First Orion Customer Portal Privacy Policy

Last Updated: May 1, 2023

Version 1.1

First Orion’s Customer Portal located at https://portal.firstorion.com/ is a website provided by First Orion Corp., 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 and is referred to in this Privacy Policy as the “Customer Portal.”

This Privacy Policy covers the collection, use, and disclosure of predominately business information, including identifying information about the registrant (“Registration Information”), information about the telephone numbers the registrant uses to make calls (“Number Information”), the services provided to businesses that utilize the Customer Portal and the technologies used by the Customer Portal.

All other obligations governing the information registrants provide on the Customer Portal and the use of the Customer Portal are set forth within the First Orion Terms of Service (the “Terms”) posted for and applicable to the Customer Portal. The Terms can be found at https://firstorion.com/first-orion-customer-portal-terms-of-service/.

What information First Orion collects

The Customer Portal collects Registration Information and Number Information from registrants in order to provide various services offered through the Customer Portal.

The Registration Information includes information about the responsible business entity who owns the Number Information and how to contact them. The Number Information includes the telephone number itself and other descriptive information about the kinds of calls made by the number such as industry and reason for the call.

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.

First Orion may transmit Registration Information and Number Information to or from the United States for processing, storage or other purposes related to supporting the Customer Portal.

How information First Orion collects is used

The Customer Portal provides access to several services which provide greater transparency to the called party about who is calling them and why.

The basic service provides protection for the registrant’s communications against fraud. The service uses First Orion’s proprietary analytics to identify suspicious calls as possible scams or nuisance calls. The basic service also identifies scam calls from numbers legitimately used only for inbound calls (“Do Not Originate” or “DNO” numbers) when these numbers are fraudulently used for outbound calls. When registering with the Customer Portal, this basic scam protection service is free.

Additional services provide registrant with branded communication solutions such as the opportunity to display up to 32 characters in the caller ID field to provide more information about who is calling and why. These services are provided by First Orion for a fee.

When we disclose Registration Information and Number Information

To help us provide an accurate and more transparent experience for the called party, Registration Information and Number Information may be shared with legal entities within the First Orion group globally who will take steps to safeguard it in accordance with the Terms.

There are also times when it may be appropriate for First Orion to make certain Registration Information and Number Information available to companies that First Orion has a relationship with or that perform work for First Orion with regard to the Customer Portal or to provide call management functions on our behalf. These companies may help us process information, fulfill orders, deliver applications and other services to the registrant, manage and enhance data, provide customer service, assess the registrant’s interest in our applications and services, conduct customer research or satisfaction surveys or offer registrants additional related products and services’.

At times, we may be required by law or litigation to disclose Registration Information and Number Information. We may also disclose Registration Information and Number Information 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, Registration Information and Number Information will likely be among the business assets transferred. Registrants will be notified by email or prominent notice via the Customer Portal of such change in ownership as well as any choices registrants may have regarding this information.

How we protect Registration Information and Number Information

First Orion takes precautions — including administrative, technical, and physical measures — to safeguard Registration Information and Number 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, the Customer Portal may use “cookies” and other technologies to help us understand which parts of the Customer Portal 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 the Customer Portal in order to make it even more user friendly as well as to study the effectiveness of our user communications. And we may use cookies to customize the user’s experience and provide greater convenience each time a user interacts with the Customer Portal. This includes the use of Google Analytics to study traffic patterns to make the user experience more rewarding as well as to study the effectiveness of our 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 a registrant prefers not to enable cookies, certain features of the Customer Portal may not be available once cookies are disabled.

The Customer Portal 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, and to track users’ movements around the Customer Portal.

In addition, we may use pixel tags — tiny graphic images — to tell us what parts of the Customer Portal users have visited or to measure the ease of use for visitors.

Pixel tags also enable us to send email messages in a format that users can read. And they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users.

We also use Hotjar in order to better understand our users’ needs and to optimize the Customer Portal experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Customer Portal and services with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

Updates

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

Privacy questions

If a registrant has questions or concerns about this privacy policy or its information practices, contact us at https://firstorion.com/contact/ or send paper mail to:
Attention: Privacy
First Orion Corp.
520 Main Street, Suite 400
North Little Rock, Arkansas 72114 USA