Privacy Policy – Edited

Privacy Policy

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

 

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. Additionally, FIRST, has recently joined the EU-US Privacy Shield program, and in doing so commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to data transferred from the EU. More information on FIRST’s association with the Privacy Shield program can be found below in the Privacy Shied Statement section of this policy.

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. Alternatively, you can call us at +1 646.430.5213.

Who are we?

We are FIRST, a full service global events agency with over 20 years of experience. At FIRST, we offer not only event planning and production, but also experiential production and marketing campaigns, also solutions and managed personnel catered to solving your business challenges.

FIRST, has registered entities and subsidiaries throughout the world including CLIVE, our sister experiential agency. FIRST and CLIVE’s registered entities are as follows.

FIRST US – First Protocol, Inc. d/b/a FIRST at 630 Ninth Avenue, New York, NY 10036 (TAX/EIN: 20-1231125)

FIRST UK – First Protocol Event Management Ltd. T/A FIRST at 70 Newcomen Street, London, SE1 1YT UK (VAT ID: 672 6745 05)

FIRST IRL – First Events Agency Limited (Ireland), 108 Q House, Furze Road, Sandyford, Dublin 18 (Company no.UK: 620319)

FIRST SGP – First PTE Limited, 3 Phillip Street, #12-02, Singapore, 048693 (Company No: 201207308R)

FIRST HK – First Agency Limited, Units A-C, 25/F., Seabright Plaza, No. 9-23 Shell Street, North Point, Hong Kong (Company No: 2444361)

CLIVE UK – Clive Agency Ltd., Axe & Bottle Court, 70 Newcomen Street, London, SE1 1YT(Company No.UK: 3240052)

CLIVE US – Clive Agency (US) Ltd., 630 Ninth Avenue, Suite 310, New York, NY 10036 (Tax/EIN: 31-0589138)

CLIVE IRL – Clive Agency [Ireland] Ltd., The Brickhouse, Block 1, Clanwilliam Court, Mount Street Lower, Dublin 2, Ireland (Company No: 604801)

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. We may also collect IP address information to keep track of what pages are accessed and when. This information is collected from devices, including mobile devices, and applications or browsers used in accessing these sites. Examples include: device identification, location, IP, connection information, operating system, browser version, referral URL, etc.

In addition to routine data collection conducted on our site, we may also work with various third-party vendors who specialize in event registration. A list of commonly used, and trusted, third-party vendors used by our agencies 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.

Please note, that throughout this policy ‘you’ is intended to represent the clients with whom FIRST has contracted to provide services, and not the individuals attending these events. Individuals seeking to enact their data privacy rights under regulations like the GDPR, should first contact the event host.

What type of information is collected from you?

When working with us, we collect information from you and any potential attendees. For example, when planning and activating an event or project for you, 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, food allergies, etc. If you do business with FIRST/CLIVE, 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.

How is your information 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.

• Where we have a good faith belief that it is necessary in order 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 in order 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; and
    6. Necessary to protect your vital interests or other of others.

 

Financial Information we Collect or Receive

If you choose to register for our events, sponsor our events, exhibit at our events or attend a seminar we may collect credit card information, bank account information and information necessary to verify your identity, such as date of birth. In certain countries, national identifier numbers (similar to Social Security Numbers in the US) may also be collected or received if needed to verify your identity. We use commercially reasonable standards to protect this information. Depending upon your wishes, we may retain this information or arrange for it to be securely stored in order to facilitate your future purchases.

Duration and Retention

We review our retention periods for personal information on a regular basis. 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. For example, we will retain your information as long as required to comply with applicable tax/revenue laws, cybersecurity and privacy laws, laws and regulations that affect the conduct of our business; to resolve disputes, enforce our agreements, cooperate with law enforcement requests or to meet other legal obligations. 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.

Who has access to 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. When you register for an program, event, show, or other promotion that is sponsored by a third party we will, if you reside within the European Union, seek your affirmative consent to provide the third party personal information, in a manner clearly specified on the registration materials, unless otherwise posted in connection with the promotion.

It is important to note, that various loyalty programs such as hotels/car rental agencies, that may be used in the activation of you event/project may from time to time use your information for marketing and communication purposes, and that you should carefully review the terms of these providers. Please be reassured that we will not release your information to third parties beyond the FIRST/CLIVE networks for them to use for their own direct marketing purposes, unless you have requested us to do so or affirmatively consent that we may do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.


Third Party Service Providers working on our behalf

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.

