Effective Date:  June 23, 2021

PRIVACY POLICY

This Privacy Policy describes the privacy practices of FirstlySM (“we,” “us,” or “our”), including what Personal Information we collect, what we do with it, how share it, and your rights regarding that Personal Information.   Please read this Privacy Policy carefully.  By accessing or using our Services, you acknowledge that have read and agreed to the terms in this policy.

Applicability:

This Privacy Policy applies to all Firstly users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all Firstly services, including our websites (including  and any of its subdomains, the “Website”), web applications (“Firstly Apps”), mobile applications (“Mobile Apps”), and related services (collectively, the “Services”).

Personal Information Collected

Information You Provide. The amount and type of information collected depends on the nature of your interaction with Firstly and its Services.  At a minimum, we ask all visitors to provide an email address (“Personal Information”). Visitors can always refuse to supply Personal information, with the caveat that it may prevent them from engaging in certain Services. 

Information We Collect When You Use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding your device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, among other data.

All of the information collected will be handled in accordance with state and federal privacy laws.

How Your Personal Information is Shared

Firstly discloses Personal Information to employees, third party service providers, affiliates, and subcontractors that need access that information to enable Firstly to provide the Services and who agree not to disclosure your Personal Information to others.  By accessing and using the Services, you consent to the transfer of your Personal Information to them.  Firstly will disclose your Personal Information when required to do so by law, if you give permission to have your information shared or when Firstly believes in good faith that disclosure is necessary to protect the property, rights or interest to Firstly, third parties or the public at large.


How Your Personal Information is Used

We use your Personal Information for the following purposes: (1) to provide and operate the Services; (2) to further develop, customize, expand, and improve our Services; (3) to provide you with ongoing customer assistance and technical support; (4) to be able to contact you with general or personalized service-related notices and promotional messages; (5) to facilitate, sponsor, and offer certain contests, events, and promotions, determine participants’ eligibility, monitor performance, contact winners, and grant prizes and benefits; (6) to analyze our performance and marketing activities; (7) to create aggregated statistical data and other aggregated and/or inferred information, which we or our business partners may use to provide and improve our respective services; (8) to enhance our data security and fraud prevention capabilities; and (9) to comply with any applicable laws and regulations.

How Your Personal Information is Stored

Your Personal Information may be stored in data centers located in the United States of America.

Our Retention Policy

We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information from our live systems. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honor your request. Firstly will not delete personal data from logs or records necessary to the operation, development, or archives of the Firstly.

If you would like to request deletion of your Personal Information, please email us at support@firstly.com; please include “Deletion Request” in the subject line.

Your Rights

You may have certain rights under data protection laws in relation to the personal information we hold about you. In particular, you may have a right to:

  • request a copy of personal information we hold about you;
  • ask that we update the personal information we hold about you, or independently correct such personal information that you think is incorrect or incomplete;
  • ask that we delete personal information that we hold about you from live systems, or restrict the way in which we use such personal information (for information on deletion from archives, see the “Retention of personal information” section);
  • object to our processing of your personal information; and/or
  • withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

If you would like to exercise these rights or understand if these rights apply to you, please contact us.

CHANGES TO POLICY

Firstly may change its Privacy Policy from time to time, and in our sole discretion. You are encouraged to check this page for any changes to our Privacy Policy.   Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

CONTACT US

Please contact us if you have any questions about our Privacy Policy or your rights related to your Personal Information at support@firstly.com.