PLEASE READ THE OBJECT FIRST PRIVACY POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION THAT YOU SHOULD KNOW BEFORE USING THE OBJECT FIRST WEBSITE AND/OR SERVICES. BY ACCESSING AND/OR USING THE OBJECT FIRST WEBSITE OR SERVICES, YOU WILL BE DEEMED TO HAVE WHOLLY ACCEPTED THE TERMS AND CONDITIONS OF THIS Object First PRIVACY POLICY.

Last Updated June 28, 2022

Your use of the Object First, LLC. and its affiliates (“Object First”), if and as applicable, Website and Services, including any dispute concerning your online privacy therewith, is subject to Object First’s Privacy Policy (“Privacy Policy”) and Object First Terms of Use and Services (“Terms of Use”). By using the Object First  Website and/or Services, you ACCEPT the practices set forth in the Privacy Policy and the Terms of Use. For this reason, please frequently refer to the Privacy Policy to ensure your continued ACCEPTANCE of all Object First practices relating to your personal data/information (“Personal Information”). Your continued use of any portion of the Website and/or Services following the posting of an updated Privacy Policy will constitute your full ACCEPTANCE of any changes.

Object First complies with the EU-US Privacy Shield (the “Framework”) Principles regarding all Personal Information received in the United States (“U.S.”) from the European Union (“EU”) in reliance on the Privacy Shield, and is an active participant in the Framework. As such, Object First is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Object First’s commitment to the Framework’s Principles is outlined in Sections L & M, below. To learn more about Privacy Shield and the Principles You can visit the Privacy Shield Website.

When you visit Object First’s Website at https://objectfirst.com/ (“Website“), and use Object First’s products or services (“Services”), you trust Object First with your Personal Information. Object First takes your privacy very seriously which is why this Privacy Policy explains what information Object First may collect or receive, how it uses such information, and what rights you have regarding your Personal Information. Thus, please read through the Privacy Policy carefully before you access or use any Object First Services.

The Privacy Policy applies to all Personal Information collected through your use of the Website and Services. Object First is committed to protecting your Personal Information and your right to privacy. If you have any questions or concerns about Object First’s Privacy Policy or practices with regards to your Personal Information, please contact Object First’s Data Protection Officer (“DPO”) at XXXXXX as outlined in Section L, below

A. UPDATES; CHANGES IN PRIVACY POLICY

Object First reserves the right to modify or update the Privacy Policy at any time and will notify you as to any changes via the Website, by email, or as outlined in the Terms of Use. The modified or updated Privacy Policy will be indicated by a “Last Updated” or “Revised” date and the updated version will be effective as soon as it is accessible. Object First wants you to always be aware of what Personal Information it collects, how Object First uses that information, and under what circumstances Object First may disclose your Personal Information. All Personal Information that Object First may collect or receive will be handled in accordance with the Privacy Policy in effect at the time the information is collected. If the Privacy Policy changes in any significant respect in the meantime, Object First will not (without your permission) use your Personal Information in a manner that is inconsistent with the Privacy Policy in effect at the time your information was collected.

B. PERSONAL INFORMATION YOU DISCLOSE TO OBJECT FIRST

Object First may collect Personal Information that you voluntarily provide to it when registering on the Website to receive information about Object First Services, obtaining demo samples or Services, or when participating in other activities on the Website or otherwise contacting Object First. The Personal Information that Object First may collect depends on the context of your interactions with the Website and Services. Such information may include:

Name and Contact Data: first and last name, job title, corporate e-mail address, your employer, phone number, and your country of residence.

Credentials: user account details, passwords for authentication, and account access. Object First may also use similar credentials, like password hints and other security information, as the case may be.

Object First requires that all Personal Information that you provide to be true, complete and accurate. You must notify Object First or update your account if any changes to such Personal Information occurs.

C. INFORMATION AUTOMATICALLY COLLECTED

Some information is collected automatically when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Website and other technical information. This information is primarily needed to maintain the security and operation of the Website and for Object First’s internal analytics and reporting purposes.

Like many businesses, Object First also may collect or use Personal Information associated with cookies and similar technologies for advertising or other similar purposes. However, any such uses of Personal Information and cookies will receive the utmost care and attention from Object First. Any vendors or third parties used for advertising will be reputable and abide by at least similar standards of data protection to that of Object First.

D. INFORMATION COLLECTED FROM OTHER SOURCES

Object First may purchase or receive limited data from public databases, marketing partners, or other publicly available sources. Examples of the information Object First may receive from other sources include: social media profile information; marketing leads; search results; and links to paid listings (such as sponsored links).

