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PRIVACY POLICY

Privacy policy

 

Last Updated: August 14, 2021

 

Thank you for your interest in Firsthand, an affiliate of Infobase Holdings,
Inc. (referred to as “Firsthand”, “we”, “us” or “our”). Your privacy is
important to us, and this Privacy Policy describes how we process personal
information as part of our business operations, including the types of personal
information that we collect, the purposes for which we use it, the types of
third parties to whom we share it, and the rights and responsibilities you may
have with respect to such personal information.  This Privacy Policy applies to
the personal information you provide to us through any type of engagement or
interaction, such as when you access or use our Site or any of our Services. For
purposes of this Privacy Policy, the Site and Services are collectively referred
to as the “Online Services”. By accessing or using the Online Services or by
otherwise providing us with personal information, you are consenting and
agreeing to the terms and conditions set forth in this Privacy Policy.

 

DISCLAIMER. by using THE ONLINE services you may have the ability to provide
your RESUME AND OTHER personal information to THIRD PARTY alumni mentors,
unaffiliated advisors, AND EMPLOYEE RECRUITERS AND we are not responsible for
how SUCH A THIRD PARTY MAY collect, use, or process your personal information.
IF YOU RETAINED THESE SERVICES THROUGH A THIRD PARTY, SUCH AS YOUR EMPLOYER OR
UNIVERSITY, PLEASE CONTACT THE APPLICABLE THIRD PARTY DIRECTLY ABOUT EXERCISING
YOUR DATA PRIVACY RIGHTS.

 

 

 1. Definitions

 

For purposes of this Privacy Policy, the term “personal information “ refers to
any information that, either alone or in conjunction with other data, can be
used to distinguish or identify a particular individual, household, or device,
and that is subject to, or otherwise afforded protection under, a law, statute,
or regulation governing data privacy or security.

 

Any capitalized term that is not otherwise defined herein, shall be ascribed the
meaning set forth in the Terms of Service.

 

 2. The Types Of Personal Information We Collect

 

The type and categories of personal information that Firsthand collects varies
based on the nature and scope of our business activities. However, when you do
not provide personal information that Firsthand requests, we may not be able to
provide you our services or complete a transaction, and you agree that Firsthand
will not be liable or otherwise responsible for any damages or loss arising from
such circumstances. Generally, we collect the following types and categories of
personal information from users of our Online Services or as part of our
business operations:

 

The Personal Information We Collect

Category

Description

Identity and Contact Data

Basic data that is used to identify or contact an individual, such as your name,
title, email address, telephone and fax numbers, physical address (including
street, city, state, postal code, and/or country), and date of birth.

Resume Data

Your resume, curriculum vitae, or similar information related to your
professional experiences, which may include your Identity Data; current and
former employment/employer; Education Data (see below); awards and recognitions;
language proficiency; memberships and associations; references; publications;
volunteer work; career goals; and, professional skills and similar types of
data.

Education Data

Information pertaining to your education, including level of education
completed; schools and universities attended; degrees and certifications
obtained; dates of graduation or completion; grades and grade point average;
transcripts; attendance records; courses taken; sanctions or other disciplinary
record; awards and honors; and, similar types of data.

Users Accounts

When you set up an account within our Online Services, you may create a profile
(“Profile”) that will include your username and password, and the personal
information you upload to it, such as any Resume Data and Education Data

Advisor Data

Professional and biographical information about the Advisors who agree to
provide career counseling and similar services to Advisees.

Business Contact Data

Information related to other employees, owners, directors, officers, or
contractors of a third party organization with whom we may conduct, or possibly
conduct, business activities.

Marketing Data

Data about your marketing and communications preferences.

Transaction Data

Data about the Services you have purchased from us, including your specific
orders; details of payments made to and from you; and your purchase history and
preferences. Firsthand uses a third party service provider to collect and
process all payment card data and Firsthand does NOT collect or store any
payment card numbers.

