First Orion Privacy Policy effective 04/24/2020

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 PrivacyStarTM), and 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 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 Call 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 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 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 your personal information in our Call Knowledge products by going to 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 Suite (Engage® and InformTM 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 is calling and why they are calling so you are comfortable answering the call.

Our InformTM service allows a business who is calling you to control the caller ID 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 through our stand-alone Engage® App, or as a feature of other Apps you may download. You can find our Engage® App in the Google Play Store for Android devices or the App Store for iPhones.

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®- 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 outside of the App. Once the enhanced call is delivered to your phone, the contact is automatically 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 Call Protection Suite

First Orion’s Call 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 to 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 PrivacyStarTM App or you can access these features through your telecommunication carrier if they are a First Orion client. You can find our PrivacyStarTM 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 whom 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 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 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 any incoming call from a number already in your contacts displays the name from 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 which 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 U.S. 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 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 Informationu>) 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 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 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.

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

Personal information stored in the U.S. 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 Privacy Rights

Verified Requests

You have the right to submit a request to First Orion to exercise your right to know, your right to delete, and in some cases your right to opt-out as described below. Before fulfilling the request, First Orion must verify that you are the one about whom it has collected personal information. Failure to satisfactorily verify your identity will prevent the request from being fulfilled in entirety.

Right to Know

You have the right to know what personal information is collected, used, disclosed, or sold by First Orion and how the information will be used. Upon receipt of a verified request, First Orion will disclose to you the specific pieces of personal information it has collected. The types of sources from which the personal information is collected, the business purpose for which the personal information is collected and the categories of third parties with whom First Orion shares the personal information can be found in this privacy policy.

Right to Delete

You have the right to request that First Orion delete your personal information in certain circumstances. If you submit a verified request to delete, First Orion will delete all of your personal information from its records unless that personal information is necessary for First Orion 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 your relationship with First Orion or comply with a legal obligation.

Right to Opt-Out of the Sale of Personal Information

You have the right to direct First Orion to stop selling your personal information to a third party. If you submit a verified request to opt-out, First Orion will stop selling personal information about you to third parties. If, later, you want to allow First Orion to sell your personal information, you can send an opt-in request to First Orion.

First Orion provides a prominent link on our website (“Do Not Sell My Personal Data”) to a webpage to submit a request.

If First Orion collects personal information but does not sell it First Orion will so state in its privacy policy.

Additional Information about a Consumer’s Rights

Personal Information

The rights listed above only 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 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

In those instances where First Orion is a service provider to another business and you send First Orion a request, the request can only be acted on by the business, not First Orion.

Consumer requests handled by First Orion in the past year:

Year 2019 Total Requests to Exercise 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
Received 50 0 0 50
Fulfilled 50 0 0 50
Denied 0 0 0 0

Your EU and UK 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.

Privacy questions

If you have questions or concerns about this privacy policy or our information practices, please contact us at 1-877-640-4220, https://firstorion.com/contact-general/ or by sending paper mail to:

First Orion Corp.
Attention: Legal Team
520 Main Street, Suite 400
North Little Rock, AR 72114 USA
© 2020 First Orion Corp. All rights reserved.

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