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Legal & Policy

Multi Tenant Privacy Policy

Last Updated: February 22, 2022

Firstup (“Firstup”) provides a service that connects Firstup’ customers with their affiliate(s), employees, contractors, consultants, customers, agents, partners, bloggers, or any other party who has an account and has been granted access to the service by organization pursuant to an agreement between Firstup and its customer (each a “User”). This Privacy Policy explains how Firstup collects, uses, and discloses information about you as a User through its platform, websites, mobile applications and other online services that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy explains how Firstup collects, uses, and discloses information when you interact with a Firstup-branded Service for certain purposes and does not cover the data practices of customers that use Firstup technology to collect information from or about their Users. Please visit the privacy policy of the Firstup customer who has granted you access to the services to learn about their data practices with respect to the information they collect using Firstup technology.

We may change this Privacy Policy from time to time provided that they do not adversely affect your rights unless so mandated by law. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

Collection of InformationInformation About Your Use of the Services

Automatically Collected Information

When you access or use our Services, we automatically collect information about you, including:

Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, page viewed, your IP address and the referrer domain if you visited our platform from an external site.

Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services and help deliver cookies, count visits and understand usage. For more information about cookies and how to disable them, please see “Your Choices” below.
Use of InformationWe use the information we collect to provide, maintain, and improve our Services, such as to deliver and customize the Services, administer customers’ accounts, and communicate with customers about our Services and other products or services that may be of interest.

We may also use the information we collect to:

monitor and analyze trends, usage and activities in connection with the Services;

detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Firstup and others;

determine what products you and others might be interested in order to craft solutions to business problems; and

track communication preferences, so that communications are aligned with your wishes, including requests to not be contacted; and

combine your information with other information that is available to us, including information from other sources.
Sharing of InformationWe may share information we collect as follows or as otherwise described in this Privacy Policy:

With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;

In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Firstup or others;

In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

Between and among Firstup and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and

With your consent or at your direction. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
SecurityFirstup takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Data RetentionWe store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
Transfer of Information to the U.S. and Other CountriesFirstup is based in the United States and we process and store information in the U.S. As such, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it e.g. by signing the standard contractual clauses stipulated by the EU Commission with the data recipients or by relying on other approved methods. If Firstup transfers personal data to official authorities outside the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, if required by law, express consent has been given or is based on the legitimate interest of Social Chorus or the party for data protection purposes, e.g. internal administrative purposes and no higher legitimate interest of the data subject.
Residents of the EEA, UK, and SwitzerlandIf you are a resident of the EEA, UK, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, UK or Switzerland, when we process your personal data, we will only do so under the following circumstances:

· In order to perform our responsibilities under a contract with our customers, such as by providing the Firstup services you requested.

Data Subject Requests

If you are a resident of the EEA, UK, or Switzerland, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you should contact the organization who has granted you access to our services. You may also contact us using the contact information below to exercise these rights, but be advised that we generally do not retain the personal data we collect to identify the customer experiences you are eligible to access, and thus will likely not be able to honor your request.

Questions or Complaints

If you are a resident of the EEA, UK, or Switzerland and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:

https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm or
https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html.

Compliance with Privacy Shield FrameworksFirstup has withdrawn from the Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the European Economic Area, and Switzerland to the United States. Firstup will continue to apply the Privacy Shield Principles to the personal information that we received while participating in the Privacy Shield.
Your ChoicesYou must contact the organization who has granted you access to our services to update, correct or delete the information they collect about you using our services. If you are unable to do so, please contact us at the address below.
CookiesMost web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.
Your California Privacy RightsConsumers residing in California have certain rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). If you are a California resident, this section applies to you. 

California Consumer Privacy Act

Additional Disclosures Related to the Collection, Use, Disclosure and Sale of Personal Information

Collection and Use of Personal Information: In the preceding 12 months, we have collected the following categories of personal information: IP Address, Email Address, First Name, Last Name and Device Information. We collect personal information for the purposes described in the “Use of Information” section above.

Disclosure of Personal Information: We may share your personal information with third parties as described in the “Sharing of Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information: IP Address, Email Address, First Name, Last Name and Device Information.

Sale of Personal Information: California law requires that we provide transparency about personal information we “sell”. Firstup does not sell any information collected from you or your company on our Firstup branded end user services.

Your Consumer Rights

If you are a California resident, you have the right to (1) request more information about the categories and specific pieces of personal information we have collected, sold and disclosed for a business purpose in the last 12 months, (2) deletion of your personal information, and (3) opt out of the sale of your personal information, if applicable, and (4) be free from discrimination for exercising your rights under the CCPA. You may make these requests by calling (888) 674-1158 or emailing support@firstup.com.

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes.  If you are a California resident and would like to make such a request, please contact us by calling (888) 674-1158 or emailing support@firstup.com.
Contact UsIf you have any questions about this Privacy Policy, please contact us at:

In the U.S. and other locations outside of the EU:

Firstup Inc.

123 Mission St, 25th Floor

San Francisco, California 94105

Email address: privacy@firstup.com

Phone: 844.975.2533

In the EU:

Firstup UK Limited

New Penderel House, 4th Floor

283-288 High Holborn,

London WC1V 7HP

United Kingdom

Email address: privacy@firstup.com