Effective August 2016
FirstTwo, Inc. (“we,” “us,” or “FirstTwo”) collects information about you through your use of the www.firsttwo.com website and the FirstTwo service (collectively, the “Services”) and through any other interactions you may have with the FirstTwo platform.
This Privacy Policy explains how FirstTwo collects, uses and discloses that information.
We respect the privacy of our users and recognize the importance of protecting your information. By registering for and using the Services, you are accepting the practices described in this Privacy Policy. Capitalized terms that are not otherwise defined in this Privacy Policy have the meaning attributed to them in our Terms of Service (http://www.firsttwo.com/terms). If you do not agree with anything in this Privacy Policy, please do not use the Services. Your continued use of our Services will signify your acceptance of this Privacy Policy.
If you are using the Services pursuant to a service agreement your business or organization has with us, then this Privacy Policy is integrated into and is a part of that service agreement. In the event of any inconsistency between this Privacy Policy and any service agreement, the service agreement and any relevant customer order governs your relationship with us.
1. INFORMATION WE COLLECT & HOW WE USE IT
FirstTwo is the sole owner of the information collected on the Services and we collect Personal Information from our users at several different points.
1.1 Personal Information Defined
The term “Personal Information” as used in this Privacy Policy refers to information that can be used to identify, locate, or contact an individual. This includes your name, username, email address, picture, employer’s name, job title, as well as any contact or other information you choose to provide. It also includes other information that may be associated with Personal Information, such as an internet protocol (“IP”) address, browser type, internet service provider, operating system, and device type.
Personal Information does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
Generally, we collect Personal Information when you provide it directly to us and through technology further described in Section 4 below.
1.2 Information We Collect From Visitors
You are not required to register or provide any Personal Information to us to simply visit and browse our website. However, like many other websites, we 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. More information on the types of information automatically collected and how the information is collected can be found in Section 4 below.
1.3 Registration and Signup
In order to use the Services, you must first complete the registration form and create a username and password. During registration you must give us your contact information (such as your name and email address) and employer information (the name of your organization or agency). If you are registering for a premium portion of the Services, you may also be asked to provide certain financial information (such as a valid credit card number and expiration date).
1.4 How We Use Your Information
All of the information you provide to us during the registration process, through your use of the Services, and through any other interactions with us will be used in the following ways:
(a) To provide the Services to you.
(b) To create a “profile” of your preferences. We tie your Personal Information to information in your profile in order to provide the content of the Services to you on a personalized basis and to identify and authenticate your account when you log in to the Services. We do not share your profile with other third parties. Please see Section 4 for more information.
(c) For billing purposes. If we have trouble processing an order, we will use this information to contact you.
(d) To contact you about your use of the Services and to provide notifications about the Services. Out of respect for your privacy, we present the option not to receive some types of these communications. Please see Section 5 for more information.
(e) To improve the Services.
2. SECURITY
Although no data transmission can be guaranteed to be completely secure, FirstTwo follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. These standards are reasonably designed to:
(a) Ensure the security and confidentiality of your records and information;
(b) Protect against any anticipated threats or hazards to the security or integrity of your records and information; and
(c) Protect against unauthorized access to or use of your records or information that could result in substantial harm or inconvenience to you or any other user of the Services.
Your information is located on secure servers and protected from intrusion using industry-standard practices. We use transport layer security (TLS) when you sign into the Services.
If you have any questions about the security of our Services, you can send email us at support@firsttwo.com.
3. INFORMATION WE DISCLOSE AND WHEN WE DISCLOSE IT
We will not disclose your Personal Information to third parties except to:
(a) Companies affiliated with us (e.g., subsidiaries and other companies owned by or controlled by FirstTwo) who may only use your Personal Information for the purposes described in Section 1.4 above.
(b) Our trusted service providers, including but not limited to payment processors and other third parties that you may directly authorize to receive your Personal Information. Our service providers are bound by law or contract to protect your Personal Information and are only allowed to use your Personal Information in accordance with our agreements with them.
(c) Effect a merger or acquisition or to support the sale or transfer of business assets. If FirstTwo is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or prominent notice on the Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
(d) Enforce our rights or protect our property; protect the rights, property or safety of others, investigate fraud, or respond to a legitimate government request; or as needed to support auditing, compliance, and corporate governance functions.