It is important to note, that various loyalty programs such as hotels/car rental agencies, that may be used in the activation of you event/project may from time to time use your information for marketing and communication purposes, and that you should carefully review the terms of these providers. Please be reassured that we will not release your information to third parties beyond the FIRST/CLIVE networks for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Third Party Product Providers with whom we work in close association

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 (e.g. CVENT and ETOUCHES). 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 into with us/them. In some cases, they will be acting as a data controller of your information and therefore we advise you to read their Privacy Policy. These third-party product providers will share your information with us which we will use in accordance with this Privacy Policy.

When you are using our secure online payment pages, 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.

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

Your Choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive any direct marketing communications from us about services, then you can select your choices by opting out on the forms on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have expressed interest in receiving such communications. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. change your marketing preferences you may contact us by; email: privacy@firstagency.com or telephone on +1 646.430.5213.

  • 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. Upon request, copies of this data may be requested by means of the contact information above, or by contacting a known third-party data processor handling your information directly. Third-party processor contact information can be located on the associated processor’s privacy-policy, should you need assistance contacting a third-party processor we are available to help fulfill your request(s).
  • Right to be Forgotten– Individuals whose data is being processed by FIRST or any of its subsidiaries or third-party data processors, retain the right to erasure.
  • Right to object If you are located within the European Union or a country that has adopted the relevant provision of the General Data Protection Regulation (GDPR), you may object to our using your personal information for the above purposes at any time by contacting privacy@firstagency.com. If you do so, we will cease using your personal information for the above purposes (i.e., under a legitimate interest set out above) and remove it from its systems unless such personal information is permitted to be used by us for another purpose set out in this Privacy Policy or applicable law or we determine a compelling legitimate interest to continue in processing your personal information is determined.

You may, if you are located within the European Union or a country that has adopted the European Union’s General Data Protection Regulation, or if your country’s laws otherwise require,  withdraw your consent or otherwise object to uses of your information as described above by contacting privacy@firstagency.com.

You may also withdraw your consent to email marketing by unsubscribing, using the unsubscribe link in such communications. If you do so, FIRST will cease using your personal information for the above purposes and remove it from its systems unless such personal information is permitted to be used by FIRST for another purpose set out in this Privacy Policy or FIRST determines and demonstrates a compelling legitimate interest to continue in processing your personal information In case of withdrawal of consent, FIRST will not process your personal information subject to this consent any longer unless legally required to do so. In case FIRST is required to retain your personal information for legal reasons your personal information will be restricted from further processing and only retained for the term required by law. However, any withdrawal has no effect on past processing of personal information by FIRST up to the point in time of your withdrawal. Furthermore, if your use of a FIRST offering requires your prior consent, FIRST will not be (any longer) able to provide the relevant product, service, offer, or event to you after your withdrawal. Please direct any such request for withdrawal to: privacy@firstagency.com.

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. To make such a request, please contact the email set forth below and specify in detail the information or the activity to which your request relates, the format in which you would like the personal data returned and the recipient, you or your designee. Furthermore, you may contact FIRST if you believe that the personal information that FIRST has is incorrect.

If you are located within the European Union or a country that has adopted the relevant provisions of the GDPR, you may benefit from a number of rights with regard to your personal information that we process. 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. Your right to have your personal information deleted does not apply, however, where the information is necessary:

  1. for exercising the right of freedom of expression and information;
  2. for compliance with a legal obligation which requires processing by European Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  3. for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
  4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  5. for the establishment, exercise or defense of legal claims.

You also have the right to ask us to cease processing your personal information is dependent upon the following events: (i) you state that the personal information we has about you is incorrect; but we may retain the information  for as long as it requires to check the accuracy of the relevant personal information; (ii) there is no legal basis for our  processing of your personal information and you demand that we restrict your personal information  from further processing, (iii) we no longer require your personal information  but you claim that you require such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) in case you object to the processing of your personal information by us it may retain and process the information for as long as it is required to review as to whether we have a prevailing interest or legal obligation in continuing to process your personal information.

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.

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.

Security

At FIRST/CLIVE we place an emphasis on and take the commercially appropriate measures in the safeguarding and processing of personal data, as well as the retention and deletion policies surrounding this data.

We utilize SSL certificates with strong SHA2 & 2048-Bit Encryption for all of our website’s traffic to enhance the security of the information of our visitors.

