First Orion’s Privacy Policy (US and Canada)

Effective April 15, 2024

First Orion Corp. (“First Orion,” “we,” or “our”) is a business dedicated to using technology and data to give consumers tools to recognize and manage calls they receive and to help businesses reach the right people in a compliant manner. Our mission is to provide transparency and control in communication that empowers people to trust their phones again.

This Privacy Policy describes how we collect, use, and share your personal information. “Personal information” means any information that relates to an identified or identifiable individual. The Privacy Policy applies to information we collect when you use our website and in connection with our products and services.

Our products and services include various features and functionality to tell you who is calling and why, identify and block calls from businesses who are likely scammers, do reverse telephone number lookups, file complaints, and report call violations to the proper authorities, and have enhanced information displayed on your device about who is calling you and why. In addition, our Call Knowledge Suite helps companies verify to whom the phone number belongs, what type of line it is (wireless, landline, or other), and whether a number is in service.

Your Rights as a Consumer

First Orion takes the privacy of personal information about individuals seriously. Under various federal and state laws, you have certain rights related to how your personal information is collected, used, disclosed, and sold. First Orion extends these privacy rights to anyone who is a resident of the United States or Canada. In addition, these rights apply differently to each line of business as described below. A general description of your rights is provided at the end of this Privacy Policy.

First Orion’s Customer Portal

First Orion’s Customer Portal located at https://portal.firstorion.com is a website that collects registration information and phone number information from businesses who register in order to provide various services offered through the Customer Portal.

The registration information includes information about the business entity that owns the phone number information and how to contact the registrant. The number information includes the telephone number itself and other descriptive information about the kinds of calls made by the number such as the registrant’s industry and the reason for their calls.

First Orion may obtain other information about registrants on the Customer Portal from third parties and combine it with information provided by the registrant to create a more accurate reflection of who is calling and why.

More information about the Customer Portal can be found at https://firstorion.com/first-orion-customer- portal-privacy-policy/.

First Orion’s Branded Communication solutions

First Orion’s INFORM® branded communication solutions available through the Customer Portal provide businesses who call you the ability to display enriched, branded, personalized information so you know more about who is calling and why they are calling so you are comfortable answering the call.

These solutions are provided through carriers and their service providers who are clients of First Orion. First Orion is a data processor for the calling party for these services. We also offer solutions that prevent spoofing by authenticating calls before they terminate in the carrier network. Our optional INFORM feature called Paired prevents a spoofed call from being branded, while SentryTM prevents spoofed calls from being delivered. These solutions require that the business provide the calling party number and called party numbers as part of a pre-call API request. Called party numbers received with the pre-call API request are immediately encrypted and the hashed value is stored only for the duration of the pairing.

Our ENGAGE® service allows a richer display of information that is not limited to the caller ID field. This service is provided as a feature of Apps you may download or have on your mobile device. For ENGAGE to function, you will need to allow the App to access your contacts so the ENGAGE delivery service can dynamically create a contact for incoming calls that display the enhanced information. We do NOT export any information from your contacts for any purpose. Once the enhanced call is delivered to your phone, the contact is automatically deleted.

The App also collects identifying information in the form of your phone number and uses it initially for identity validation purposes. We also use your phone number and other specifications about your device so we know where to deliver the enhanced information about the caller and to properly deliver the message in a compatible format.

Any personal information provided by a business in connection with its use of our Branded Communication services is stored in the USA and retained until it is no longer needed by our clients.

We do not sell any personal information obtained in connection with our Branded Communication services.

First Orion’s Communications Protection services

First Orion’s Communications Protection services provide business labels such as “Scam Likely” and “Telemarketer” to identify likely scammers and other types of callers to help you to avoid becoming a victim of phone fraud or being bothered by unwanted calls. In addition, these solutions offer various other features and functionality for you to block unwanted, private, or unknown calls, do reverse telephone number lookups, file complaints, and report call violations to the proper authorities.

You can take advantage of First Orion’s Communications Protection services in several ways. You can download the free First Orion PrivacyStar® App or you can access these features through your telecommunications carrier if they are a First Orion client. You can find our PrivacyStar App in the Google Play Store for Android devices or the App Store for iPhones.

Your phone number will be used for identity validation purposes and to know who to bill for fee-based services as well as to improve the functionality of our Apps and carrier services.

To provide this service, First Orion’s data scientists analyze information from your carrier and the App about the calls you receive and the actions you take (such as blocking a call or reporting a problem). We also collect and analyze identifying information (name, address, and phone number) about businesses from third parties, including carriers and data brokers, and publicly available government records to accurately identify business lines.

When you download the PrivacyStar® App, you will need to agree to several permissions so that it functions properly. The questions may vary depending on whether you are on an Android or iOS device since these operating systems function differently.

– Allow First Orion to make and manage phone calls?