(e) We may also disclose Personal Information to defend ourselves in litigation or a regulatory action, and when required or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate.
4. COOKIES, PIXEL TAGS AND WEB BEACONS
When you use the Services, we collect certain information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and server logs. As you use the Services, your browser and devices communicate with servers managed by our trusted service providers or us to record the interactivity and to fulfill your requests for the Services.
A “cookie” is a small amount of information that a web server sends to your browser that stores information about your account, your preferences, and your use of the Services. The information from cookies and related technology is stored in web server logs and also in web cookies kept on your computers or devices, which are then transmitted back to our Services by your computers or devices. The cookies are managed by our trusted service providers or us.
Some cookies are temporary, whereas others may be configured to last longer. “Session" cookies are temporary cookies used for various reasons, such as to manage page views. Your browser usually erases session cookies once you exit your browser. “Persistent” cookies are more permanent and are stored on your computer or mobile device even after you exit your browser. We use persistent cookies for a number of purposes, such as retrieving certain information you have previously provided (such as your user id if you asked to be remembered), and storing your preferences (e.g., the way our website’s pages or information is displayed).
Pixel tags and web beacons are tiny graphic images placed on our website or in our emails that allow us to determine whether you have performed specific actions. When you access these pages or open email messages, the pixel tags and web beacons generate a notice of that action and send the notice to us or our trusted service providers. These tools allow us to measure response to our communications and improve the Services.
We collect many different types of information using these technologies. For example, we may collect information from the devices you use to access the Services, your operating system type or mobile device model, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the IP addresses of the devices you use to interact with the Services. We may also collect information about the websites you were visiting before you came to our website or started using the Services and the websites you visit after you leave our Services, if this information is supplied to us by your browser.
In many cases the information we collect using cookies and other tools is used in non-identifiable ways and without any reference to Personal Information. For example, we use information we collect about you to optimize the Services and understand its traffic and usage patterns. In other cases, such as when you access the Services as a logged in and registered user, we associate the information we collect using cookies and related technologies with Personal Information. In either case, this Privacy Policy governs how we use that information.
Additionally, if the settings on your location-aware device allow us to receive location information, we may collect that automatically in order to provide the Services. If we associate location information with other Personal Information, this Privacy Policy will govern how we would use that information.
If you wish to opt out of having cookies set on your browser or device as described above, you may manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. Additionally, we may use tools provided by our trusted service providers such as Google Analytics to track use of the Services. If you would like to opt out of third party tracking via Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. Please note that disabling cookies may disable many of the features available through the Services. We therefore recommend that you leave cookies enabled. Because there is no current industry standard, FirstTwo does not recognize or respond to browser-initiated Do Not Track signals.
5. CHOICE/OPT-OUT
We provide you the opportunity to ‘opt-out’ of having your Personal Information used for certain purposes when we ask for this information. For example, if you do not wish to receive any additional marketing material from us, you can indicate your preference by emailing us at support@firsttwo.com.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the unsubscribe instructions included in each newsletter or communication or by emailing us at support@firsttwo.com.
6. LINKS TO OTHER SITES
This privacy statement applies only to information we collect while rendering the Services. The Services contain links to other sites that are not owned or controlled by us.
Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to read the privacy statements of each and every website that collects your Personal Information.
7. ACCESS TO PERSONAL INFORMATION
If your Personal Information changes, you may correct, update, delete it by making the appropriate change on your account settings page while logged in to the Services.
If you no longer wish to use the Services, you may delete your account information by emailing our Customer Support at support@firsttwo.com.
8. CHANGES
We reserve the right, in our sole discretion, to make changes to this Privacy Policy from time to time. If we decide to change our Privacy Policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently at http://www.firsttwo.com/privacy. If we make material changes to this policy, we will notify you here, by email, or by means of a notice within the Services.
9. CONTACT US
If you have any questions or suggestions regarding our privacy policy, please contact us at: FirstTwo, Inc., 227 Bellevue Way NE #276, Bellevue, WA 98004, or via email to support@firsttwo.com.