Effective Date: January 1, 2020
Information that FirstGroup, its service providers and/or Third-Party Services (defined below) may collect may include personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, and address (“Personal Information”). In addition, Personal Information, once “De–identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is non-Personal Information. Non-Personal Information may be collected, used and shared without obligation to you, except as prohibited by applicable law.
FirstGroup, its service providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, FirstGroup does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information.
The methods that may be used on the Service to collect Usage Information may include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
- Cookies: A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. The Service may associate some or all of these types of cookies with your devices.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from our web server, or from a third party with which we work and is active only while you are connected to the Service and deleted or deactivated thereafter.
Some information about your use of the Service, and certain third-party services, may be collected using tracking technologies, including those that may track Usage Information across time and services and used by FirstGroup and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain third-party services.
If you give us your postal address, we may send you periodic mailings with information on our new products and services. You may also receive business mailings from our sister companies within FirstGroup.
If you supply us with your telephone number, you may receive telephone contact from us with information, such as regarding orders you have placed, new products and services or information on upcoming events.
We value your opinions and comments. You may have the opportunity to give us your feedback through our online form. In requesting information, we may ask for your name, address, zip code, or e-mail address so that we can appropriately identify you.
PERSONAL INFORMATION WE SHARE WITH THIRD PARTIES
FirstGroup may share non-Personal Information, (provided that FirstGroup is aware of no restrictions of FirstGroup’s use, if any), with third parties or FirstGroup’s affiliates (“FirstGroup Affiliates”) for any purpose not prohibited by applicable law. FirstGroup’s sharing of Personal Information is, however, subject to the following:
Marketing: We may use your Personal Information to send you marketing communications. Absent your consent, FirstGroup will not share your Personal Information with third parties, other than FirstGroup Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
Your Disclosure or Consent: Your activities on the Service may, by their nature, result in the sharing of your Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not FirstGroup.
In addition, FirstGroup may share your Personal Information (as well as your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of FirstGroup assets, or transfer of all or a portion of FirstGroup’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
SAFEGUARDS TO PROTECT THE LOSS, MISUSE, OR ALTERATION OF YOUR INFORMATION
FirstGroup takes reasonable measures to protect Personal Information collected on the Service from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and FirstGroup does not guarantee the security of your information collected through the Service.
We believe that protecting the privacy of children is very important. Our Services are not intended for individuals under the age of 18. In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly collect or store any personal information, via the Service, from children under the age of 13. If we discover we have received any personal information from a child under the age of 13 via the Service in a manner not permitted by COPPA, we will delete such data to the extent required by COPPA. If you believe that we have collected any information from anyone under the age of 13, please contact us at the contact points specified below.
EEOC / AFFIRMATIVE ACTION REPORTING
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The Service may include hyperlinks to, or include on or in connection with websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other tracking technology to independently collect information about you and may solicit Personal Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” FirstGroup’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service or by the Third-Party Service that you use. Also, both FirstGroup and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
CHOICES: TRACKING AND COMMUNICATIONS OPTIONS
You can opt out of receiving certain promotional communications (emails or text messaging) from FirstGroup at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from FirstGroup to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, FirstGroup may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or FirstGroup’s ongoing business relations.
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, FirstGroup currently does not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of cross-device data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. FirstGroup supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expects that ad networks FirstGroup directly engages to serve you Interest-based Advertising will do so as well, though FirstGroup cannot guaranty their compliance. FirstGroup is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
FirstGroup may provide web pages or other mechanisms allowing you to delete, correct, or update some of your information, and potentially certain other information about you (e.g., profile and account information). FirstGroup will make good faith efforts to make requested changes in FirstGroup’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from FirstGroup’s databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
Nevada “consumers” have the right to instruct us not to “sell” “covered information” as those terms are defined by Chapter 603A of the Nevada Revised Statutes. You may contact us at USPrivacy@firstgroup.com to be verified and learn more about your opt-out rights under that law.
Attention: General Counsel
600 Vine Street, Suite 1400
Cincinnati, Ohio 45202