Feedback

Your feedback about the Online Services and any of our other products or
offerings, which include data gathered from questionnaires in which you
voluntarily complete.

Survey Data

Your responses to the surveys in which you participate. In the event you
participate in our professional and employer surveys, some questions therein may
be mandatory and you cannot complete the survey without furnishing some personal
information.

Correspondence Data

Records and copies of your correspondence with us.

Demographic and Sensitive Information

We may collect demographic details, including special categories of data, such
as data related to gender and race. Firsthand uses this demographic information
to analyze the survey participants and, at times, to compare results among
different groups of participants. All demographic questions are purely
voluntary, and participants will not be penalized for not answering such
questions.

Technical Data

See below.

 

Technical Data

 

In addition to the foregoing, when you use the Online Services, we collect and
use additional data and tools, including usage data, metadata, location data,
and cookies and tracking technologies (collectively, “Technical Data”), which is
described below.  The Online Services collect Technical Data on a consistent and
reoccurring basis, unless your device settings are updated to prevent such
collection. We use this Technical Data in accordance with the terms and
disclosures set forth in this Privacy Policy.

 

Usage Data. When you access and use the Online Services, we may automatically
collect details of your access to and use of the Online Services, including
traffic data, usage logs, and other communication data, and the resources that
you access and use on or through the Online Services (e.g., browsing history,
search history). We may also collect information about your device and internet
connection, including the device’s unique device identifier (e.g., device type,
IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network
information. The Online Services may collect diagnostic-related data related to
your use of the Online Services, such as crash data and logs, performance data
(e.g., launch time, hang rate, or energy use), and any other data collected for
the purposes of measuring technical diagnostics.

 

Metadata and Device Access. The Online Services may access metadata and other
information associated with files stored on your device, such as photographs,
audio and video clips, personal contacts, and address book information.

 

Location Data. When you access and use the Online Services, we may collect
information and data identifying the precise, real-time location of the device
that is used to access or use the Online Services. You can choose whether or not
to allow the Online Services to collect and use information about your device’s
location. If you block the use of location information, some parts of the Online
Services may become inaccessible or not function properly.

 

Cookies and Tracking Technologies. We use cookies and other tracking
technologies within the Online Services. A cookie is a small file placed on your
smartphone or other device. It may be possible to refuse to accept cookies by
activating the appropriate setting on your smartphone or device. However, if you
select this setting, some parts of the Online Services may become inaccessible
or not function properly. In addition, the Online Services may contain small
electronic files known as web beacons (also referred to as clear gifs, pixel
tags, and single-pixel gifs) that permit us to analyze data on the users of the
Online Services (e.g., recording the popularity of certain content and verifying
system and server integrity). The Online Services may collect data about the
advertisements you have seen or engaged. For more information, see our Cookies
Policy.

 

 3. Video Teleconferencing

 

Firsthand hosts and uses video teleconferencing (“VTC”) platforms to facilitate
certain aspects of our Services (e.g., mentoring sessions, career fairs), and to
host conferences, meetings, training events. These VTC platforms may be owned
and administered by a third party service provider (e.g., Zoom, WebEx, Skype for
Business). Please be aware that the VTC platforms may record the content,
conversations, and discussions thereon, and such records may be stored or
retained by our third party service providers. By participating in the VTC
platforms, you hereby consent to the collection and retention of any information
and content provided therein, and hereby consent to the recording of such
activities. Notwithstanding the foregoing, each Advisor hereby acknowledges and
agrees that Advisor (i) shall not record mentoring sessions or any content
therein, or retain any communications or content therefrom, unless Advisor
obtains advanced written approval and consent of each and every party, including
the Advisee, participating in the mentoring session  and (ii) that the foregoing
approval and consent is completely voluntarily and Advisor shall not alter or
change the mentoring session in the event such approval and consent is withheld.

