/or our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
First Orion may transmit personal information to or from the United States for processing, storage or other purposes related to supporting First Orion Websites, Apps and other solutions and services. Personal information stored in the U.S. may therefore be accessed by courts, law enforcement and national security authorities in the United States in accordance with First Orion’s EU-U.S. Privacy Shield policy described below.
Publicly displayed information is public
If you use a bulletin board, chat room or blog on a First Orion website or App, you should be aware that any information you share is visible to other users. Personally identifiable information you submit to one of these forums can be read, collected, or used by other individuals for their purposes. First Orion is not responsible for the personally identifiable information you choose to submit in these forums.
How we protect your personal information
First Orion takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.
Cookies and other technologies
As is standard practice on many corporate websites, First Orion’s websites use “cookies” and other technologies to improve the user experience. These include the use of Google Analytics, to study traffic patterns, to make the website user experience more rewarding as well as to study the effectiveness of our website user communications. How Google uses the data may be found at www.google.com/policies/privacy/partners/. Information gathered using Google Analytics consists of counts of unique daily or monthly visitors, visitors by device type, location data, unique registrants, time on site, browser types, onboarding abandonment, channel, and existing user abandonment.
If you prefer not to enable cookies, certain features of the First Orion websites may not be available once cookies are disabled.
First Orion may gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.
In some of our email messages we may use a “click-through URL” linked to content on the First Orion websites. When website users click one of these URLs, they pass through our web server before arriving at the destination web page. We may track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.
In addition, we may use pixel tags — tiny graphic images — to tell us what parts of our website users have visited or to measure the effectiveness of searches website users perform on our site.
Pixel tags also enable us to send email messages in a format that website users can read. And they tell us whether emails have been opened to ensure that we’re sending only messages that are of interest to our website users.
First Orion’s website has links to the sites of other companies. First Orion is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.
Your EU and UK Privacy Rights
First Orion will ensure that all personal information supplied is held securely in accordance with the General Data Protection Regulation (EU) 2016/679, as adopted into law of the United Kingdom in the Data Protection Act 2018. Some of this information may be stored in the United States. However, any such information will also be treated in accordance with First Orion’s EU-US Privacy Shield Policy.
First Orion’s is certified for the EU-U.S. Privacy Shield with the Department of Commerce. First Orion’s Privacy Shield Policy can be found at https://firstorion.com/privacy-shield-policy/
and our Privacy Shield Policy for Human Resource Data can be found at https://firstorion.com/privacy-shield-for-human-resource-data/.
It is your choice to provide personal information to First Orion. As required by law, you may verify the details you have submitted to First Orion, change, correct or delete your personal information, or unsubscribe from marketing communications by contacting us as described below.
First Orion UK Limited
Attention: Legal Team
3 Waterhouse Square, 138 Holborn
London EC1N 2SW
© 2018 First Orion Corp. All rights reserved.
First Orion Corp., 500 President Clinton Avenue, Suite 215, Little Rock, Arkansas 72001, USA.