Privacy Policy – UK & EU

Overview

First Orion UK Limited (company number 09929064), the UK affiliate of First Orion Corp., a Delaware USA company, 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 provides information on how First Orion collects and processes your personal data (i.e., information that relates to an identified or identifiable individual) through your use of our branded communication services. This Privacy Policy covers the collection, use, disclosure, and sharing of your personal data and how the law protects you.

First Orion’s Branded Communication Services

First Orion’s branded communication services (the “Services”) provide companies 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. First Orion is a data processor for these Services.

Our ENGAGE® service allows a richer display of information that is not limited to the caller ID field. This service is provided through our stand-alone ENGAGE App or as a feature of other Apps you may download or have on your mobile device. You can find our Engage App in the Google Play Store for Android devices or the App Store for iPhones.

Our INFORM® service allows businesses that call you to control the caller ID display on your phone (instead of the carrier controlling the display) and may include add-on services that can prevent spoofing. This service is provided through carriers through which First Orion is authorized to provide this service. The use of INFORM is limited to calls being made from and to telephone numbers under the North American Numbering Plan Administrator (NANPA).

Information we may collect from you with regard to the Services:

You may give us information when you register to use the Services or by corresponding with us by phone, email, or otherwise. This includes information you provide when you report a problem with the Services.

Information collected by the Services and how such information is used:

When you register to use our ENGAGE App, the App 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.

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.

First Orion’s Processing of Personal Data

Legal Basis for Processing Personal Data: We rely upon the following legal grounds as a basis for processing your personal data.

To perform our obligations under a contract with you or to make pre-contract arrangements with you.
To provide the Services and carry out the core activities related to our provision of the Services.
For legal and regulatory compliance.
For our legitimate business interests and those of our customers. For example, we have a legitimate interest in providing and improving our Services as well as maintaining and improving the security and integrity of our Services.
In some cases where we send you promotional material by email we obtain your consent as a legal basis to process your personal data.
To respond to your inquiry using the personal data you voluntarily provide on the contact form as necessary to fulfill your request.
You give us your consent to do so for a specific purpose.

Disclosure of Information: First Orion does not sell your personal data collected in connection with our Services. Generally, we may disclose your personal data for our business purposes such as with the following persons or entities.

Persons, companies or professional firms providing advice and consultancy regarding accounting, administrative, legal, tax, financial and/or debt collection matters related to the provision of the Services to First Orion;
Vendors hired to provide support services for First Orion’s lines of business (e.g., hosting providers or e-mail platform providers);
Other companies/entities that are part of First Orion; and
Public entities, bodies or authorities to whom your personal data may be disclosed in accordance with the applicable law or binding orders of those entities or authorities.

Transfer of Personal Data: First Orion is headquartered in the USA. Your personal data may be shared with our affiliated companies who are based in countries other than the country in which you are located. These other countries may have data protection laws that are different from your own country.

If you are located in the EEA or the UK, your personal data may be accessed by First Orion affiliates in the United States. Whenever we transfer your personal data from the UK and EEA to the United States or any other country that has not been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Government, we will ensure that a similar degree of protection is afforded to it by using specific appropriate safeguards approved by the European Commission and the UK Government, which are designed to give personal data the same protection it has in the EEA/UK (for example, requiring the recipient of personal data to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time).

Data Retention: Personal data processed through our Services will be kept by First Orion for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We determine the appropriate retention period for personal data on the basis of the purpose for which we process the personal data, the amount, nature and sensitivity of the personal data processed, the potential risk of harm from unauthorized use or disclosure of the personal data, and whether the purposes of the processing can be achieved through other means, as well as on the basis of applicable legal requirements.

Storage of Personal Data: All personal data relative to the use of the ENGAGE service or App outside of the United States is stored in Ireland and retained until it is no longer needed by our clients. Personal data relative to the INFORM service is stored in the USA and retained until it is no longer needed by our clients.

Data Controller and Processor Roles: First Orion is the data processor for all information collected and processed through our Services.

Your Rights: As a data subject, you are entitled to exercise the following rights at any time:

Access your personal data being processed by First Orion (and/or a copy of that personal data), as well as information on the processing of your personal data;
Correct or update your personal data processed by First Orion, where it may be inaccurate or incomplete;
Request erasure of your personal data being processed by First Orion, where you feel that the processing is unnecessary or otherwise unlawful;
Request the restriction of the processing of your personal data, where you feel that the personal data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
Exercise your right to portability: the right to obtain a copy of your personal data provided to First Orion, in a structured, commonly used and machine-readable format, as well as the transmission of that personal data to another data controller; or
Object to the processing of your personal data, based on relevant grounds related to your particular situation, which you believe must prevent First Orion from processing your personal data.

Aside from the above means, you can also exercise your rights described above by using the form provided at privacy.firstorion.com/. As a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of personal data, if you believe that the processing of your personal data is unlawful.

How we Protect your Personal Data

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.

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.

Privacy Questions

If you have questions or concerns about this privacy policy or our information practices, you can contact us at firstorion.com/contact-us or our Data Protection Officer at privacy@firstorion.com, or by sending paper mail to:

First Orion UK Limited
Attention: Legal Team
10 Temple Back
Suite 2, First Floor
Bristol, United Kingdom
BS1 6FL