Privacy Policy

Privacy Policy

At FIRST, we’re committed to protecting and respecting your privacy.

INTRODUCTION

We are FIRST, a brand experience agency with over 20 years of experience. At FIRST, we bring together brands and people through creative, connected events and experience as a full-service partner or through embedding specialist talent.  FIRST has registered entities and subsidiaries throughout the world the full list of which is available at the bottom of this policy.

This Policy explains when, why and how we collect personal information about people who visit our website or conduct business with us. In addition, it explains how we use this data and the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this page occasionally to ensure that you have the latest version and are aware of any changes. By doing business with us and using our website, you’re agreeing to be bound by this Policy.

Any questions regarding this Policy and our privacy practices should be sent by email to privacy@firstagency.com or by writing to FIRST, 630 Ninth Avenue, Suite 310, New York, NY 10036 Attn: Privacy. Alternatively, you can call us at +1 212.810.4100

This policy applies to the following classification of individuals that interact with FIRST:

  • Clients: Clients are individuals that are employees or associates of the direct customers of FIRST including those for whom FIRST processes data as a “data processor” or “service provider” according to our clients’ instructions.
  • Visitors: Individuals and prospective customers who interact with our website or those we meet at industry events.

In this policy, ‘you’ represents Visitors to our website and the Clients with whom FIRST has contracted to provide services, and not the individuals attending events for which FIRST processes data as a “data processor” or “service provider” according to our clients’ instructions.

Attendees of an event hosted by one of our clients who have questions about how data is used or want to exercise their rights regarding their personal data, should review the client’s privacy policy and direct their request or inquiry to the client of FIRST that controls their data.

What type of information is collected from you when you work with us or visit our website?

When working with us or visiting our website, information collected includes name, title, e-mail address, telephone number, and company information (including financial and billing information when purchasing services from FIRST).  If you do business with FIRST, our Finance departments may collect payment information. In addition to our Finance departments’ handling of payment information, we may utilize third-party payment processors, who specialize in the secure online capture and processing of credit/debit card transactions, as explained below.

When planning and activating an event or project for you and your potential attendees, we would collect registrant information based on the nature of your event. Much of the information gathered in the planning and registration portions of your projects/events can be classified as personal or confidential information under various local/global regulations. For example: Name, email address, contact information, company affiliation, meal preferences inclusive of food allergies, IP address, etc.

How do we collect information from you?

We obtain information about you when you use our website, for example when you contact us with inquiries regarding service offerings, career opportunities, feedback surveys, social media interaction, and newsletter registrations. Information is collected from devices, including mobile devices, and applications or browsers used in accessing this site. Examples include device identification, location, IP address (anonymized), connection information, operating system, browser version, referral URL, etc.

This information may also be collected when you visit our website may be obtained using cookies (as described in the Use of ‘Cookies’, section below) pixels and beacons and may include approximate geolocation data (country and state/region), your activities on our website, your activities on other websites and certain demographic information.

In addition to routine data collection conducted on our site, we may also work with various third-party suppliers who specialize in event registration, mobile applications, and/or virtual events. A list of commonly used, and trusted, third-party vendors used by our agency can be requested by emailing privacy@firstagency.com. Whether or not third parties are engaged in handling your business would depend on the scope of work for your specific project/event.

How is the information we collect used?

We may use your information to:

  • Send you communications which you have requested and that may be of interest to you. These may include information about our companies’ services.
  • Consider you for various employment opportunities which you have expressed interest in; process a job application.
  • Seek your views, comments, or feedback on services we provide.
  • Fulfill our agreement with you when you register for an event by facilitating your event registration and attendance at the event.
  • Where we have a good faith belief that it is necessary to investigate (or assist in the investigation of), prevent, or take action regarding illegal activities, suspected fraud, cyber-attack, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
  • Share personal information where we have a good faith belief that such action is necessary to comply with a judicial proceeding, a court order, or legal process served on us, or to establish or exercise our legal rights or defend against legal claims.
  • For maintenance and enhancement of the security of the digital information we collect and use, including analysis of the personal information to pursue the legitimate business interest in protecting our customers and website visitors against malware, cyber-attack and other crime and security risks.
  • Aggregate and anonymize personal information provided under this Privacy Policy to create anonymized data sets which will then be used to improve our and our affiliates’ services. We may also share aggregated anonymized personal information with clients, customers, prospective clients and customers or business partners to demonstrate usage of the services, or to identify industry and advertising trends.
  • Notify you of changes to our service.
  • Carry out our obligations arising from any contracts or other agreements entered into by you and us.

From time to time, we may use customer information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change at some time in the future, we will post the policy changes to our website.

The legal basis for our uses, sharing and disclosures (“processing”) of your personal information include, as pertinent, where:

  1. Necessary to perform the contractual obligations in agreements with you to provide access to our services as stated in the preceding paragraph;
  2. You have consented to the processing as set out in this Policy, which consent you can revoke at any time;
  3. Necessary to comply with a legal obligation, a court order or to exercise or defend a legal claim;
  4. Necessary for the purposes of our or a third-party’s legitimate business interests (so long as those interests do not override personal rights as indicated by law);
  5. You have expressly made your personal information public;
  6. Necessary to protect your vital interests or other of others.


