First Insight Privacy Policy for EU Residents

    Last Updated: 5/25/2018

    First Insight Inc (First Insight, we, us) believes it is important that you understand how First Insight collects, stores, shares and uses information from and about our website visitors, customers and vendors. We adhere to this GDPR Privacy Notice (Notice), our cookie policy and other legal notices posted on this website www.firstinsight.com website), in respect of our collection, use and disclosure of personal and non-personal data collected through the website or in the course of our business activities conducted elsewhere when we act as the controller of that data and when its processing is governed by the EU General Data Protection Regulation (GDPR). This Notice does not apply to the information collected, stored, shared, or distributed by third-party sites. This Notice may be updated from time to time.

    For the purposes of GDPR, First Insight is the controller of any personal data collected from you on the website or otherwise for the purpose of conducting or developing our business with you. For the purposes of this Notice, personal data means any information relating to an identified or identifiable person.

    Summary

    First Insight is dedicated to being transparent about what data we collect about you and how we use it. Maintaining the security of your data is a priority at First Insight, and we are committed to respecting your privacy rights. The policy is structured so you can quickly find answers to the questions that interest you the most.

    Information We Collect Automatically

    When you visit our website, our server automatically collects certain browser or device generated information, which may in some cases constitute personal data, including but not limited to:

    • Your domain
    • Your IP adress
    • Your date, time and duration of your visit
    • Your browser type
    • Your operating system
    • Your page visits
    • Information about your computer or device
    • Information from third parties
    • Internet traffic

    We do not use this automatically collected information to try to identify you by name, and we do not associate it with the information you provide voluntarily, as detailed below.

    Information You Provide

    In order to access or use certain portions of the website or enjoy the full functionality of the website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal data to us in the following ways:

    • by filling in forms (for example, a 'Contact us' form) on our website or at a trade show or anywhere else we conduct business;
    • by downloading documentation from our website;
    • by subscribing to newsletters or other communications;
    • by corresponding with us by phone, e-mail or otherwise using our contact details; or
    • by applying for a job, work placement or internship, in relation to which you should also refer to the specific privacy notices made available to you during the recruitment process.

    Typically, the personal data you give us may include name, business affiliation, business address, telephone number, and email address, and any personal details required to resolve any enquiries or complaints. Where you are applying for a job, work placement or internship, you will be asked to provide certain additional information, for example about your education, employment history and right to work, pursuant to a specific privacy notice for job candidates.

    This personal data is required to enter into a contract with you (such as in anticipation of an employment contract or a services agreement) or to perform a contract with you (such as to provide services at your request), and failure to provide any information may result in our inability to provide requested services or products, or consider your application for employment.

    Information from Other Sources

    We may also obtain contact information and employment details about you from third parties like tradeshow organizers, partners, etc., including publicly accessible sources such as LinkedIn and other social networks.

    Cookies

    Our website uses cookies. More information about our use of cookies can be found in our cookie policy.

    Use of Personal Data

    The following is an overview of our purposes for using your personal data. Additional details on how we process your personal data may be provided to you in a separate notice or contract.

    All processing and use of your personal data is justified by a "condition" for processing. In the majority of cases, processing will be justified on the basis that:

    • the processing is necessary to perform a contract with you or take steps to enter into a contract at your request, such as to fulfil an order, to review your job application, or to provide product information you have requested;
    • the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records or to verify employment eligibility;
    • the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. Our legitimate interests are to use supplier, customer and website user data to conduct and develop our business activities with them and with others while limiting the use of their personal data to purposes that support the conduct and development of our business; or
    • you have consented to the processing.

    We use the personal data we collect to:

    • conduct and develop our business with you and with others, as more fully described below;
    • provide you with any services or products you have contracted for;
    • administer and manage performance of purchase or sales agreements with our suppliers and customers;
    • provide after-sales support;
    • process, evaluate and complete certain transactions involving the website, and more generally transactions involving First Insight's products and services;
    • operate, evaluate, maintain, improve and develop the website (including by monitoring and analyzing trends, access to, and use of the website for advertising and marketing);
    • evaluate, improve and develop our products and services generally;
    • customize our website to users' needs;
    • engage you about events, promotions, the website and First Insight's products and services;
    • provide you with documentation or communications which you have requested;
    • correspond with users to resolve their queries or complaints;
    • support and manage a recruitment, work placement or internship process, including considering applications and making offers;
    • send you marketing communications, where it is lawful for us to do so;
    • protect and ensure safety of the website, First Insight confidential and proprietary information, and First Insight employees;
    • manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations;
    • share your personal data with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal data held by us about our users may be one of the transferred assets;

    First Insight will not sell or rent your personal data to third parties.

