Please read this Policy carefully. If you do not agree with this Policy or any part thereof, you should not access or use any part of the Services, or otherwise provide us with your personal information. If you change your mind in the future, you should stop using the Services and provide us with no further personal information.
Information We Collect or Process
You may choose to provide personal information to us in a number of ways, such as when you participate in an offer or promotion, when you make a purchase on our sites, visit our social media pages or use our Services. For instance, the personal information you may provide to us and how it may be provided includes the following:
If you register to use the Services as a Customer, then you will provide us with your name, business contact information, title, office address, email address, telephone number(s), device type, and a password in order to create an account, along with signature information (including timestamp);
If you are using the Services as an End User of a Customer, we collect information about End Users from their use of the Services, including the content of their text messages. The information we collect, some of which is personal information, includes: mobile telephone numbers and IP addresses;
If you are not a Customer or End User, you are considered a visitor to our sites, during which time we may collect information you provide by interacting with us through our sites, including by submitting questions, commenting on our forums and interacting with us through social media;
When you use the Services, you provide us with information such as your device information, including model, manufacturer and brand (but specifically excluding IMEI or device UUID), user ID, channel mode, SDK version, network type, App ID, call information, quality of services information (including network quality metrics), and device status changes;
Information provided through social media networks or one of our mobile applications when you visit our social media pages (such as your name, profile picture, likes, location, friend list and other information described on the social media network or your geo-location details when using one of our mobile applications);
To complete your purchase of our Services (First Light does not collect and store your complete credit card information. Your credit card payments are processed by a third-party credit card processing service); and
If you submit any personal information relating to other people to us or to our service providers in connection with the services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
When you visit our sites, view or click on our online advertisements (including our advertisements on third party websites), visit our social media pages or use our Services, we also collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies. The information we may collect automatically includes:
Usage information. Whenever you visit or interact with our sites, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how our sites are accessed and used (“Usage information”). Usage information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on our sites, as well as search terms that visitors use to reach our sites. This information helps us keep our sites usable for our visitors and allows us to tailor content to a visitor’s interests.
Device Identifier. We automatically collect your IP address or other unique identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet or other device) you use to access our sites. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer our sites, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your interests, and gather broad demographic information for aggregate use.
Cookies; Pixel Tags. We and third parties may automatically collect information about your visit to and use of the Services via cookies. The information they collect may include personal information, such as your IP address, and advertising identifiers. The technologies used on our sites to collect Usage information, including Device Identifiers, include but are not limited to: cookies (data files placed on a Device when it is used to visit our sites), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate you with social networking sites like Facebook, Instagram, LinkedIn, Twitter and, if you so choose, enable interaction between your activities on our sites and your activities on such social networking sites. We, or our partners, may place cookies or similar files on your Device for security purposes, to facilitate site navigation, to perform analytics, and personalize your experience while visiting our sites (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location or demographic information). A pixel tag may tell your browser to get content from another server.
How We Use the Information We Collect
We use the information we collect for a variety of business purposes including: complete your subscription for the Services, respond to your correspondence and requests, obtain your feedback regarding our sites or Services, send you information and updates about our sites or Services, confirm a Customer’s identity and associate an authorized representative or End User with a Customer’s account, confirm an End User’s identity, monitor and enforce compliance with our Terms, Acceptable Use Policy or other agreements.
We may use the information for other purposes such as customer support for our Services and to troubleshoot problems, customize your experience with our Services, communicate with you, promote our Services, such as through targeted advertising, and learn how users interact with our sites and Services so that we can improve our Services and develop new features; communicate with you about your account and activities on our sites, modify or change any of our policies; tailor content, advertisements, and offers we serve you; improve our sites; comply with contractual obligations; and for purposes disclosed at the time you provide your personal information or otherwise with your consent. We may also collect information for purposes such as:
Communicate with you (including by phone or by email) about our products, services, offers, surveys, events and promotions, and oﬀer products and services we believe may be of interest to you;
Publish your testimonials about First Light, including on our sites, forums, blogs, and social media assets (if we choose to publish your testimonial, we will generally only include your name, title and company name);
Follow up with individuals and companies with whom you have shared First Light content;
Analyze and enhance our marketing communications and lead generation strategies (including by identifying when emails sent to you have been received and read);
Analyze trends and statistics regarding visitors’ use of our sites;
Protect against fraud and unauthorized transactions;
For billing purposes; and
To detect and block fraudulent use of the sites and Services.