With whom do we share your information?

We will not sell or rent your information to third parties. We will not share your information with third parties for marketing purposes.

We may pass your information to our third-party service providers, agents subcontractors and other associated partners for the purposes of completing tasks and providing services to you on our behalf (for example to process registrations and secure accommodations). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganization, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers

We may pass your information to our third-party service or product providers, agents, subcontractors, and other associated partners for the purposes of completing tasks and providing services to you on our behalf (for example to process registrations and secure accommodations). However, when we use third party service or providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We work closely with various third-party product providers to bring a range of quality and reliable services and products designed to meet the needs our clients for services such as registration, applications, and virtual events (). When your project/event requires the use of such a third-party provider the relevant third party-product provider will use your details to provide you with information about the event and carry out obligations arising from any contracts you have entered with us/them.

When you are using our secure online payment portal, your payment is processed by a third-party payment processor, who specializes in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact the provider specified for your activation directly.

However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Duration of Use and Retention of Data

We will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or as required or permitted by law, and then will delete it as required by law. We may also retain log files for internal analysis purposes, though we would retain them for only a brief period except in cases where we are legally required to retain them for longer periods, and in cases where they are used for site safety and security or to improve website functionality.

How you can access and update your information

The accuracy of your information is important to us. We’re actively working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you would like to make any changes to information we hold, please email us at: privacy@firstagency.com.  If you’re actively engaged in business dealings with us, you may also contact the relevant associates handling your project/event at any time to correct your information.

Privacy of Minors and Children

We do not knowingly contact or intentionally collect information from those visitors and Users of the Services who are under 16 years old. In fact, the website and Services are not intended for use by children under sixteen (16) or to solicit information of any kind from children under sixteen (16).

However, it is possible that we may inadvertently receive information from children under sixteen (16). If we become aware that we have inadvertently received personal information from a visitor under the age of tsixteen (16) we will delete the information from our records. If you believe that we have received information from your child that is under the age of sixteen (16), please do not hesitate to notify us using the information below. When we receive your notification, we will delete such information permanently. Such notifications can be sent to:privacy@firstagency.com

Use of ‘Cookies’

Like many other websites, the FIRST website uses cookies. ‘Cookies’ are small pieces of information sent by an organization to your computer and stored on your hard drive to allow that website to recognize you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use cookies to determine from which country or region is visiting. This helps us to improve our website and deliver a better more personalized service.

Cookie Controls:  It is possible to switch off cookies by setting your browser preferences. When visiting our site you may be asked to acknowledge and provide consent to our use of cookies.  Turning cookies off may result in a loss of some functionality when using our .

If you are visiting our Website from the EEA, UK or Switzerland, then we do not set non-essential cookies unless you accept all cookies on the “cookie banner” that launches when you land on our Website. Strictly necessary cookies cannot be disabled.

Links to other websites

Our website may contain links to other websites run by other organizations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We do not endorse and cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

Security

At FIRST, we use a variety of organizational, technical, and administrative measures to protect personal data within our organizations. We follow commercially reasonable security standards and commercially appropriate measures in the processing and protecting of personal data submitted to us, both during transmission and once received, as well as in the retention and deletion policies surrounding this data.

Your personal information is transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information through use of appropriate security measures, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.

Privacy Principles Statement

FIRST abides by data protection principles, including.

  • Lawfulness, fairness, and transparency
  • Purpose limitation
  • Data minimization
  • Accuracy
  • Storage limitation
  • Security (integrity and confidentiality)
  • Accountability

Adherence to these principles applies to all Personal Information that is collected to provide services to or for FIRST and all its wholly owned entities and subsidiaries, and to provide employment opportunities to our employees and contractors, as described in but not limited our website’s capabilities section.

You should be aware that when required to do so, FIRST must cooperate with, and in doing so, disclose any requested personal information in its possession to public authorities in accordance with the law, including to meet national security or law enforcement requests. In addition to these requests, as mentioned in prior sections of this policy, FIRST, works with an extensive portfolio of Third Parties. FIRST has provided to all these Third Parties, disclaimers, addendums, and annexes where applicable to define each participant’s liability and accountability as data processors and controllers for these transfers.