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, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Privacy Principles Statement

While the Court of Justice of the European Union invalidated the EU-US Privacy Shield Framework, with which FIRST/CLIVE was registered, on July 16, 2020, FIRST/CLIVE continues to abide by the seven principles of data protection as set forth EU-U.S. Privacy Shield Framework https://www.privacyshield.gov and complies with those principles regarding the collection, storage, use, processing, and transfer of certain Personal Information from the European Union. Those principles are:

• Lawfulness, fairness and transparency

• Purpose limitation

• Data minimization

• Accuracy

• Storage limitation

• Security (integrity and confidentiality)

• Accountability

FIRST/CLIVE’s adherence to these principles applies to all Personal Information received from the European Union that is collected to provide services to or for FIRST/CLIVE and all its wholly owned entities and subsidiaries’ customers, and to provide employment opportunities to our agency’s 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/CLIVE must cooperate with, and in doing so, disclose any requested personal information in its possession to public authorities in accordance to 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/CLIVE, works with an extensive portfolio of Third Parties. When applicable, FIRST/CLIVE assumes liability in cases of onward transfers to these Third Parties and has put in place the appropriate safeguards and privacy by design to secure the transfer of data to these Third Parties. FIRST has also provided to all of 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.

International Transfers

FIRST/CLIVE operates on a global basis. By using our products and services you understand and agree that your personal information may be transferred from the European Economic Area (EEA, which comprises the European Union countries plus Norway, Iceland, Liechtenstein) to a country that does not have an equivalent level of data protection, such as the United States. 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. In particular, if your information is in the US, it may be accessed by government authorities in accordance with US law

To the extent that FIRST/CLIVE is deemed to transfer your Personal Information outside the EEA, FIRST/CLIVE relies upon data transfer agreements with Standard Contractual Clauses, which the European Commission has adopted to provide safeguards for personal information that is transferred outside the EEA. You may obtain a copy of the Standard Contractual Clauses by contacting privacy@firstagency.

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 store your country preference. This helps us to improve our website and deliver a better more personalized service. It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, please request our cookies policy by emailing privacy@firstagency.com. When visiting our site you will be asked to acknowledge and provide consent to our use of cookies, note that turning cookies of may result in a loss of some functionality when using our website.

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 cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

Privacy of Minors and Children

We do not intentionally collect information from those visitors and Users of the Services who are under 18 years old. Pursuant to the Children’s Online Privacy Act (“COPPA”), we do not knowingly contact or collect personal information from children under thirteen (13). In fact, the website and Services are not intended for use by children under thirteen (13) or to solicit information of any kind from children under thirteen (13).

However, it is possible that we may inadvertently receive information from children under thirteen (13). If we become aware that we have inadvertently received personal information from a visitor under the age of thirteen (13) 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 thirteen (13), 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.

California Residents

The only personal information FIRST collects, processes and maintains is business information in which you have communicated with us concerning a business transaction, asked us to perform a service or provide you with a product, including event registration or services in connection with an event, or which is otherwise excluded from the definition of “personal information” and most of the requirements with regard to that information within the California Consumer Privacy Act (CCPA). The business basis for, and the manner in which, such business information is collected and processed is set forth within this Privacy Notice.

FIRST does not “sell” personal information as the terms “sell” or “sale” are defined within CCPA.  FIRST only shares the information it collects with business partners who are its “service providers,” and sharing information in this way is not a “sale” as that term is defined in the CCPA.  Service Providers are business partners who perform business functions for FIRST, as the term ”Service Provider” is defined within CCPA. They agree to use information only for these business purposes and not to redisclose it except as permitted or required by law as set out in our contracts with them. The nature of the services provided by these business partners and a description of the categories of these service providers is set forth within this Privacy Notice.

If you have questions regarding collection and sharing of your business information or believe that information that identifies you and has been collected and shared by FIRST is not business information within the meaning of CCPA, or is not provided to a Service Provider as stated above, and you wish to advise us of these beliefs and ask that we not share that information please contact is at privacy@firstagency.com.

Are you a citizen of Europe?

As part of the services offered to you through this website, and in the course of business with us, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU, Including the US. These countries may not have similar data protection laws to the UK, for example, your data in the US may, under certain circumstances be accessed by law enforcement agencies. By submitting your personal data, you’re agreeing to this transfer, storing or processing in accord with the safeguards provided in this policy. If we transfer your information outside of the EU in this way, we have taken steps to ensure that appropriate privacy and security measures are taken with the aim of ensuring that your privacy rights continue to be protected, as further described in the section “EU-US Privacy Shield,” below.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

Contact and EU 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 DPO by email to privacy@firstagency.com or by traditional mail to our US office at:

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

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 pertinent EU entity within the EU.

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