 

 4. How We Collect Personal Information/SOURCES

 

Firsthand obtains your personal information directly from you when you provide
it to us (i.e., direct collection) and from third parties (i.e., indirect
collection), which includes the following:

 

Direct Collection. We often collect personal information directly from you when
you undertake the following activities: use or access our Services; complete one
of our web forms; contact our customer service centers or request information
from us in any other way; visit one of our locations or premises; submit an
order or make a purchase with us; provide us contact information via a business
card or through similar communications; complete a survey or otherwise provide
us feedback; report product/service issues; communicate with us via social
networking websites, third party applications, or similar technologies; and/or
visit, one of our trade counters at an exhibition.

 

Indirect Collection. We may collect personal information about you from third
parties, which we may combine with other information we already retain in order
to provide the Online Services or promote our legal or business interests.  For
example, Institutions that partner with Firsthand may provide personal
information to us so we can create user accounts for their students. In
addition, employers may provide us with personal information and other
background data on their job applicants so we can assist with their employment
recruitment process.  If you provide personal information about a third party,
then you expressly represent and warrant to Firsthand that you have the full
right and lawful authority to provide Firsthand with the information.

 

 5. How We Use Your Information

 

We use, process and retain your personal information to provide the Online
Services, and to promote and defend our business interests. This includes:

 

 * Providing and administering the Online Services, including executing
   transactions and enabling you to access the services therein.
 * Delivering to you notice about job opportunities and communications from
   potential employers.
 * Analyzing your use of the Online Services to personalize them to you (e.g.,
   suggest employers to you based on your Resume Data).
 * Contacting you directly and providing you information about the Online
   Services or on our other products or offerings and answering service
   requests.
 * Tracking and updating your orders and invoices.
 * Furnishing you technical notices and security alerts, and support and
   administrative messages.
 * Performing analyses that help us to develop and improve the quality of our
   Online Services, and other products, and offerings.
 * Furnishing you questionnaires and conducting research and analysis to help us
   better understand your purchasing preferences, identify the products and
   services that best meet your requirements, measuring the effectiveness of our
   advertising and marketing, or to otherwise improve our business.
 * Enforcing security and legal requirements, such as detecting, preventing and
   responding to fraud, intellectual property infringement, violations of our
   Terms of Service, violations of law or other misuse of our Online Services,
   products, or facilities.
 * Administering and protecting our business and our Online Services, including
   system maintenance, support, reporting and hosting of data.
 * Protecting the health and safety of our employees, contractors, customers,
   and others in our community.
 * Promoting, defending or protecting our legal, regulatory, or business
   interests, including enforcing contracts and other agreements.
 * In any other way with your consent.

 

Survey Data

 

In important part of our Services is to undertake professional surveys to better
understand employer and employee needs, capabilities, and business models and
develop ratings for certain types of categories related thereto.  In the event
you participate in such a survey, we will use the information derived therefrom
for the following purposes:

 

Employer Profiles. As part of our Employer Profile surveys, you have an
opportunity to provide us feedback about your workplace experience with a
particular employer. Our editors consolidate, review, and analyze your feedback
(and the survey results of other participants) and write a summary of these
experiences within an Employer Profile on our Site. Firsthand editors may also
select quotes from within your survey feedback to include as part of an Employer
Profile. Please be aware that Employer Profiles, including your feedback
therein, may be published to the general public and therefore you should avoid
including in your feedback any personal information or other details that might
compromise your own anonymity or that of any other individual.

 

Employee/Intern Reviews. For our Employee/Intern Review surveys, you have an
opportunity to provide us feedback about your workplace experience with a
particular employer and your feedback may be published within an Employer Review
on our Site. Your feedback may be posted without any editorial review by us. In
addition, you may register with Firsthand in order to submit reviews, insights,
and opinions about your current or former employers or schools. In either case,
while your name is not associated with a quotation or review, the review may be
accompanied by general identifiers, where provided, such as office location,
position/level, department, or year in which the survey was conducted. The
review also identifies whether you are a “verified employee” or “verified
intern” to indicate that the comment was collected through Firsthand’s survey
process and distinguish it from other user-generated reviews.

