First Orion’s UAE Engage® Services and Website Privacy Policy (Effective August 5, 2021)

Overview

First Orion Corp, DMCC, a branch office of First Orion Corp, a Delaware USA company, is a business dedicated to using technology and data to give consumers tools to recognize and manage calls they receive and to help businesses reach the right people in a compliant manner.  Our mission is to provide transparency and control in communication that empowers people to trust their phones again.

Scope of this Policy: This Privacy Policy covers the collection, use, disclosure and sharing of personal information (i.e., information that relates to an identified or identifiable individual) and the technologies used by First Orion through our Engage® services and on our website (firstorion.ae). Any information you provide to First Orion through the use of our Engage® services, through the use of our website, or that which is gathered by First Orion based on your use of our website will be collected and processed in a lawful, fair, and transparent manner.

First Orion’s Call Enhancement Suite (Engage® Service) 

First Orion’s Call Enhancement Suite of services provides companies who call you the ability to display enriched, branded, personalized information so you know more about who is calling and why they are calling so you are comfortable answering the call. First Orion is a data processor for these services.

Our Engage® service allows a richer display of information that is not limited to the caller ID field. This service is provided through our stand-alone Engage® App, or as a feature of other Apps, you may download or have on your mobile device. You can find our Engage® App in the Google Play Store for Android devices or the App Store for iPhones. When you register with Engage®, it collects identifying information in the form of your phone number and uses it initially for identity validation purposes.  We also use your phone number and other specifications about your device so we know where to deliver the enhanced information about the caller and to properly deliver the message in a compatible format.

For the service to function, you will need to allow Engage® to access your contacts so the Engage® delivery service can dynamically create a contact for incoming calls that display the enhanced information. We do NOT export any information from your contacts for any purpose. Once the enhanced call is delivered to your phone, the contact is automatically deleted.

All personal information relative to our Call Enhancement Suite is stored in Ireland and retained until it is no longer needed by our clients.

First Orion’s UAE Website

Data Collected and Processed on our website:  

Our website is hosted in the USA and provides general information to help you better understand the products and services we offer in the UAE and surrounding region. It also provides information on how to contact us.

When you fill out the Contact For General Inquiries form found at the bottom of each webpage, you are asked to provide your name, mailing address, phone number, email address, and information relating to your inquiry or support issue.  This allows us to respond to any questions or concerns you may have about the website or our lines of business.

All personal information relative to First Orion’s UAE website is stored in the USA for as long as needed to achieve the purpose for which the data is collected and processed.

Cookies: As is standard practice on many corporate websites, First Orion uses “cookies” to improve the user experience.  Our cookie policy can be found at https://www.iubenda.com/privacy-policy/60166633/cookie-policy

Links to Other Websites: Our website may have links to the sites of other companies. First Orion is not responsible for their privacy practices. We encourage you to learn about the privacy policies of those companies.

Purposes and Grounds for Processing: First Orion will use the personal information you voluntarily provided on the contact form to respond to your inquiry or complaint.  This information is necessary to fulfill your request.

First Orion will also analyze the personal and non-personal information collected from your visit to our website to develop and administer the website (analytics and profiling). This processing is dependent on your acceptance or rejection of the use of cookies.

Both personal and non-personal information will also be used to detect and prevent misuse of our Website, or any other fraudulent activities carried out through our website. Such processing is in accordance with the relevant laws which may include access to the information by local authorities.

We do not sell your personal information collected on our website.

Recipients of Personal Data:  Your personal information may be shared with the following persons or entities.

  • Persons, companies or professional firms providing advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services to First Orion;
  • Vendors hired to provide support services for First Orion’s lines of business (e.g., hosting providers or e-mail platform providers);
  • Other companies/entities that are part of First Orion Corp; and
  • Public entities, bodies or authorities to whom your Personal Data may be disclosed in accordance with the applicable law or binding orders of those entities or authorities.

Transfer of Personal Data:  First Orion is headquartered in the USA.  We may transfer personal information you have voluntarily provided, or we have collected from your visit to our website to our USA headquarters or any other First Orion offices around the world.

Retention of Personal Data:  Personal Data processed by our website or through our Engage® service will be kept by First Orion for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

Personal Data:  Personal data provided by you relative to our website or collected through our Engage® service is stored in the USA and accessible from the UAE.

Data Controller and Processor Roles: First Orion is the data controller for all information collected and processed from our website.  First Orion is the data processor for all information collected and processed through our Engage® service.

Your Rights: You, as a data subject, are entitled to exercise the following rights at any time:

  • Access your Personal Data being processed by First Orion (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
  • Correct or update your Personal Data processed by First Orion, where it may be inaccurate or incomplete;
  • Request erasure of your Personal Data being processed by First Orion, where you feel that the processing is unnecessary or otherwise unlawful;
  • Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
  • Exercise your right to portability: the right to obtain a copy of your Personal Data provided to First Orion, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller; or
  • Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent First Orion from processing your Personal Data.

Aside from the above means, you can also exercise your rights described above by sending us an email using the form provided at the end of each webpage under Contact For General Inquiries. As a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through our website is unlawful.

How we protect your personal information

First Orion takes precautions — including administrative, technical, and physical measures — to safeguard your personal information against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction.

Updates

First Orion reserves the right, at its sole discretion, to change, add or remove portions of its privacy policy from time to time by posting the updated privacy policy and effective date. It is your responsibility to check this privacy policy periodically for changes.

Privacy questions

If you have questions or concerns about this privacy policy or our information practices, you can contact us at  https://firstorion.ae/contact-general/ or our Data Protection Officer at privacy@firstorion.com, or by sending paper mail to:

First Orion Corp, DMCC

Attention: Data Protection Officer

 

Mazaya Business Avenue BB1

Office 3005, Jumeirah Lakes Towers

Dubai – United Arab Emirates

 

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