    Disclosure of Personal Data

    First Insight from time to time will share your personal data with our affiliated businesses for the purposes described above. We may also appoint third party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving our products, services or the website. First Insight may share your personal data with these affiliates and third parties to perform services that the third parties have been engaged by First Insight to perform on First Insight's behalf, subject to appropriate contractual restrictions and security measures, or if we believe it is reasonably necessary to prevent harm or loss, or if we believe that the disclosure will further an investigation of suspected or actual illegal activities.

    If your personal data is transferred outside the EU to other First Insight affiliates or to third party service providers, we will take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers of personal data among First Insight affiliates we have put in place European Commission- approved Standard Contractual Clauses. The list of all the countries to which your personal data is transferred, and whether each country benefits from a decision of the European Commission determining that the country provides adequate protection to personal data, is set forth here (United States of America; United Kingdom). You have a right to obtain details of the mechanism under which your personal data is transferred outside of the EU by contacting us.

    First Insight reserves the right to share any information that you provide which is not deemed personal data or is not otherwise subject to contractual restrictions.

    Children

    The website is not for use by children under the age of 16 years and First Insight does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the website to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify First Insight and First Insight will delete all such personal data.

    Marketing

    Where lawful to do so, and subject to your consent where required, we may communicate with you by SMS and email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the 'unsubscribe' instructions provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.

    Security

    First Insight aims to safeguard and protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and First Insight utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by First Insight are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.

    Retention of Your Personal Data

    We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation setting out the period during which legal claims may be filed in court. For example, we’ll retain your personal data during the statute of limitation period, to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.

    External Links

    The website may contain links to third party sites. Since First Insight does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This Notice applies solely to personal data collected by our websites or in the course of our business activities.

    Changes to this Notice

    Any changes or updates we may make to this Notice will be posted on this page. Please check back frequently to see any updates or changes to this Notice.

    Your Rights
    • Right to withdraw consent - where applicable, you have the right to withdraw your consent at any time. For example, if you wish to opt-out of receiving electronic marketing communications, you can change your settings in your account on the website, use the 'unsubscribe' link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.

    • Right of access, rectification and erasure - you have the right to request access to and obtain a copy of any of your personal data that we may hold, to request correction of any inaccurate data relating to you and to request the deletion of your personal data under certain circumstances. [You can see and update most of this data yourself online, or by contacting us directly.

    • Data portability - where we are relying (as the legal basis for processing) upon your consent, or the fact that the processing is necessary to perform a contract to which you are party or to take steps at your request prior to entering a contract, and the personal data is processed by automatic means, you have the right to receive all such personal data which you have provided us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

    • Right to restriction of processing you have the right to restrict our processing of your personal data (that is, allow only its storage) where:
      • you contest the accuracy of the personal data, until we have taken sufficient steps to correct or verify its accuracy;

      • where the processing is unlawful but you do not want us to erase the personal data;

      • where we no longer need your personal data for the purposes of the processing, but you require such personal data for the establishment, exercise or defense of legal claims; or

      • where you have objected to processing justified on legitimate interest grounds (see below), pending verification as to whether we have compelling legitimate grounds to continue processing.

      Where your personal data is subject to restriction we will only process it with your consent or for the establishment, exercise or defense of legal claims.

    • You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal data infringes applicable law.

      • Right to object to processing (including profiling) based on legitimate interest grounds - where we are relying upon legitimate interests to process personal data, you have the right to object to that processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal data for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

      • Right to object to direct marketing (including profiling) - you have the right to object to our use of your personal data (including profiling) for direct marketing purposes, such as when we use your personal data to invite you to our promotional events.

      Please contact us as indicated in the Contact Information section below if you wish to exercise any of your rights, or if you have any enquiries or complaints regarding the processing of your personal data.

    Contact Information

    If you have any questions in relation to this Notice or you wish to exercise any of your rights, please contact us at:

    Email
    data.protection@firstinsight.com

    Mail
    Attention: Information Security and Operations Manager
    First Insight, Inc.
    2000 Ericsson Drive, Suite 200
    Warrendale, PA — 15086
    USA

    Processing Countries
    • United States of America
    • United Kingdom