Your Choices: Europe, United Kingdom, and Countries and US States with Similar Privacy Laws

If you reside in a Member State of the European Union, the United Kingdom, a country with similar laws to the EU’s General Data Protection Regulation (GDPR) or the laws of certain states of the US, you may, subject to certain conditions and exemptions, have the following rights with regard certain data created by or about you:

  • Right to Access– Individuals whose data is being processed by FIRST or any of its subsidiaries or third-party data processors, retain the right to know how/where/why their data is being collected/used/stored. You may request from FIRST, at any time, information about which personal information FIRST processes about you and the correction or deletion of such personal information. If FIRST uses your personal information to perform a contract with you, you may further request a copy of the personal data that you have provided to FIRST. These rights are defined and, in some cases limited, by the laws of your jurisdiction. These rights include (a) data portability, including the right to obtain a copy of the personal information you have provided to us; (b) data correction (also known as rectification, including the ability to request correction or amendment of your personal information and (c) data deletion, including the right to have us delete your personal information except for information that we are required to retain.
  • Right to be Erasure– Individuals whose data is being processed by FIRST or any of its subsidiaries or third-party data processors, retain the right to erasure subject to conditions and exemptions in applicable laws.
  • Right to object or withdraw consent–You may object to, or withdraw consent for, our using your personal information for the above purposes at any time.

You may inquire about the exercise of these rights and, if the laws of your jurisdiction permit, exercise them as permitted by law by contacting privacy@firstagency.com.

Please note that withdrawal of consent will not impact information processed before you withdrew your consent.

International Transfers Beyond the European Economic Area, the United Kingdom and Canada

FIRST operates on a global basis. To facilitate our business practices and provide our services you understand and agree that your personal information may be collected, accessed from, transferred to or stored in the United States or in other countries where we operate, including countries outside the European Economic Area (EEA, which comprises the European Union countries plus Norway, Iceland, Liechtenstein), Switzerland, the United Kingdom or Canada.  Personal data may be accessed by FIRST personnel providing services in any country where we operate, or in which we engage third party service providers (processors or subprocessors), including India, Australia, and Singapore. When your personal information is transferred from your home country to another country, the laws and regulations that protect your personal information may be different than those in your home country.

Contact – EU and UK Representative Information

If you have questions regarding this Privacy Policy, wish to lodge a complaint or wish to exercise the rights in the Choice and Control section of the Policy, you may contact our Data Protection Officer by email to privacy@firstagency.com or by traditional mail to our US office at:

FIRST, 630 Ninth Avenue, New York, NY 10036 ATTN: PRIVACY

If you live within the European Union, and wish to issue a complaint or exercise the rights under the Choice and Control section of this Policy that may apply to you, you may do so by emailing privacy@firstagency.com and your communication will be routed appropriately to the EU Representative within the .

California Residents

If you are a California resident, California law provides you with specific rights regarding your personal information, including the right to request that FIRST disclose certain information about our collection and use of your personal information over the past 12 months.  In addition to the rights already provided in this Privacy Policy, this supplementary notice provides information about what personal information we (as a business) collect about you, how we use, how we may disclose or share it, and your specific rights under California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA”), which was effective as of January 1, 2023 provide .

Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA: identifiers such as a real name, postal address, IP address, email address, or other similar identifiers; categories of personal information described in subdivision (e) of California Civil Code Section 1798.80 (e.g., name, address, telephone number); characteristics of protected classifications under California or federal law such as age or gender; commercial information, including records of products or services purchased or considered; internet or other electronic network activity information; approximate geolocation data; professional or employment-related information; inferences drawn from any of the information identified above.

As a business, FIRST has not collected Sensitive Personal Information in the preceding 12 months to the effective date of this policy.

California Resident Privacy Rights and How to Exercise Them

If you are a California resident, you have rights, with certain limitations, to ask us information about the Personal Information we collect about you and maintain as business in the preceding 12 months. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to access, know, request deletion and opt out of Sale or Sharing of your information, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.  We may not discriminate with regard Your decision to exercise any of your rights pursuant to California law.

If you wish to make a request to exercise your rights, please contact us at privacy@firstagency.com.  Or telephone at 212-810-4100. Or by traditional mail to FIRST, 630 Ninth Avenue, New York, NY 10036 ATTN: PRIVACY

We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Furthermore, you may designate an authorized agent to make a request under the CCPA on your behalf, provided, we require the agent to provide proof that you gave the agent signed permission to submit the request (in which case we may still require you verify your identity) or a copy of your power-of-attorney document granting the agent the right to act on your behalf.

FIRST Entities

FIRST, has registered entities and subsidiaries throughout the world and are as follows.

  • FIRST Protocol Group Limited (Parent Company; all others are wholly owned subsidiaries; United Kingdom)
  • Clive Agency (US) Inc (United States)
  • FIRST Global Management Services Inc (United States)
  • FIRST Agency Solutions Inc (United States)
  • FIRST Protocol Inc (United States)
  • FIRST Agency Solutions Limited (United Kingdom)
  • FIRST Agency Solutions PTE Limited (Singapore)
  • FIRST Agency Solutions PTY Limited (Australia)
  • FIRST Events Agency Limited (Ireland)
  • FIRST Events Agency Ltd (France Branch)
  • FIRST Agency Limited (Hong Kong)
  • FIRST Protocol Agency Ireland Limited (Ireland)
  • Clive Agency Limited (United Kingdom)
  • FIRST Protocol Event Management Limited (United Kingdom)
  • FIRST PTE Limited (Singapore)
  • FIRST Agency Limited (Hong Kong)
  • FIRST Global Management Services Limited (United Kingdom)