 

Blog Posts, Career Advice, and Other Forums. Firsthand may use anonymous
comments and/or aggregated scores provided to our surveys for the purposes of
publishing blog posts or articles; making presentations; or participating in
public or private forums or other discussions on employee satisfaction,
perceptions of employers, and industry trends.

 

Research Reports. Firsthand may use aggregated and de-identified data from our
surveys for the purposes of client research, to help employers benchmark
employers against the industry and their peers and/or to gauge relative levels
of satisfaction among their own employees. In the event these research reports
include the survey’s text feedback, Firsthand reviews and edits, as necessary,
such feedback to seek to minimize the personal information associated with your
comments. However, you should be aware that their comments may be published or
used for research and avoid including details that might compromise their
anonymity.

 

 6. Sharing Your Personal Information With Others

 

We do not sell, lease, or rent your personal information to a third party for
profit or other valuable consideration. We may, however, share your personal
information with selected third parties for our business purposes, including as
set forth in this Privacy Policy. In addition, we may also share your personal
information as follows:

 

Corporate Group Sharing. We share personal information to our parent company,
Infobase Holdings Inc.,  and among our affiliates and subsidiaries who act for
Firsthand or on behalf of our parent company and these recipients may use your
personal information in accordance with the terms and conditions of this Privacy
Policy (e.g., marketing, surveys) or their own data privacy representations. In
addition to the foregoing, Firsthand may leverage computer networks and systems
of our parent company, affiliates, and subsidiaries and the personal information
may be transmitted or retained thereon.  For information about our parent
company, visit https://www.infobase.com/about/.

 

Service Providers. We share information, including personal information, with
our third party service providers that assist us in providing our Online
Services, application development, service delivery, backup, storage, payment
processing, analytics, and other services for us. These third party service
providers may have access to or process your personal information for the
purpose of providing these services for us. We may collect, and we may engage
third party analytics providers to collect, metrics and information regarding
your use of the Online Services to improve existing features or inform sales and
marketing strategies, based on our legitimate interest to improve the Online
Services.

 

Advisors and Third Party Employers. As part of the Services, we may share your
personal information with advisors and employers with whom you may seek to
engage for advice and consultation or we believe satisfy your employment or
consulting needs or requirements.

 

Business Partners. In addition, we may share data with trusted partners to
contact you based on your request to receive such communications, help us
perform statistical analysis, or provide customer support. We may partner with
trusted third parties to provide you with co-marketing content that we think may
be relevant to you. We may also share your personal information with our third
party professional advisors and consultants (e.g., outside counsel, tax
advisors).

 

Corporate Restructuring. If we (or our assets) are acquired by another legal
entity, whether by merger, acquisition, bankruptcy or otherwise, that legal
entity would receive all information gathered by Firsthand via the Online
Services, including your personal information retained thereon. To the extent
practicable, we will notify you of any such change in corporate ownership by
posting a notice on the Site or taking similar actions.

 

Compelled Disclosure. We will use or disclose your personal information if
required by law, statute, or regulation, or judicial or administrative order or
decree, or any other demand submitted by a government, regulatory, or judicial
entity that has the force and effect of law.

 

Business Interests. We reserve the right to use and disclose your personal
information to a third party if we reasonably believe that use or disclosure
will protect our rights or your safety or the safety of others.

 

Privacy Policy. This Privacy Policy may describe other circumstances in which
Firsthand shares personal information with third parties, and such descriptions
shall not limit the categories of sharing set forth in this Section 6 of the
Privacy Policy and the personal information descriptions set forth in this
Section 6 shall not limit Firsthand’s ability to share personal information as
set forth elsewhere in this Privacy Policy.

