First Orion Brazil Privacy Policy

Effective September 13, 2021

First Orion Corp.™, a Delaware U.S. company and its subsidiaries (“First Orion”)is a business dedicated to using technology and data to:

  • (i) give consumers tools to recognize and manage calls they receive and to help businesses reach the right people in a compliant manner and
  • (ii) providing companies with a full-service solution for the provision of content to mobile devices

Our mission is to provide content, transparency and control in communication that empowers people to trust their phones and other mobile devices.

Scope of this Policy

This Privacy Policy covers the collection, use, disclosure, and sharing of personal information by First Orion for the products and services described below. Any information that you voluntarily agree to provide to First Orion, or which is collected by First Orion based on your use of these products and services will be collected and processed in a lawful, fair and transparent manner.

First Orion’s Products and Services available in Brazil are described below.

First Orion’s Scam Protection Suite

First Orion’s Scam Protection Suite of services provides business labels such as “Scam Likely” and “Telemarketer” to identify likely scammers and other types of callers and help you to not become a victim of phone fraud or to be bothered by unwanted calls. In addition, the services offer various other features and functionality for you to block unwanted, private, or unknown calls.

You can take advantage of First Orion’s Scam Protection Suite of services in several ways. You can download the free or paid First Orion PrivacyStarTM App or you can access these features through your telecommunication carrier if they are a First Orion client. You can find our PrivacyStarTM App in the Google Play Store for Android devices or the App Store for iPhones.

Your phone number will be used for identity validation purposes and to know whom to bill for fee-based services as well as to improve the functionality of our Apps and carrier services.

To provide this service, First Orion’s data scientists analyze information from your carrier and the App about the calls you receive and the actions you take (such as blocking a call). We also collect and analyze identifying information (name, address, and phone number) about businesses from third parties, including carriers and data brokers, and publicly available government records to accurately identify business lines.

When you download the App, you will need to agree to several questions so that it functions properly. The questions may vary depending on whether you are on an Android or iOS device since these operating systems function differently.

– Allow First Orion to make and manage phone calls?

This allows the App to launch a call from your detail screen when you touch the phone icon and to perform all the other call management activities provided in the App such as identifying unknown callers, blocking calls, filing complaints, and receiving enhanced caller information about who is calling and why.

– Allow First Orion to access your contacts?

First Orion is a data processor for all personal information processed by our Scam Protection services.

First Orion’s Branded Calling Services (Engage® Service)

First Orion’s Branded Calling Services provides companies who call you the ability to display enriched, branded, personalized information so you know more about who is calling and why they are calling so you are comfortable answering the call.

Our Engage® Service allows a richer display of information that is not limited to the caller ID field. This service is provided through our stand-alone Engage® App, or as a feature of other Apps, you may download or have on your mobile device. You can find our Engage® App in the Google Play Store for Android devices or the App Store for iPhones.

When you register with the Engage® App, it collects identifying information in the form of your phone number and uses it initially for identity validation purposes. We also use your phone number and other specifications about your device, so we know where to deliver the enhanced information about the caller and to properly deliver the message in a compatible format.

For the service to function, you will need to allow the Engage® App to access your contacts so the Engage®– delivery service can dynamically create a contact for incoming calls that display the enhanced information. We do NOT export any information from your contacts for any purpose. Once the enhanced call is delivered to your phone, the contact is automatically deleted.

All personal information relative to our Engage® Service is stored in the United States and retained until it is no longer needed by our clients.
We do not sell your personal information in our Engage® Service.

First Orion is a data processor for all personal information processed by our Engage® Service.

First Orion’s Mobile Content Monetization Services

First Orion’s Mobile Content Monetization Services is a service to companies that provide content to mobile users.

Whenever you access, purchase and use the content provided through our Mobile Content Monetization Services, First Orion will store your phone number, as well as other technological information resulting from your access to the content (IP, cookie information, etc.)

FIRST ORION will store and use this personal information for the purpose of:

    • (i) Offering third party content, services and products on your mobile device;
    • (ii) Delivery of the content, service and product eventually contracted by the data holder with the mobile operator;
    • (iii) Research and development of new products or services by FIRST ORION;
    • (iv) Compliance with a court order, law or applicable governmental request;
    • (v) Security and preservation of human life;
    • (vi) Public security issues; and
    • (vii) When necessary, if necessary to defend against any rules or claims of third parties, whenever necessary, the limits of what is necessary.

When sharing personal information, access to personal information will only be granted to third parties through the request, of course, the FIRST ORION will require the recipients of personal information to fully comply with the LGPD in this context.

The data collected by FIRST ORION for content delivery are transferred, stored and processed in Brazil where they stand out as the best technological tools for providing content, product and service.

The data captured by FIRST ORION will be kept in our possession for as long as necessary for the delivery of content, product and service by the mobile operator to the data subject.

Likewise, we may retain personal information for compliance with the law, judicial decision or as long as there are any possibilities of legal questioning regarding the personal information or treatment related to it (prescriptive and decadential deadlines involved).

First Orion is a data processor for all personal information processed by our Mobile Content Monetization Services.

This website

First Orion has a website in Brazil that explains, among other things, our lines of business and provides a link to this privacy policy which explains your rights relative to each line of business and how to contact us..

You provide all the personal information collected on this website to help us deliver a better level of user experience on the site. You may provide your identifying information including name, mailing address, phone number, email address, contact preferences, and commercial information relating to an inquiry or support issue. This enables us to give you convenient access to First Orion and helps us keep you posted on the latest product announcements, software or service updates, special offers, and events that you might like to hear about. It also allows us to respond to any concerns you may have voiced on the site or with our customer service department.