Furthermore, Object First may collect your Personal Information when you contact Object First’s customer support team via call, email or another communication tool. The purpose of collecting such information is to help you solve any issue you have with Object First Services. The legal basis of collecting this information is Object First’s fulfillment of contractual or pre-contractual obligations to you or your consent thereto. Additionally, Object First may record support team calls. The purpose of call recording is quality control of Object First’s customer support services and personnel training. The legal basis of call recording is Object First’s legitimate interests in retaining you as a customer and providing you with first-class customer support services.

Object First’s trusted partners, such as Google, help Object First to place advertisements on and off the Website and perform analytics. Please read Object First’s current trusted partners’ privacy and cookies policies below:

All processing of your Personal Information is based on legitimate purposes including business interests, fulfillment of contractual obligations, and/or your consent. To opt-out from use of your Personal Information for advertising purposes, contact Object First’s DPO as outlined in Section M, below.

E. HOW OBJECT FIRST USES YOUR INFORMATION

Object First may use your Personal Information for a variety of business purposes, as described in detail, below. Object First may process your Personal Information for such purposes in reliance on its legitimate business interests in order to enter into or perform a contract with your consent. The following indicates the specific processing grounds on which Object First relies, if and when it processes any Personal Information.

As a non-exclusive list of examples, Object First may use your Personal Information:

To facilitate the creation of an account and log-on process with your consent;

  1. To keep in touch with you for administrative, business, or contractual purposes with your Consent;
  2. To keep in touch with you for administrative, business, or contractual purposes with your Consent;
  3. For advertising and marketing purposes, if this is in accordance with your preferences. You can always opt-out of Object First’s marketing e-mails at any time by Contacting Object First as outlined in Section L, below;
  4. To send you Services and new feature information depending on your account preferences;
  5. To notify you about changes and updates to Object First’s terms, conditions, or policies;
  6. In order to fulfill and manage your orders for contractual reasons. Object First may use your information to fulfill and manage your orders, payments, returns, or exchanges made through the Website or otherwise;
  7. To request feedback or comments from you concerning Object First Services;
  8. To respond to legal requests and prevent harm. For example, if Object First receives a subpoena or other legal request, Object First may need to inspect the Personal Information it holds in order to determine if and how to respond; and
  9. To view your online actions across the Website and Services for data analysis, specifically, identifying usage trends, determining the effectiveness of promotional campaigns, and to evaluate and improve the Website, products, Services, and your overall experience.

F. HOW OBJECT FIRST SHARES YOUR INFORMATION

Object First only shares Personal Information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. As a non-exclusive list of examples, Object First only shares and discloses your Personal Information in the following situations:

  • Compliance with Laws. Object First may disclose your Personal Information where it is legally required to do so in order to comply with applicable law, governmental requests, or a judicial proceeding, court order, or legal process such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements);
  • Vital Interests and Legal Rights. Object First may disclose your Personal Information where it believes it is necessary to investigate, prevent, or take action regarding potential violations of Object First policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or in the event of litigation;
  • Vendors, Consultants and Other Third-Party Service Providers. Object First may share your Personal Information with third party vendors, service providers, contractors or agents (“Third-Party Processors”) who perform services on its behalf and require access to such information. For example, Object First may use third parties for technical and customer support, payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. These Third-Party Processors may be located within the EU, the U.S., or another country in Object First’s sole discretion, however, any third party with which Object First shares your Personal Information will be held to similar data protection standards to that of the EU-US Privacy Shield Framework and the GDPR.
  • Tracking Technology. Object First also may allow select third parties to use tracking technology on the Website, which will enable the collection of data about how you interact with the Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content or pages, and better understand online activity in order for Object First to better its Website and Services. Object First does not share, sell, rent or trade any of your Personal Information with third parties for their promotional purposes;
  • Business Transfers. Object First may share or transfer your Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of its business to another company;
  • Business Partners. Object First may share your Personal Information with its business partners to offer you certain products, Services or promotions, and/or to facilitate provision of Object First products and Services to you, as well as with other Object First entities; and
  • With your Consent. Object First may disclose your Personal Information for any other purpose in accordance with your consent.

G. COOKIES

Object First may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Cookies are short pieces of data generated by a web server or mobile application that a service stores on a user’s device. The Website may require the use of a cookie for purposes of keeping information you enter on multiple pages together. Cookies also enable Object First to customize the Website and offerings to your needs and provide you with a better online experience. Beacons are used in combination with cookies to help the Website and mobile application operators understand how visitors interact with their online services.

Cookies and similar technologies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and/or to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of the Website.

Opting out of e-mail marketing. You can unsubscribe from Object First’s marketing email list at any time by clicking on the unsubscribe link in the emails received or by contacting Object First as outlined in Section L, below. Upon notifying Object First, You will then be removed from the marketing email list; however, Object First will still need to send you service-related emails that are necessary for the administration and use of your account.

H. TRANSFER OF INFORMATION

Object First may transfer, store, and process your information in countries other than your own.

