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Privacy Policy

First Orion Privacy Policy (Last Update: 09/08/2017)
First Orion UK Limited (company number 09929064) of 11th Floor Lewins Mead, Whitefriars, Bristol, BS1 2NT (“First Orion”, or “we”, or “our” or “us”), is a business dedicated to using technology and data to give consumers tools to recognise and manage calls they receive. Your privacy is a priority for us, and we are committed to safeguarding it.

For the purpose of the Data Protection Act 1998 (the “Act”), First Orion is the data controller.
This Privacy Policy covers the collection, use, and disclosure of personal information and various technologies used by First Orion in the U.K. with respect to our website, tpsprotect.org.uk, (the “Website”) and when you use our free or subscription based application, TPS Protect (the “App”).

Our App includes features to register for the Telephone Preference Service (“TPS”), provide information about unknown callers, send unwanted callers to voice mail, automatically send known scammers to voice mail, perform telephone number lookups about complaint activity, and make complaints about nuisance and illegal calls to the relevant authorities via the TPS.

In order to use the App you are required to accept the Terms of Use and End User License Agreements which are available via the App and on the Website.
What information we collect and how we may use it
First Orion is committed to helping consumers avoid nuisance and illegal call activity. To do this, we collect anonymised 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, supporting enforcement activity. You will require registration with the TPS, as you will not be able to file complaints unless you meet the registration requirements of the TPS. The TPS may requires your telephone number, your email address, and your postcode. This data is shared with the TPS and your telephone number (and other information described herein) maybe stored in the App, so that you don’t have to fill that information in every time you file a complaint.
The personal data First Orion collects is relevant to your interaction with us when you use the App. This information includes the telephone numbers, caller ID information, 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 anonymised and 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, this information will be provided to the TPS and the relevant regulators or agencies such as the Information Commissioner’s Officer (“ICO”) and/or Ofcom, 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.
When we disclose your information
To help regulators or agencies such as the ICO and Ofcom in their enforcement activities, your personal data may be shared with them, and they are responsible to safeguard it.

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.

Where we store your personal data
All information 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 App, 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 App 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.

How we protect your personal information
First Orion takes precautions — including administrative, technical, and physical measures — to safeguard your personal data against loss, theft, and misuse, as well as unauthorised access, disclosure, alteration, and destruction.

Children
We do not knowingly collect personal information from children. We will delete the information as soon as possible after we become aware that we have that information.

Cookies and other technologies
As is standard practice on many corporate websites, our Website and App uses “cookies” and other technologies to help us understand which parts of our Websites are the most popular, where our visitors are going, and how much time they spend there. We may use cookies and other technologies to study traffic patterns on our Website, to make it even more rewarding as well as to study the effectiveness of our Website user communications, to customise your experience and to provide greater convenience each time you interact with us.

 

The following table shows the cookies we use.

If you prefer not to enable cookies, certain features of our Website 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 analyse trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base.
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 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.
Updates
First Orion reserves the right, to change, add or remove portions of its privacy policy from time to time by posting the updated privacy policy and effective date. Please check this privacy policy periodically for changes.
Your Rights
You have the right to request access to and correct your personal data held by us. If you wish to obtain a copy of any of your personal data, or if you believe that the personal data relating to you which we collect and maintain is incorrect, please contact us by email or at the address below. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Privacy questions
If you have questions or concerns about First Orion’s privacy policy for the App or Website, or its information practices, please contact us by emailing us at
privacy@tpsprotect.org.uk
or writing to us at:
First Orion UK Limited.
Attention: Legal Team

3 Waterhouse Square, 138 Holborn, London EC1N 2S

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