 

In the event that you facilitate a transaction with Firsthand, or request
information from, or otherwise engage with us, and such activities require
Firsthand (in our sole judgment) to share your personal information with a
service provider or other third party, you hereby consent to the same and
acknowledge and agree that any such third party information sharing is being
undertaken at your direction.

 

 7. Third Party Links, Single Sign On (SSO)

 

Firsthand may include in the Online Services certain links to other websites,
including websites operated by unaffiliated third parties. Each such third party
website has its own privacy policies and practices, which may be different than
the policies and practices described herein; we urge you to read any privacy
policy posted on a third party website carefully as such third party privacy
policy (and not this Privacy Policy) controls with respect to the collection,
use, and processing of your personal information thereon. Additionally, to the
extent that you follow a link to a website operated by an independent third
party, please be aware that Firsthand exercises no authority or control over
that third party and we cannot be, and are not, responsible for any information
that you may submit at that website or how it is used.

 

You may log into our Online Services through or from a third party social media
or authentication service (e.g., Facebook, LinkedIn, Google). These sign-on
services will authenticate your identity and provide you access to our Services,
provide you with the option to share certain personal information (e.g., name,
email address, profile picture, location) with us, and pre-populate our forms or
other parts of our Services with the personal information already retained by
the third party. You should verify your privacy settings on these third party
services to understand and determine the types of personal information sent to
us.

 

 8. Third Party Collection and Tracking

 

When you access the Online Services, certain third parties may use automatic
information collection technologies to collect information about you or your
device that is used to access the Online Services. These third parties may
include advertisers, ad networks, and ad servers; analytics companies; your
mobile device manufacturer, and your mobile service provider. They may collect
personal information about your online activities over time and across different
websites, apps, and other websites. They may use this information to provide you
with interest-based (behavioral) advertising or other targeted content. We do
not control the tracking technologies employed by third parties or how they may
be used. If you have any questions about an advertisement or other targeted
content, you should contact the responsible provider directly.

 

 9. Data Retention and Localization

 

The time period in which Firsthand retains your personal information varies
depending on the purpose for the data processing. For example, we retain
personal information needed to provide you with products and services, to
facilitate transactions you have requested, or to engage in marketing
activities, and for so long as necessary to comply with applicable laws and
regulations (including tax law) and defend our legal or business interests. In
all other cases, we retain your personal information for as long as is needed to
fulfill the purposes outlined in this Privacy Policy.

 

Firsthand is based in the United States and the personal information that we
(and our third party service providers) collect and process is retained and
stored in the United States. Please be aware that (i) the United States may not
provide the same level of protection of personal information as in your country,
state, or jurisdiction of residence or nationality, (ii) the European Union and
other foreign authorities have determined that, in some circumstances, the
United States does not provide an adequate level of protection for personal
information, and (iii) when transferred to the United States, your personal
information may be accessible by, or otherwise made available to, government
authorities and officials pursuant to regulatory, judicial, and/or
administrative orders, decrees, and demands, and/or other domestic laws,
statutes, and regulations, applicable in the United States. In addition, we (and
our third party service providers) may retain personal information in other
jurisdiction that we (or our services providers) operate. You hereby consent to
your personal information being transferred to, and stored in, the United States
and the other jurisdictions where we (and our service providers) operate.

 

 10. Information Security

 

We are committed to protecting the security of your personal information. We use
a variety of security technologies and procedures to help protect your personal
information from unauthorized access, use or disclosure. However, no information
system can be fully secure, so we cannot guarantee the absolute security of your
personal information. Moreover, we are not responsible for the security of
information you transmit to the Online Services over networks that we do not
control, including the Internet and wireless networks, and you provide us with
any information and data at your own risk. To the extent permitted by law,
Firsthand shall not be liable or otherwise responsible for any data incident
that compromiseS OR MAY COMPROMISE the confidentiality, SECURITY, integrity, or
AVAILABILITY of your personal information. The safety and security of your
personal information also depends on you. Where we have given you (or where you
have chosen) a username and password to access the Online Services, you are
responsible for maintaining the security and confidentiality of those
credentials and not revealing them to others. You must contact us immediately if
you have reason to believe that your username or password to our Online Services
have been compromised.