This allows the App to launch a call from your detail screen when you touch the phone icon and to perform the other call management activities provided in the App such as identifying unknown callers, blocking calls, filing complaints, and receiving enhanced caller information about who is calling and why.

– Allow First Orion to access your contacts?

We want to assure that any incoming call from a number already in your contacts displays the name stored in your contacts on your device. We do NOT export outside the App any information from your contacts for any purpose.

– Allow First Orion to send and view SMS messages?

This allows the App to streamline the verification process that sends an SMS message when you first launch the App and to block SMS messages from the same numbers used to make scam calls. The App does not do anything else with SMS messages.

In the USA if you voluntarily choose to provide complaint information about calls you receive, this information will be provided to the appropriate government agencies including, but not limited to, the Federal Trade Commission (FTC), the Federal Communication Commission (FCC), and the Consumer Financial Protection Bureau (CFPB) to aid in their enforcement activities. We may also use complaint information to assist calling parties in understanding how individuals who are called view their calling practices and to better understand complaint and call block trends.

First Orion does not sell any personal information collected in connection with our Communications Protection services.

All personal information relative to our Communications Protection services is stored in the USA and retained for 12-18 months.

First Orion‘s Call Knowledge Suite

First Orion’s Call Knowledge Suite helps businesses reach the right people and the right companies in a compliant manner with products and services that provide information our clients need to comply with various telecommunication laws and regulations.

Our Call Knowledge Suite collects and sells information about a phone number (both consumer and business lines), including names and addresses, the status of the phone number (active or inactive), and other information about the line. This information is collected by First Orion from third parties, both carriers and data brokers, from our own research activities, and from publicly available government records.

Our clients, businesses, and data resellers use this information to verify contact numbers, know the type of line (landline or cell) so they can comply with various laws and regulations, and know whether a line is active or inactive so they won’t waste money trying to call it. In addition, we provide information when phone lines are ported from one carrier to another. We also identify businesses that our analytics show are likely scammers. Finally, we use this information internally to improve the functionality of our Apps and services.

You may opt out of the sale of your personal information in our Call Knowledge products by going to https://privacy.firstorion.com.

All personal information relative to our Call Knowledge Suite is stored in the USA and retained until the information is no longer accurate.

First Orion’s Corporate Website

First Orion has a corporate website that describes our lines of business and provides a link to this Privacy Policy which explains your rights relative to each line of business, how to contact us, and a link, privacy.firstorion.com, to opt out of the sale of your personal information from our Call Knowledge Suite of products and services.

Personal information collected on the First Orion website will help us deliver a better user experience. You may provide your identifying information including name, mailing address, phone number, email address, contact preferences, and commercial information relating to an inquiry or support issue. This enables us to give you convenient access to First Orion 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.

The information you provide related to an inquiry may be shared with one of our authorized resellers if your business better fits the reseller’s market focus. This is for the purpose of providing more relevant information about how our products and services are used and to provide better support if you need to know more about these offerings.

All personal information collected through the First Orion website is stored in the USA indefinitely.

Cookies and other technologies

As is standard practice on many corporate websites, First Orion uses “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 website or the First Orion Customer Portal 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 other content. When 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.

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. Personal 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 personal information you choose to submit in these forums. In addition, First Orion may, at its sole discretion, delete information from the bulletin board at any time.

First Orion does not sell any personal information collected in connection with our website.

Personal information stored in the United States may be accessed by courts, law enforcement, and national security authorities in the United States upon First Orion receiving a proper request.

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.

Children

We do not sell the personal information of a consumer if we know that the consumer is less than 16 years old unless the consumer, or the consumer’s parent or guardian if the consumer is between the ages of 13 and 16, has affirmatively authorized the sale of the consumer’s personal information. We do not knowingly collect personal information from children under 13 for marketing purposes. If a child under 13 submits personal information to First Orion via our website and we learn that that personal information is about a child under 13, we will delete the information as soon as possible.

Your State Law Privacy Rights

Several states have enacted laws governing the processing of personal information. To learn more about your rights under State Privacy Laws, please see the State Privacy Notice

Your EU and UK Privacy Rights

First Orion complies with applicable local privacy laws with regard to the collection and use of personal information received by First Orion in the US from the EU, UK and other countries.

Updates

First Orion reserves the right, at its sole discretion, to change, add, or remove portions of its Privacy Policy from time to time by posting the updated Privacy Policy and effective date. It is your responsibility to check this Privacy Policy periodically for changes.

Employees and Prospective Employees

First Orion’s Global HR Privacy Notice can be found at https://firstorion.com/hr-privacy-notice-global/

Privacy questions

If you have questions or concerns about this Privacy Policy or our information practices, please contact us at 1-877-640-4220, privacy@firstorion.com, or https://firstorion.com/contact/.