Please be aware that your Personal Information may be transferred to, stored, or processed by Object First in its facilities, with Object First entities, or by those third parties with whom Object First has formed trusted contracts with in the U.S., the United Kingdom, the EU, Ukraine, the Russian Federation, or other countries, as the case may be.

If you are a resident in the EU, then some of the above countries may not have data protection or other laws as comprehensive as those in your country. However, Object First will take all necessary measures to protect your Personal Information in accordance with the Privacy Policy and applicable law.

I. HOW LONG DOES OBJECT FIRST STORE YOUR INFORMATION

Object First keeps your Personal Information for as long as necessary to fulfill the purposes outlined in the Privacy Policy, unless otherwise required by law. Object First undertakes not to store your information for longer than is required, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

When Object First no longer has a legitimate business need to process your Personal Information, it will either delete or anonymize such information. However, if this is not possible (for example, because your Personal Information has been stored in backup archives), then Object First will securely store your Personal Information and isolate it from any further processing until deletion is possible.

J. HOW OBJECT FIRST PROTECTS YOUR INFORMATION

Object First aims to protect your Personal Information through a system of organizational and technical security measures.

Object First has implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information it processes. However, please also remember that Object First cannot guarantee that the internet itself is 100% secure. Although Object First will do its best to protect your Personal Information, transmission of Personal Information to and from the Website is at your own risk. You should only access the Website and Services within a secure environment.

K. MINORS

Object First does not knowingly collect Personal Information from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or legal guardian of such a minor and consent to such minor dependent’s use of the Website. If Object First learns that Personal Information from users less than 18 years of age has been collected, it will deactivate the account and take reasonable measures to promptly delete such data from Object First’s records. If you become aware of any data Object First may have collected from children under age 18, please contact the DPO at Viktoriia Gorod viktoriia.gorod@objectfirst.com, or as outlined in Section L, below.

L. PRIVACY-RELATED INQUIRY OR COMPLAINT

If you have an inquiry or complaint concerning Object First’s use of your Personal Information, please reach out to Object First ‘s Data Protection Officer, as follows:

Object First LLC.

Data Protection Officer: Viktoriia Gorod

Email: viktoriia.gorod@objectfirst.com

ATTN: Privacy Inquiry/Complaint

Mailing Address: 100 Cummings Center Suite 224-C, Beverly, MA 01915

In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that Object First’s Privacy Policy has been breached. Object First and/or the DPO will investigate your inquiry or complaint promptly.

Object First is committed to cooperate with the panel established by the EU Data Protection Authorities (“DPA”) with regard to unresolved Privacy Shield Complaints concerning data transferred from the EU. If you are a Qualified Individual, you may lodge a free complaint with the DPA in the country where you reside if you are unsatisfied with how your complaint is handled by Object First. If you are a Qualified Individual, you can find your DPA by visiting the European Commission Website on Data Protection Authorities, selecting the country in which you reside, and following the links provided to make a complaint.

M. EU-US PRIVACY SHIELD POLICY

Object First’s Privacy Policy also adheres to the EU-US Privacy Shield Framework (the “Framework”) as set forth by the U.S. Department of Commerce regarding the processing of Personal Information transferred from the EU to the U.S. The Framework further outlines Object First’s practices for collecting, disclosing, maintaining, using, and protecting your Personal Information. As a participant, Object First is certified with the Department of Commerce that it will adhere to the Privacy Shield Principles. Should there be a conflict between Object First’s Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To view Object First’s EU-US Privacy Shield status and listing as a participant, click the following link to view the Privacy Shield List of Participants.

In compliance with the Framework’s Principles, Object First is committed to resolve complaints about your privacy and its collection or use of your Personal Information. As outlined in Sections C, D, & F, above, Object First may use some third-party services in order to provide you with functionality and services pertaining to your use of the Website and Services. In the case of onward transfers to these third parties, Object First may be liable for breaches of Personal Information regarding such transfers. However, all Third-Party Processors used by Object First will be similarly held to provide at minimum the same level of protection of Personal Information as required by the Framework. Should you be a Qualified Individual and have an inquiry or complaint concerning Object First’s Privacy Policy or use of your Personal Information, You should follow the procedures as outlined in Section L, above.

Under certain limited conditions, you may be able to invoke binding arbitration as provided under the Framework to address an otherwise unresolved complaint.

Copyright © 2022 Object First LLC. All rights reserved. The Website, Services, and all documentation are the copyrighted property of Object First LLC. and/or its licensors and protected by copyright laws and international intellectual property treaties. Object First® and related logo, and all related product and service names, design marks and slogans are the trademarks and/or registered trademarks of Object First LLC. and/or its affiliates. All other product and service marks contained herein are the trademarks of their respective owners. Any use of the Object First LLC. or third-party trademarks or logos without the prior written consent of Object First LLC. or the applicable trademark owner is strictly prohibited.