FIRST CORP GROUP SIA
PRIVACY POLICY
Welcome to the FIRST CORP GROUP SIA (“FCG”) Privacy Policy. FCG understands that your privacy is important to you and that you care about how your personal data is used. We appreciate your privacy and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the applicable law. This section of our site is intended to provide you with information about personal data processing and data protection in FCG.
Please read this Privacy Policy carefully and ensure that you understand it.
COOKIE POLICY
From time to time, FCG may place information on your computer which allows FCG to recognize your computer. This information is commonly known as a “cookie”. Typically, cookies enable collection of certain information regarding your computer, including your internet protocol (IP) address, your computer’s operating system, your browser type, and the address of any referring sites. Cookies are intended to enable and enhance FCG’s services as provided by accessing the website or entering into a contract for services (the “Service”).
By accessing or continuing to access the Service, you agree to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Service.
CONTACT DATA PROTECTION STATEMENT
Protecting the integrity of your data, whether about you, your company, your transactions, your products, or your service, is our highest priority. The commitment to keep your personal data confidential and secure at all times and the personal data processing practices in our business activities are explained below. Your personal data is processed in accordance with all applicable laws and regulations.
When you are representing our customer or vendor company and engaged with us (e.g. using or buying the products or services from us or selling products or services to us) (“Business Activity”), this Contact Data Protection Statement (“Statement“) is intended to provide you with general information on the processing of your personal data (“Contact Data“).
Please read this Statement carefully prior to accessing or participating in any Business Activity. By accessing or participating in the Business Activity and/or submitting (directly or indirectly) your Contact Data in connection with the Business Activity, you express your understanding to the processing of your Contact Data in the manner provided in this Statement. Otherwise, we expect you will immediately discontinue accessing or participating in the Business Activity, and you will not provide or will cease to provide your Contact Data to us. However, please note that absence of your Contact Data might fully or partially prevent us from fulfilling or executing the Business Activity.
The Data Controller
For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”), FCG is the Data Controller.
We do not have a data protection officer. We have appointed a Data Privacy Manager. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below:
FIRST CORP GROUP SIA, registered in the Republic of Latvia, company No 44103144689
Address: Paula Lejiņa 1-49, Riga, LV-1029, Latvia
Telephone: +371 22 13 37 32
E-mail: legal@firstcorpgroup.com
Data Privacy Manager: Mrs. Jelena Anikejeva
Our Data Collection Methods
Accessing or participating in some Business Activities with us you will need to provide us with certain Contact Data. Depending on the Business Activity, it is also possible that all or certain Contact Data is collected interactively from you (e.g. in a sales meeting or by phone or by e-mail, etc.) without subjecting you to any computerized data collection method.
In addition to collecting Contact Data from you personally, we may collect your Contact Data from other sources, including but not limited to other persons providing services for us or working with us as agents, vendors, banks, payment platforms, etc., or Internet resources as www.google.com, www.facebook.com, www.linkedin.com, etc., or other data bases FCG has access to.
Furthermore, in the course of your participation in any Business Activity electronically, we may automatically track certain Contact Data concerning you, such as your IP address, the source of your visit and type of web browser even prior to explicitly requesting any of your Contact Data.
It is not statutory for you as the Contact Data subject to provide the Contact Data, but certain Contact Data is required to execute or enter into a Business Activity (such as business contract) with FCG. Lack of or failure to provide Contact Data prevents or may prevent the Business Activity (such as business contract) as the case may be.
The Data We Collect and Process
Basic Contact Data consists typically of your name, e-mail address, residence address, telephone number and the name of your employing company (if applicable).
In addition, we may collect other types of Contact Data that are necessary for the Business Activity in question. For Customers, we also collect marketing data such as preferred survey method, E-mail marketing consent, SMS marketing consent, and similar. For Vendors and Agents, we also collect data regarding access to FCG digital platforms and miscellaneous business information, among others.
Generally, to the extent permitted by applicable laws and regulations, we retain your Contact Data at most five (5) years after the last Business Activity where you have been involved, but the specific retention period is described in the relevant Description. Additionally, as the case may require, we may have to extend Contact Data retention on the grounds of establishment, exercise or defense of legal claims or execution of our internal investigations. This retention period is justified due to our obligations or needs related to e.g. product and service warranties, product liability statutes as well as burdens of proofs in possible litigation situations.
The Purposes of Data Collection and Processing
The primary purpose of collecting and processing your Contact Data is to make the Business Activity and related products and services available for you. Additionally, among other defined processing purposes, we may use your Contact Data to communicate with you. For instance, we may provide additional information relating to our products and/or services or other similar topics. The information may contain advertising in the form of electronic direct marketing or otherwise. If direct marketing is included in the Business Activity, we take into account related special safeguard requirements, including consistently providing you with the option to unsubscribe from our marketing activities. We may also use your Contact Data for research and development purposes such as improving and developing our IT systems and business processes.
The purpose of use of the Contract Data may include business development and reporting, quality management, research and development of products and services, research and development of FCG IT infrastructure, invoicing, taxation and related financial transactions, and other purposes to further the conduct of business.
At all times and independent of any single purpose of processing we strive for efficient and secure Contact Data processing. This includes continued development of the Business Activities to ensure high quality and a broader scope and availability of our products and services.
