Last Updated June 28, 2022
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.
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;
- To keep in touch with you for administrative, business, or contractual purposes with your Consent;
- To keep in touch with you for administrative, business, or contractual purposes with your Consent;
- 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;
- To send you Services and new feature information depending on your account preferences;
- To notify you about changes and updates to Object First’s terms, conditions, or policies;
- 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;
- To request feedback or comments from you concerning Object First Services;
- 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
- 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.
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.
I. HOW LONG DOES OBJECT FIRST STORE YOUR INFORMATION
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.
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 firstname.lastname@example.org, 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
ATTN: Privacy Inquiry/Complaint
Mailing Address: 100 Cummings Center Suite 224-C, Beverly, MA 01915
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
Under certain limited conditions, you may be able to invoke binding arbitration as provided under the Framework to address an otherwise unresolved complaint.
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