First Orion Privacy Policy(Effective 12/28/2019)

First Orion Corp 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 covers the collection, use, disclosure and sale of personal information and the technologies used by First Orion in the U.S. and Canada for all First Orion’s products and services, our free or subscription-based Apps (including PrivacyStar™), and when you visit our website.

Our products and services include various features and functionality to tell you who is calling and why, identify and block businesses who are likely scammers, do reverse telephone number lookups, file complaints, report call violations to the proper authorities, and provide enhanced information that can be displayed on your device. In addition, our Call Knowledge Suite helps companies verify who that phone number belongs to, what type of device it is, 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 Knowledge Suite

First Orion’s Call Knowledge Suite helps businesses reach the right people and the right companies in a compliant manner with several 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 phones), including names and addresses, the status of the phone number (active or inactive) and other information about the line and device. This information is collected by First Orion from third parties, both carriers and data brokers, 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 devices are ported from one carrier to another. We also identify businesses who 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 the personal information in our Call Knowledge products by going to www.privacy.firstorion.com

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

First Orion’s Call Enhancement (Engage™ and Inform™ Services)

First Orion’s Call Enhancement Suite of services provides companies who call you the ability to display enriched, branded, personalized information so you know more about who’s calling and are comfortable answering the call.

Our Inform™ service allows a business who is calling you to control the called ID 15-character display on your phone instead of the carrier controlling the display. This service is provided through carriers who are clients of First Orion.

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 other Apps you may download.

When you download the App, it 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 the App to function, you will need to allow it to access your contacts so the Engage™ deliver 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 outside of the App. Once the enhanced call is delivered to your phone, the contact is deleted.

All personal information relative to our Call Enhancement Suite is stored in the U.S. and retained until it is no longer needed by our clients.

We do not sell your personal information in our Call Enhancement Suite of services.

First Orion’s Protection Suite

First Orion’s Protection Suite of services provides business labels, such as “Scam Likely”, and “Telemarketer”, to identify likely scammers and other types of callers and help you not become a victim of phone fraud or to be bothered by unwanted calls. In addition, the services 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 Call Protection Suite of services in several ways. You can download the free or paid First Orion PrivacyStar™ App or you can access these features through your telecommunication carrier if they are a First Orion client. You can find our PrivacyStar™ App in the Google Play Store for Android or the App Store for iPhones.

You 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 block a call or report 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 App, you will need to agree to several questions 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 all the other call management activities provided in the App such as identifying unknown callers, blocking call, filing complaints and receiving enhanced caller information about who is calling and why.

Allow First Orion to send and view SMS messages?

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

In the U.S. if you voluntarily choose to provide complaint information about calls you receive, this information will be provided to the appropriate government agencies such as, but not limited to, the Federal Trade Commission (FTC), the Federal Communication Commission (FCC) and the Consumer Financial Protection Bureau (CFPB) to aid in ther 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 the complaint and call block trends.

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

All personal information relative to our Call Protection Suite is stored in the U.S. and retained for 12-18 months.

First Orion’s Corporate Website

First Orion has a corporate website that explains, among other things, 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 (Do Not Sell My Personal Information) to opt-out of the sale of your personal information from our Call Knowledge Suite of products and services.

You provide all the personal information collected on the First Orion website to help us deliver a better level of user experience on the site. 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.

All personal information relative to a First Orion website is stored in the U.S. indefinitely.

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 consist 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 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 “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. The 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.

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

Personal information stored in the U.S. may, therefore, 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 don 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 Privacy Rights

    Verified Request

  • Consumers have the right to submit requests to a business to exercise their right to know, their right to delete and in some cases their right to opt-out as described below. A business must verify
    that the consumer making the request is the consumer about whom the business has collected the personal information before it fulfills the request. Failure to satisfactorily verify the identity of the consumer will prevent the request from being fulfilled in entirety.
    Right to Know

  • Consumers have the right to know what personal information is collected, used, disclosed, or sold by a business and how the information will be used. Upon receipt of a verified request, a business must
    disclose to the consumer the specific pieces of personal information is collected, the business purpose for which the personal information is collected, and the categories of third parties with whom the business shares the personal information.
    Right to Delete

  • Consumers have the right to request that businesses delete their personal information in certain circumstances. If a consumer submits a verified request to delete, the business must
    delete all the consumer’s personal information from its records unless that personal information is necessary for the business to complete the transaction for which the information was collected, to protect against deceptive, fraudulent, or illegal activity, to enable solely internal uses that are aligned with the consumer’s relationship with the business or comply with a legal obligation.
    Right to Opt-Out of the Sale of Personal Information

  • Consumers have the right to direct a business that sells personal information to stop selling that information to a third party. If a consumer submits a verified request to opt-out, the business must stop selling personal information about the consumer to third parties. If at a later date, the consumer wants to allow the business to sell the personal information, the consumer can send an opt-in request to the business.Businesses that sell personal information must provide a prominent link on their website (“Do Not Sell My Personal Data”) to a webpage to submit a request. A business that collects personal information, but does not sell it, must so state in its privacy policy.

Additional Information about a Consumer’s Rights

    Personal Information

  • The rights listed above only apply to a consumer’s personal information – meaning information that identifies, relates to, describes, or could be reasonably be linked with a particular consumer (such as your name, your phone number, online identifiers, records of services purchased, purchasing history, browsing or search history, and inferences drawn from any other personal information). Personal information does not include publicly available information that is made available from government records.
    Service Providers

  • If a service provider that processes personal information on behalf of a business receives a request from a consumer, the service provider will inform the consumer that the request should be submitted directly to the business it services and, when feasible, provide the consumer with contact information for that business.

Consumer requests handled by First Orion in the past year:

Year 2019 Total Requests to Excercise Consumer Rights Right to Know (Access Categories and/or Elements of Personal Information) Right to Delete Personal Information Right to Opt-Out of the Sale of Personal Information
Recieved 50 0 0 50
Fulfilled 50 0 0 50
Denied 0 0 0 0

 

Your EU and Privacy Rights

First Orion is certified for the EU-U.S. Privacy Shield with the Department of Commerce. First Orion’s Privacy Shield Policy can be found at www.firstorion.com/privacy-shield-policy/
and our Privacy Shield Policy for Human Resource Data can be found at www.firstorion.com/privacy-shield-for-human-resource-data.

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.

First Orion Global Privacy Principles

  • Transparency: We will provide information about how data is collected, used and shared so you can make informed decisions.
  • Control: We will give you choices to put you in control of your privacy.
  • Security: We will protect the data you provide to us through strong security, encryption and data minimization.
  • Value to You: The personal data we collect will be used to provide a benefit to you.

Your Rights

  • Verified Requests to Access, Delete or Opt-Out: You may submit a personal request to access your personal information, opt-out of the sale of your information, or in some cases to delete the information. Before fulfilling the request, we must verify your identity.

Additional Information about Your Rights

  • Personal Information: These rights apply to your personal information – meaning information that identifies, relates to, describes, or could reasonably be linked to you (such as your name, your phone number, online identifiers, records of services or products purchased, browsing or search history, and inferences drawn from other personal information).
  • Service Providers: In those instances, where we are a service provider processing your information for another organization with whom you have a relationship, requests can only be acted on by that organization, not First Orion.

Contact Us

  • Email:
  • Phone: 501-358-4061

Our Policies

Exercise Your Rights

Privacy questions

If you have questions or concerns about this privacy policy or our information practices, please contact us at 1-877-640-4220, First Orion Contact or by sending paper mail to:

First Orion Corp.
Attention: Legal Team
500 President Clinton Avenue, Suite 215
Little Rock, AR 72201 USA