All personal information relative to this website is stored in the United States indefinitely.

As is standard practice on many corporate websites, First Orion uses “cookies” and other technologies to improve the user experience. These include the use of Google Analytics, to study traffic patterns, to make the website user experience more rewarding as well as to study the effectiveness of our website user communications. How Google uses the data may be found at www.google.com/policies/privacy/partners/.

Information gathered using Google Analytics consists of counts of unique daily or monthly visitors, visitors by device type, location data, unique registrants, time on site, browser types, onboarding abandonment, channel, and existing user abandonment.

If you prefer not to enable cookies, certain features of the First Orion website may not be available once cookies are disabled.

First Orion may gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site, and to gather demographic information about our user base as a whole.

In some of our email messages we may use a “click-through URL” linked to other content. When users click one of these URLs, they pass through our web server before arriving at the destination web page. We may track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked simply avoid clicking text or graphic links in the email.

In addition, we may use pixel tags — tiny graphic images — to tell us what parts of our website users have visited or to measure the effectiveness of searches website users perform on our site.

Pixel tags also enable us to send email messages in a format that website users can read. And they tell us whether emails have been opened to ensure that we’re sending only messages that are of interest to our website users.

First Orion’s website has links to the sites of other companies. First Orion is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.

If you use a bulletin board, chat room, or blog on a First Orion website or App, you should be aware that any information you share is visible to other users. Personal information you submit to one of these forums can be read, collected, or used by other individuals for their purposes. First Orion is not responsible for the personal information you choose to submit in these forums.

First Orion does not sell any personal information collected in connection with our website.

Personal information stored in the United States may be accessed by courts, law enforcement, and national security authorities in the United States upon First Orion receiving a proper request.

APIs, Portals, and Help Desks

First Orion provides various ways for clients to communicate and provide data, including some personal data, to us. These automated tools require the user to register. In some cases, the user will be given a preauthorized user ID and password. In other cases, the user can register and specify their own user ID and password.

Application Program Interfaces (APIs) allow our approved clients to submit information to and retrieve information from one or more of our products and services.

Portals allow businesses and individuals to register for a product or service.

Our automated Help Desk allows clients and individuals to submit trouble tickets to First Orion with questions or problems they are having with a product or service.

All of these systems require the individual to register and provide contact information such as individual name, company name, email and phone number.

Transfer or Sharing of Personal Information

Your personal information may be shared with the following persons or entities.

  • Persons, companies or professional firms providing advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services to First Orion;
  • Vendors hired to provide support services for First Orion’s lines of business (e.g., hosting providers or e-mail platform providers);
  • Persons authorized to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
  • Persons authorized to process personal information needed to carry out activities strictly related to the provision of First Orion’s services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of First Orion);
  • Other companies/entities that are part of First Orion; and
  • Public entities, bodies or authorities to whom your personal information may be disclosed in accordance with the applicable law or binding orders of those entities or authorities.
  • Persons, companies or professional firms involved on content provision.

First Orion is headquartered in the United States and may transfer personal information you have voluntarily provided, or we have collected from your use of these products and services to our United States headquarters or any other First Orion offices around the world.

First Orion does not sell your personal information that is collected by this website.

Your Rights

You, as a data subject, are entitled to exercise the following rights at any time once you are verified as the one whom the data is about:

    • Access your personal information being processed by First Orion (and/or get copy of that personal information), as well as information about First Orion’s processing of your personal information:
    • Correct or update your personal information processed by First Orion, where it may be inaccurate or incomplete;
    • Request erasure (deletion) of your personal information being processed by First Orion, where you feel that the processing is unnecessary or otherwise unlawful;
    • Request the restriction of the processing of your personal information, where you feel that the personal information processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
    • Exercise your right to portability: the right to obtain a copy of your personal information provided to First Orion, in a structured, commonly used and machine-readable format, as well as the transmission of that personal information to another data controller; or
    • Object to the processing of your personal information, based on relevant grounds related to your particular situation, which you believe must prevent First Orion from processing your personal information. This includes the right to opt-out of the sale of your personal information which can be accessed by Contacting Us.

Storage, Processing and Retention of Personal Information

First Orion is headquartered in the United States. We may store, access and/or transfer personal information you have voluntarily provided, or we have collected in these products and services to our United States headquarters or our First Orion UK business.

Personal information provided or collected by these products and services is stored in First Orion’s United States or Ireland AWS facility or our Brazil data center.

Personal information collected and processed by these products and services will be kept for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

Protecting your Personal Information

First Orion takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.

Merger, Sale or Bankruptcy

In the event that First Orion is acquired by or merged with a third party entity, we reserve the right to transfer or assign the information we have collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used.

Updates to this Policy

First Orion reserves the right, at its sole discretion, to change, add or remove portions of its privacy policy from time to time by posting the updated privacy policy and effective date. It is your responsibility to check this privacy policy periodically for changes.

Your continued use of these products and services constitutes your agreement to this Privacy Policy and any amendments that have been made.

Questions and How to Contact Us

If you have questions or concerns about this privacy policy or our information practices, you can contact us or our Data Protection Officer at privacy@firstorion.com.br, or by sending paper mail to:

FIRST ORION Brasil Tecnologia Ltda.
Attention: Data Protection Officer
Av. Paulista, 2421 – 1º andar – Caixa Postal 94 – Bela Vista – CEP 01311-300
São Paulo/SP

© 2021 First Orion Corp. All rights reserved