Information We Share
We do not sell, rent, or otherwise disclose personal information about you, except as described in this Policy. We may share non-personal information, such as aggregate data and Usage information with third parties. We may share the information we collect with our affiliated companies, business partners, ad network vendors and their participants, and other third parties for the purposes described in this Policy, including to communicate with you about products and services, offers, events and promotions that we believe may be of interest to you. We may also share the information with our service providers that perform services on our behalf. We do not authorize these service providers to use or disclose the information except as necessary to perform certain services on our behalf or comply with legal requirements. We also may share information about you with other third parties. We will ask for your permission prior to sharing information about you with other third parties.
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected]. You also may write to us at:
First Light Dev Limited
6 Mark Place Lynmore
Rotorua New Zealand 3010
Attn: Privacy Oﬀice
Your Privacy Rights, Choice and Access
We oﬀer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
You control the personal information that you provide to us on our sites, but some personal information is required by us in order for you to obtain services from us or for you to use our sites. If you choose not to provide us with your personal information on our sites, you may not be able to take advantage of some of the services we offer or use some functionality on our sites. Except as provided above, we will not share personal information collected on our sites with third parties without your consent. You may also direct us to stop sending you promotional emails by following the removal instructions in a communication you receive from us. Your opt-out request will be processed within a reasonable period of time following the date on which we receive it. We ask that you not send us, and you not disclose, any sensitive personal information (e.g., Social Security numbers, health, biometrics or genetic characteristics or other criminal background) on or through the Services or otherwise to us.
If you wish to modify, verify, correct, or delete any of your personal information collected through our sites, you may edit your registered user information or contact us at [email protected]. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted through our sites. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. It may not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as your account is active or as needed to provide you services. If you wish to cancel your online account or request that we no longer use your information to provide you services through the platform, please contact us at [email protected]. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.
If you believe your personal information has been used in a manner not consistent with the policies outlined, please contact us using the information provided below.
How We Protect Your Personal Information
We use technical, physical and administrative safeguards intended to protect the personal information that we collect from and about you. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.
You are responsible for maintaining the security of your account credentials for the Services. First Light will treat access to the Services through your account credentials as authorized by you. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately at [email protected].
If we become aware of a breach that affects the security of your personal information, we will provide you or the Customer with notice as required by applicable law. When permitted by applicable law, First Light will provide this notice to you through the email address associated with your First Light account.
Your Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA) or United Kingdom (UK), you have certain data protection rights.
First Light aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Right to Access, Update or Delete the Information we have on you. Whenever made possible, you can access, update or request deletion of your personal data. If you are unable to perform these actions within your account settings, please contact us to assist you. You also have the right to request copies of your personal data.
Right of Rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
Right to Object. You have the right to object to our processing of your personal data.
Right of Restriction. You have the right to request that we restrict the processing of your personal information.
Right to Data Portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format. This information can be provided to you directly or to another organization at your written request.
Right to Withdraw Consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
If you make a request, we have one month to respond to you. Please note that we may ask you to verify your identity before responding to such requests. If you would like to exercise any of these rights, please contact us as follows:
Email: [email protected]
You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA) – Information Commissioner’s Office.
Access and Correction
You may contact us at [email protected] and we will provide you with reasonable access to the personal information we maintain about you. We will also provide you a reasonable opportunity to correct, amend or delete that information where it is inaccurate. We will respond to your request within a reasonable period of time. We may limit or deny access to personal information where providing such access is unreasonably burdensome or expensive under the circumstances, or as we otherwise deem appropriate. In addition, please note that (i) we may not be able to edit or delete your personal information stored with our third-party service providers, and (ii) we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
Other Websites, Data Processing and Safeguards
Our sites may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our sites (including those linked to through an email or social networking page).
While First Light has implemented administrative, technical and physical safeguards to assist in protecting the personal information we collect, please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be non-negotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their systems, or they have a general reputation for applying such measures. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Our sites and Services are not directed to minors (children under the age of 18). We do not knowingly collect, use or disclose personally identifiable information from anyone under 18 years of age. If we determine upon collection that a user is under this age, we will not use or maintain their personal information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a minor under the age of 18, we will make reasonable efforts to delete such information from our records.
How to Contact Us
If you have any questions, comments or concerns about this Policy or if you would like us to update information we have about you or your choices or preferences, please contact us by email at [email protected]. You also may write to us at:
First Light Dev Limited
6 Mark Place Lynmore
Rotorua New Zealand 3010
Attn: Privacy Oﬀice