Privacy policy

PRIVACY POLICY
Effective Date: January 1, 2016

To review material modifications and their effective dates scroll to the bottom of the page.

This Privacy Policy governs the collection, use, and sharing of information, including Personal Information (defined below), collected through the mobile software application FDF (“App”) owned by First Direct Financial LLC (“FDF”). By using the App you are accepting the practices described in this Privacy Policy. All references to “we” or “us’ shall be construed to mean FDF.

HOW WE MODIFY THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy on this page. Your continued use of this App indicates your acceptance of the amended Privacy Policy.

Regarding Personal Information (defined below), if any modifications are materially less restrictive on our use or disclosure of the Personal Information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information.

THE TYPES OF INFORMATION WE COLLECT

Personal Information. We collect information from you that is protected for purposes of privacy and data security (“Personal Information”). Personal Information that we collect may vary with each separate purpose for which you provide it, and it may include one or more of the following categories: name, physical address, an email address, phone number, credit card information including credit card number, expiration date, and billing address, and precise geo-location data.

Precise Geo-Location Information. We may collect your precise geo-location information only with your prior consent that you provide through your mobile device. Your continued use of our App acknowledges your consent to collect this information.. You are able to withdraw your consent for us to acquire your precise geo-location information from your device through your device settings, although we are not in control this process.

Financial Information. We may collect your financial information only with your prior consent that you provide through your mobile device. Your continued use of our App acknowledges your consent to collect this information.

Non-Personal Information. We reserve the right to collect anonymous information such as your mobile browser type, the type of your mobile device, your mobile device ID, the IP address of your mobile device, and the dates and times that you may access this App and specific pages (“Non-Personal Information”). Non-Personal Information is essentially anonymous when collected.

Termination of Information Collection. App users may terminate the collection of all information by deleting this App from their mobile device.

HOW AND WHEN WE COLLECT INFORMATION

Personal Information. We collect Personal Information at the time you provide it to us. We collect Personal Information through sign-up forms and as part of your registration for the App. Personal Information that we collect may vary with the each sign-up or registration.

Precise Geo-Location Information. We collect precise geo-location information when you access the App through technologies like GPS, Wi-Fi, or cell tower proximity.

Financial Information. We collect financial information when you provide it to us through sign-up forms and as part of your registration for the App.

Passive and Analytical Information. We reserve the right to monitor your use of this App. As you navigate through the App, Non-Personal Information may be passively collected (that is, gathered without your actively providing the information) using various analytics and reporting technologies, such as cookies and web beacons.

HOW WE USE YOUR INFORMATION

Personal Information. We use your Personal Information for the performance of the features provided by the App, our private, internal reporting for the App, and security assessments for the App. If you have first provided consent through your mobile device, we may use your Personal Information together with a push notification token (not your native manufacturer ID) to send you push notifications regarding services specified in the App. You may manage push notifications in your device settings.

Precise Geo-Location Information. We use your precise geo-location information only for the location-based tools provided in our App.

Financial Information. We will use your financial information only for the purpose it was given, and no other.

Non-Personal Information. We reserve the right to make full use of Non-Personal Information. For example, we may use Non-Personal Information to provide better service to App visitors, customize the App based on your preferences, compile and analyze statistics and trends about the use of this App, and otherwise administer and improve this App for your use.

INFORMATION SHARING AND DISCLOSURE

General Disclosure Policy. Our general policy is that we will not share, sell, rent, or provide access to your Personal Information to others. The only exceptions to this general policy: (i) are described in the subsections below, and (ii) if you explicitly approve through our site. We reserve the right to disclose Non-Personal Information without restriction.

Affiliated Entities. We reserve the right to provide your Personal Information and Non-Personal Information to any affiliated entities we may have, including our subsidiaries. Affiliated entities are entities that we legally control (by voting rights) or that control us.

Service Providers. We reserve the right to provide access to your Personal Information and Non-Personal Information to our trusted service providers that assist us with the operation and maintenance of this site. For example, we may contract with third parties to process payments, host our servers, provide security, and provide production, fulfillment, optimization, analytics, and reporting services. Our service providers will be given access to your information only as is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or assets to another organization, such as in the course of an acquisition, merger, bankruptcy or liquidation, we may transfer your Personal Information and Non-Personal Information. In such an event, we will require the buyer or transferee to agree to our commitments provided in this Privacy Policy.

Legal Process, Enforcement and Security Notice. We reserve the right to disclose your Personal Information and Non-Personal Information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request (such as for example, to comply with a subpoena or court order), (ii) to detect, prevent, and address fraud or other illegal activity, and (iii) to investigate, respond to, or enforce violations of our rights or the security of this site. If we believe that the security of your Personal Information may have been compromised, we may notify you of the relevant facts as promptly as possible under the circumstances, and if you have provided us your email address, we may notify you by email. You consent to our use of your email address for this purpose.

Marketing Affiliates and Resellers. We reserve the right to disclose your Personal Information to any of our (i) marketing affiliates that referred you to our App, and (ii) resellers that may re-sell our products or services to you. We may also disclose your Personal Information to any marketing partners that may participate in the offer or related fulfillment. Understand that you originated with these marketing affiliates and resellers, and that the information you may provide to them is subject to their privacy policies also.

When We Act as a Marketing Affiliate or Reseller for Others. We may act as a marketing affiliate or reseller for certain of our marketing partners for purposes of selling their products or services to you, and we reserve the right to right to disclose your Personal Information to them for purposes of transaction processing, fulfillment, and support. These marketing partners may also email you regarding complimentary products or services, however, you have two ways to opt out of receiving these emails – (i) contact us (as provided below under the Contact Us heading) with a request to opt out, or (ii) wait until you receive an email from them and then unsubscribe.