 

 11. No Personal Information Collected from Children

 

Our Online Services are not directed at, nor intended for use by, children under
the age of thirteen. As a result, we will not knowingly collect information from
children under thirteen years of age with or without consent from their parents
or guardians. If you are under the age of thirteen, you are hereby prohibited
from using our Online Services or with providing us with your personal
information. If you are a customer who provides us with general information
about children, you hereby represent and warrant that you have the right and
authority to provide us with such data.

 

 12. Your Responsibilities AND WARRANTIES

 

You are permitted, and hereby agree, to only provide personal information to
Firsthand if such personal information is accurate, reliable, and relevant to
our relationship and only to the extent such disclosure will not violate any
applicable data protection law, statute, or regulation or infringe upon any
individual’s data privacy rights or privileges. If you provide Firsthand with
ANY personal information about yourself or a third party, you expressly
represent and warrant to Firsthand that (I) you have the full right and
authority to DISCLOSE SUCH personal information to Firsthand, (II) THE COMPANY
CAN USE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, and
(III) YOU are in compliance with the requirements set forth HEREIN. You also
agree to fully reimburse Firsthand for any damages, losses, or expenses that
arise based on your violation of your representations, warranties and
responsibilities set forth in this Privacy Policy.

 

 13. Marketing; Shine the Light law (California Privacy)

 

You have the right to opt-out of receiving electronic direct marketing
communications from us. All electronic direct marketing communications that you
may receive from us, such as e-mail messages, will give you an “unsubscribe”
option of not receiving such communications from us in the future. California
residents have the right to request certain information regarding our disclosure
of personal information to third parties for their direct marketing purposes. We
do not share personal information with third parties with whom we have reason to
believe use such information for their own direct marketing purposes.

 

 14. California Privacy Rights (California Consumer Privacy Act)

 

Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”),
California residents may have additional data privacy rights, such as the right
to be notified about what personal information is collected about them, and our
intended use and purpose for collecting your personal information. California
residents have the right to know and access the categories or specific pieces of
personal information we have collected, used, disclosed, or sold about them over
the past twelve (12) months; the categories of sources from which the personal
information is collected; and, the business or commercial purpose for which the
personal information was collected, used, disclosed, or sold. In addition,
certain California residents have the right to request Firsthand transfer, to
the extent feasible, personal information in certain forms and formats.
California residents have the right to request that we (and any applicable
service provider) delete/erase their personal information under certain
circumstances. California residents have the right to opt-out of the sale of
their personal information and Firsthand does not sell your personal information
to third parties for profit or other valuable consideration. California
residents have the right not to be subject to discrimination for asserting their
rights under the CCPA.  The categories of personal information we have collected
about California residents in the preceding twelve (12) months, the categories
of sources from which the personal information is collected, and the business or
commercial purpose for collecting such personal information is set forth in this
Privacy Policy.

 

You, or your authorized agency, may submit a CCPA data privacy rights request to
Firsthand by contacting us in accordance with the details set forth below. If
you make, or an authorized agent on your behalf makes, any request related to
your personal information under the CCPA, Firsthand will ascertain your identity
(and the identity of the authorized agent, to the extent applicable) to the
degree of certainty required under the law before addressing your request.
Firsthand may require you to verify your request via email and match at least
two or three pieces of personal information we have previously collected from
you before granting you access to, or erasing, specific pieces, or categories
of, personal information, or otherwise responding to your request. We may
require written documentation that demonstrates a third party is authorized to
serve as your agent for the purposes of submitting the requests set forth
herein.

