# Privacy Policy Learn how Firstbase approaches data collection and more. ## Firstbase Privacy Policy We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint. We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws. **Key terms:** It would be helpful to start by explaining some key terms used in this policy: - We, us, our: Firstbase Inc **Personal information:** any information relating to an identified or identifiable individual **Special category personal information:** Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation. **Personal information we collect about you:** We may collect and use the following personal information about you: - Your name and contact information, including email address, home address and telephone number. - Your photograph if you choose to provide it to us. - Information from accounts you link to us, eg Facebook, Google, Twitter. - Information about how you use our website, IT, communication and other systems. This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you. **How your personal information is collected:** We collect most of this personal information directly from you or from your employee via our website or our web API your employer has access to. - From a third party with your consent, eg: your employer's HR system. - Via our IT systems, eg: website usage logging. **How and why we use your personal information:** Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg: - To comply with our legal and regulatory obligations; - For the performance of our contract with you or to take steps at your request before entering into a contract; - For our legitimate interests or those of a third party; or - Where you have given consent. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so: **What we use your personal information for:** Our reasons. - **To provide services to you:** For the performance of our contract with you or to take steps at your request before entering into a contract. - **To prevent and detect fraud against you or Firstbase Inc:** For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you. - **Conducting checks to identify our customers and verify their identity:** To comply with our legal and regulatory obligations. - **Screening for financial and other sanctions or embargoes:** To comply with our legal and regulatory obligations. - **Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business:** To comply with our legal and regulatory obligations. - **Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies:** To comply with our legal and regulatory obligations. - **Ensuring business policies are adhered to:** For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you. - **Operational reasons, such as improving efficiency, training and quality control:** For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price. - **Preventing unauthorised access and modifications to systems:** For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. - **Updating and enhancing customer records:** For the performance of our contract with you or to take steps at your request before entering into a contract. - **Statutory returns:** To comply with our legal and regulatory obligations. - **Ensuring safe working practices, staff administration and assessments:** To comply with our legal and regulatory obligations. - **Marketing our services to:** Existing and former customers; Third parties who have previously expressed an interest in our services; Third parties with whom we have had no previous dealings. **External audits and quality checks:** For our legitimate interests or those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. The above table does not apply to special category personal information, which we will only process with your explicit consent. ## Promotional Communications We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new products AND/OR services. You have the right to opt out of receiving promotional communications at any time by: - Contacting us at privacy@firstbasehq.com - Using the ‘unsubscribe’ link in emails or reply ‘STOP’ **Who we share your personal information with:** We routinely share personal information with other third parties we use to help us run our business, e.g. marketing agencies or website hosts or API service providers; We may also share personal information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. **Where your personal information is held:** Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents. **How long your personal information will be kept:** We will keep your personal information while you have an account with us or we are providing services to you. After that, we will keep your personal information for as long as is necessary: - To respond to any questions, complaints or claims made by you or on your behalf; - To show that we treated you fairly; - To keep records required by law. We will not retain your personal information for longer than necessary for the purposes set out in this policy. **Transferring your personal information out of the EEA:** To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA). **Your Rights** You have the following rights, which you can exercise free of charge: - **Access:** The right to be provided with a copy of your personal information (the right of access) - **Rectification:** The right to require us to correct any mistakes in your personal information - **To be forgotten:** The right to require us to delete your personal information—in certain situations - **Restriction of processing:** The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data - **Data portability:** The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations - **To object:** The right to object at any time to your personal information being processed for direct marketing (including profiling). ## Keeping Your Personal Information Secure We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. ## How to Complain We hope that we can resolve any query or concern you may raise about our use of your information. **Changes to this privacy policy:** This privacy notice was published on 26 May 2020. We may change this privacy notice from time to time.