Lawfulness of Processing of Contact Data
Processing of your Contact Data is generally and primarily based on legitimate interest of the data controllers. Based on defined purposes of uses of Contact Data and relationship between data controllers and Contact Data subjects, the primary legitimate interest of the data controllers is the possibility to conduct justified and lawful business according to applicable legislation.
Secondarily, for certain Contact Data subjects, our processing of Contact Data is based on direct or indirect contractual relationship: processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, and processing is necessary for compliance with a legal obligation to which the controller is subject.
Disclosures and Transfers of Contact Data
Your Contact Data may be transferred to our affiliates or to third parties (e.g. agents, vendors, banks, payment platforms, etc.) who process Contact Data on our behalf for the purposes described in this Statement and in the relevant Description. In this way, we do not release the Contact Data from our effective control. In some circumstances, we may have to disclose your Contact Data by law, because a court or the police or other law enforcement agency has asked us for it.
Due to technical and practical requirements, your Contact Data may be processed in locations other than the country in which you are situated, including locations outside the European Union or European Economic Area (incl. Switzerland). Therefore, countries to which your Contact Data may be sent/accessed from may have a different standard of data protection than the country in which you are situated. However, in all such cases, the processing of Contact Data shall be in accordance with applicable legislations (e.g. justified by EU Commission standard contractual clauses) and our data processing policies and instructions.
Contact Data are transferred outside EU and/or EEA (incl. Switzerland) only as allowed by and in accordance with applicable laws. In case of absence of EU Commission adequacy decisions, EU Commission standard contractual clauses (of type controller to processor, EU Commission decision 2010/87/EU) are used as appropriate or suitable safeguards for these data transfers. Copies of the standard contractual clauses will be available through the contact details mentioned below. Furthermore, if EU Commission adequacy decisions are applicable, we may rely on them.
If your Contact Data is transferred to external data processors (e.g. agents, vendors, banks, payment platforms, etc.) appropriate contractual arrangements (including EU Commission standard contractual clauses, as applicable), as required by the applicable laws, are executed to secure lawful and appropriate processing of your Contact Data.
We may also share your Contact Data with a purchaser or potential purchaser of our business.
We may provide aggregate statistics about our customers, sales, traffic patterns, and other related Business Activity information to reputable third parties, but these statistics are anonymized and will not include your Contact Data.
Security
Unfortunately, the transmission of information via the internet is not completely secure. We cannot fully guarantee the security of your Contact Data transmitted to us; any such transmission is therefore at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorized and illegal access, alteration, and denial of use of your Contact Data.
Your Contact Data is protected by technical and organizational measures against accidental and/or unlawful access, alteration, destruction, or other processing including unauthorized disclosure and transfer of your Contact Data.
Such measures include but are not necessarily limited to proper firewall arrangements, appropriate encryption of telecommunication and messages as well as use of secure and monitored equipment. Data security is of special concern when third parties (e.g. data processing subcontractors) providing and implementing IT systems and services are retained.
FCG duly observes data security requirements in IT system access management and monitoring of access to IT systems. Personnel processing your Contact Data as part of their tasks is trained and properly instructed in data protection and data security matters.
Use of Cookies
From time to time, we may place information on your computer which allows us to recognize your computer. This information is commonly known as a “cookie”. Typically, cookies enable collection of certain information regarding your computer, including your internet protocol (IP) address, your computer’s operating system, your browser type, and the address of any referring sites. Cookies are intended to improve availability and quality of the Business Activity. A separate Cookie Statement explains the cookies in detail (references to this Statement above and below also include the contents of the Cookie Statement unless otherwise stated case by case). In case of possible discrepancy, the information provided in the Cookie Statement prevails over information of this Statement.
Your Rights
In accordance with applicable legislation, you, as the data subject, have at any time the right to:
If you wish to exercise any of the rights set out above, please contact us at legal@firstcorpgroup.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also contact you to ask you for further information in relation to your request to speed up our response.
The request may be declined where allowed or required under the law.
Other Websites
Our Business Activity related information sources may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites are separate from our websites and do not operate under this Statement or any other data protection communication of us, but have their own privacy policies, data protection statements or similar announcements. We do not accept any responsibility or liability for these policies, statements and announcements or the lack of them or your use of such websites. Please check these policies, statements and/or any other data protection documents before you submit any Contact Data to these websites.
Changes to This Statement
From time to time, this Statement may have to be changed or amended. In addition, the access to the Business Activity may be modified or revoked at any time with or without notice. It is therefore recommended that you revisit this Statement periodically to review any changes to this Statement.
Our Responsibility and Contacting Us
FIRST CORP GROUP SIA, duly organized and registered in the Republic of Latvia under company number 44103144689, (also “FCG”, “we”, “us”, “our” above and below), are the data controllers for your personal data. FCG has the general responsibility and ultimate mastery on Contact Data and responsible for transfers of Contact Data outside EU/EEA, as well as centralized IT subcontracting. Other companies (agents, vendors, banks, payment platforms, etc.) may act as data processors for your personal data on behalf of the data controllers.
If you want to contact us on data protection related matters, please send us an e-mail at legal@firstcorpgroup.com
Effective Date: April 17, 2020