 

 15. Nevada Privacy Rights

 

Although we do not currently conduct sales of personal information, Nevada
residents may submit a request directing us to not sell personal information we
maintain about them to third parties who will sell or license their information
to others.

 

 16. European, SWISS, UK Data ProtectioN RIGHTS

 

If you are located in the European Economic Area, Switzerland, or the United
Kingdom (UK), you may have additional rights with respect to the personal
information we have about you. To the extent permitted by the European Union
(EU) General Data Protection Regulation (GDPR), or applicable data protection
laws in EU member states, Switzerland, or the UK, you may request the following:
access to the personal information we hold about you; that inaccurate, outdated,
or no longer necessary information be corrected, erased, or restricted; and, we
provide your personal information in a format that allows you to transfer it to
another entity. You also may withdraw your consent at any time if, and only if,
we are solely relying on your consent for the processing of your personal
information. You may object to our processing of your personal information where
that processing is based on our legitimate interest. For purposes of clarity, we
do not engage in any activity that subjects our survey participants, customers,
or others to a decision based solely on automated processing, including
profiling, which produces legal effects, or similarly significant results,
impacting them. You may submit a data privacy rights request to Firsthand by
contacting us in accordance with the details set forth below.

 

We process your personal information in accordance with the legal bases set
forth in the GDPR. For example, our processing of personal information (as
described herein) is justified based on the following GDPR provisions and which
may overlap: (1) processing is based on your consent; (2) processing is
necessary for our legitimate interests as set out herein; (3) processing is
necessary for the performance of a contract to which you are a party; and (4)
processing is required to comply with a legal or statutory obligation. You have
the right to lodge a complaint with your competent data protection authority. If
you wish to exercise any of these rights, please contact us in accordance with
the instructions provided below in the “Contact Us” section. We may need to
collect and process information about you solely for the purpose of responding
and satisfying any data right request you may have.

 

 17. Do Not Track Signals

 

Some web browsers may transmit “Do Not Track” signals to our Online Services.
Because of differences in how web browsers incorporate and activate this
feature, it is not always clear whether users intend for these signals to be
transmitted, or whether they even are aware of them. We currently do not, unless
otherwise required by law, take action in response to these signals.

 

 18. Persons with Disabilities

 

Firsthand strives to ensure that every person has access to information related
to our products and services, including this Privacy Policy. Please contact us
if you would like this Privacy Policy provided in an alternative format and we
will seek to meet your needs.

 

 19. Aggregated Data

 

Firsthand collects and retains de-identified, and aggregated data relating to
the use of our Online Services (“Aggregated Data”), and we use such Aggregated
Data for our own business purposes, such as to analyze customers and to develop,
improve, and market our services. For the avoidance of doubt, we may use
Aggregated Data for any purpose and such Aggregated Data is not subject to this
Privacy Policy.

 

 20. Communications Data

 

For the avoidance of doubt, in the event you provide Firsthand with a telephone
number as part of your registration to the Online Services or as part of a
purchase or transaction with us, you hereby consent and agree that Firsthand (or
our service providers) may contact said telephone number by any means (including
SMS/text message) for service and transactions purposes.

 

 21. Changes to the Privacy policy

 

At any time, we reserve the right to add to, modify or remove portions of our
Privacy Policy. The effective date of our Privacy Policy will be included at the
beginning of the Privacy Policy and will serve as a notice of when changes have
been implemented to the Privacy Policy. It is your responsibility to review this
Privacy Policy to determine if any revisions have been made to it. Your
continued use of our Online Services after any revisions have been made to this
Privacy Policy will indicate your acknowledgement of such changes and agreement
to be bound by the updated terms and conditions set forth herein.

 

 22. Contact Us

 

If you have questions regarding this Privacy Policy, would like to request more
information from us, or would like to exercise a data privacy right or
privilege, please contact us at any of the following: (address) Firsthand, 132
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