Third Parties For Direct Marketing Subject to Opt-In. We may provide you with the opportunity to receive promotional offers from specifically identified third-parties through their direct marketing efforts, but only if you explicitly consent (opt-in) to receive each offer. If you explicitly consent (opt-in), your Personal Information will be shared only with the specifically identified third-party to enable them to provide you with the offer you have requested, and then only in connection with that specific promotion and not on a continual basis. Any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should review any privacy policies posted on any of these sites before providing information to them.

Your California Privacy Rights. As described above, from time to time, we make your Personal Information available to third parties. If you do not want us to share your Personal Information with other companies or organizations, you may request opt-out of this information sharing by making a request at the following email address: compliance.officer-at-firstdirectfinancial.com. This notice is designed to comply with California’s “Shine the Light” law, but the opt-out option is available to all of our users.

Third-Party Advertising Partners. We reserve the right to share Non-Personal Information with third party advertising partners with which we have relationships. We will display behavioral ads which will be targeted to your specific interests based on your browsing history on our App or activities on third party websites. These third party ad servers or ad networks may also use cookies to track your activities on our App to measure advertisement effectiveness and other reasons that will be provided in their own privacy policies, and we have no access or control over these cookies that may be used by third party advertisers. We may participate in Google’s Adsense program, which uses DART cookies to enable serving their behavioral ads. To opt out of the DART cookies you may visit the Google ad and content network privacy policy at the following url: http://www.google.com/privacy_ads.html Tracking of users through the DART cookie mechanisms are subject to Google’s own privacy policies. We may also display contextual ads which will be based solely on the context of our App, and not will not be targeted based on your browsing history on our App or activities on third party websites. Any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should review any privacy policies posted on any of these sites before providing information to them.

SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS

In order to provide better service for our App, we may use Cookies and Web Beacons to collect Non-Personal Information to store your preferences and information about what pages you visit and past activity at our App. We may also employ Web Beacons from third parties in order to help us compile aggregated statistics regarding the effectiveness of our promotional campaigns or other operations of our App.

“Cookies” are tiny pieces of information stored by your browser on your mobile device. Cookies are also used to customize content based on your browser. Most browsers are initially set to accept cookies. If you want to disable cookies, there is a simple procedure in most browsers that allows you to turn off cookies. Please remember, however, that cookies may be required to allow you to use certain features of our App. We reserve the right to use third party web analytics services that use third party cookies (cookies passed by them, not by us) to collect Non-Personal Information about your use of our App. These web analytics services may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the service’s behalf.

Flash Cookies – third party cookies that use an Adobe Flash Media Player local shared object (LSO) – may be used along with other third party cookies for purposes of crediting any purchase you may make on our website to one of our affiliate marketing partners that may have referred you to us. These cookies will only be used for purposes of crediting sales to the referring affiliate and not for other purposes such as serving behavioral ads. Flash cookies are not the same as “browser cookies”. The Adobe Flash Media Player is software that enables users to view content on their computers. Flash cookies are also accompanied by a browser cookie. If you delete the browser cookie, the Flash cookie may automatically create (or re-spawn) a replacement for the browser cookie.

Web Beacons – sometimes called single-pixel gifs or clear gifs – are used to assist in delivering cookies, and they allow us to count users who have visited pages of our App. We may include Web Beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.

DO NOT TRACK REQUESTS

Some Web browsers incorporate a “Do Not Track” feature that signals to websites that you visit that you do not want to have your online activity tracked. Each browser communicates “Do Not Track” signals to websites differently, making it unworkable to honor each and every request correctly. In order to alleviate any communication error between browsers and website, we do not respond to “Do Not Track” signals at this time. As the technology and communication between browser and website improves, we will reevaluate the ability to honor “Do Not Track” signals and may make changes to our policy.

DATA SECURITY

We will implement reasonable and appropriate security procedures consistent with prevailing industry standards to protect data from unauthorized access by physical and electronic intrusion. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your Personal Information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive through our App.

When you transmit Personal Information through our registration process or if you purchase products or services, we encrypt that information in transit using secure socket layer technology (SSL).

After the secure transfer of your Personal Information, the information is maintained and stored with 128-bit encryption.

ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE

Any Personal Information which we may collect through this App will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of Personal Information outside your country of residence to the United States.

UPDATING PERSONAL INFORMATION

Upon request, we will permit you to request or make changes or updates to your Personal Information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your Personal Information in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary.

LINKS TO THIRD PARTY WEBSITES

The App may contain links to third party websites with whom we have a business relationship. These links may include online advertisements that we deem to be appropriate. If you do click on any of the links to their websites or accept any of their promotional offers, your click-through information and any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites; however, we have entered into agreements with these websites which provide that unless you specifically agree otherwise, they will use and share your Personal Information only for the purpose of providing or fulfilling your request for products or services. You should be careful to review any privacy policies posted on any of these sites before providing information to them.

CHILDREN’S ONLINE POLICY

We are committed to preserving online privacy for children. This App is a general audience App. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact us as provided below under “Contact Us”.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact the owner and operator of this website business at:

First Direct Financial LLC
Attn: Privacy Policy Officer
9060 East Via Linda, Suite 240
Scottsdale, AZ, 85258
Email: compliance.officer-at-firstdirectfinancial.com
Telephone: 8006803765


Material Modifications Since January 1, 2016: none.

Notice: This document is Copyright © Chip Cooper of the law firm of Jones & Haley, P.C., and licensed for use by the owner of this website under distribution rights granted to FTCGuardian.com. All rights reserved worldwide. No part of this document may be copied, reprinted, reproduced, or transmitted in any form or by any means without the prior written permission of the copyright owner.