FIRST LINE DATA, INC. 

PRIVACY POLICY (updated 1/10/2020) 

First Line Data recognizes the importance of informing you how we treat information about you that we may receive from this website: www.FirstLinedata.com (the “Site”). This Privacy Policy Statement (“Privacy Statement”) covers the Site and all personal information collected through the Site or your use of the Site. If you have questions or concerns regarding this Privacy Statement or about privacy at our Site, you should first contact First Line Data by sending an email to reports@firstlinedata.com or calling First Line Data at 1 (800) 400-6906 and First Line Data will resolve it. If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Statement and our Terms and Conditions (Legal Notices), including limitations on damages and application of the laws of the State of Colorado. Our business and Site change constantly. This Privacy Statement and the associated Legal Notices may also change. Our use of Personal Information that we receive and store is subject to the Privacy Statement and Legal Notices in effect at the time of our use of such Personal Information. If First Line Data decides to change its Privacy Statement or Legal Notices, First Line Data will post the revised First Line Data Privacy Statement and/or Legal Notices on this Site. 

Information Collected by First Line Data – General Users In general, you can visit this Site without telling us who you are or revealing any information about yourself. First Line Data’s web servers may collect the domain names, not the e-mail addresses, of visitors. This data helps us determine what is most beneficial for our users and how to continually create a better overall experience for them. This data does not include personally identifying information. First Line Data may gather Personal Information so that we can improve and personalize your experience with First Line Data. Information that we collect falls into the following primary categories. We may receive Personal Information that you enter into the Site, provide in an online form, or provide in any other way. You can choose not to provide some or all of the Personal Information we ask for, but this may prevent you from using some of our Site’s services and/or features. 

In addition to the preceding categories of Personal Information, First Line Data also collects certain non- identifiable information (the “Non-Identifiable Information”). Whenever you interact with First Line Data, we receive and store certain types of Non-Identifiable Information. For example, we may use “cookies” to obtain information when your web browser accesses this Site. A cookie is an alphanumeric identifier which we transfer to your computer via your Web browser and store on your computer’s hard drive. The cookie file allows us to recognize your computer when you visit our Site. On most web browsers you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie, and how to turn cookies off. We recommend that you leave cookies turned on because they may enable you to take advantage of some of our Site’s best features. 

How Do We Use Your Personal Information and Other Non-Identifiable Information? First Line Data uses the Personal Information you provide to us through this Site in a manner that is consistent with this Privacy Statement. If you provide Personal Information for a certain reason, we may use it in connection with the reason for which it was provided. For instance, if you contact us by e-mail, we may use the Personal Information you provide to answer your question or resolve your problem. If 

you contact us about a job listing, we may use your Personal Information to consider you for the position. First Line Data also uses your Personal Information and other Non-Identifiable Information collected through the Site to help us improve the content and functionality of the Site, to better understand our customers and markets, and to improve our products and services. First Line Data may also use your Personal Information to contact you, electronically or otherwise, in the future to tell you about products or services we believe will be of interest to you or to make it easier for you to use our site. If we do so, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. 

Information Collected by First Line Data – Customers In order to provide some of the services on First Line data.com, we ask you to provide personal information such as, for example, your name, e-mail address, home or business address, phone number and existing account numbers. Once you choose to provide us with personal information, you can be assured it will be used only to support your customer relationship with First Line Data. This includes responding to your requests, customizing your experience on our website, improving our services, and communicating with you about your account and about products and services we think will be of interest to you. In order to create an online account with First Line Data, you must provide an e-mail address. You may, either upon registering with FirstLinedata.com or any time thereafter, request that FirstLinedata.com not send any further communications to that e-mail address. 

Does First Line Data Share the Information it Receives? We are not in the business of selling information about our users. We consider this information to be a vital part of our relationship with our customers and we treat it with great care and respect. There are, however, certain circumstances in which we may share your Personal Information with certain third parties, as set forth below. 

Marketing: We may use any statements that you communicate to us through the Site regarding First Line Data or any of our products and services for advertising or marketing purposes. In addition, First Line Data works closely with certain businesses to provide you with high quality products and services. On occasion, these companies make special offers available to firstlinedata.com customers. You will have an opportunity to receive information about these offers. If you request to receive information about these offers, we will share your personal information with these companies so that they can send you details about their special offers. Each of these companies has its own policies with regard to the collection and use of personal information and FirstLinedata.com is not responsible for their use of your information. 

Agents: First Line Data, like many companies, may hire other companies to perform certain functions, such as mailing communications, sending e-mail and managing databases. When we employ another company to perform a function of this nature, we only provide them with the Personal Information they need to complete the task and we endeavor to prohibit them from using that Personal Information for any other purpose. 

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In transactions such as these, Personal Information may be one of the transferred business assets. 

Protection of First Line Data and Others: We may release account and other Personal information when we believe that such release is appropriate to comply with legal requirements, protect the rights, property or safety of our users, First Line Data or others, or enforce terms of our Terms of Use. In addition, we may exchange information with other organizations for fraud protection and risk reduction. 

Public Areas: Any submissions that you make to Public Areas will be considered public. First Line Data does not control, and is not responsible for, the actions of other users of the Site with respect to any information you post in Public Areas. In addition, information that you submit to Public Areas may be collected and used by others to send you unsolicited messages and for other purposes. 

Surveys & Contests: First Line Data may occasionally request information from you via surveys or contests. Participation in these surveys or contests is completely voluntary. The requested information typically includes contact information such as name and shipping address, and demographic information such as zip code. If you choose to participate in any survey or contest, the information you provide will be shared with the contest / survey sponsors to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. While First Line Data may use a third party intermediary to conduct surveys or contests, the third party may not use your personally identifiable information for any secondary purposes. 

How Secure is Information About Me? First Line Data uses reasonable measures to protect the Personal Information you provide to the Site from unauthorized access, deletion or alteration. However, the security of the Internet cannot be guaranteed. Accordingly, you should not provide any confidential information to this Site. 

Secure Transactions First Line Data maintains physical, electronic, and procedural safeguards to guard any non-public personal information you provide. When you are in the secure portion of our Site, your personal information is protected by First Line Data’s sophisticated security software. First Line Data’s servers have been enabled with Secure Sockets Layer (“SSL”) technology to automatically encrypt your information and help prevent unauthorized parties from viewing your non-account information during a secure session. That is why you must enter a unique User Name and Password each time you access your account information online. Additionally, when you place an order, FirstLinedata.com securely stores the information in your account to log in and process over an SSL connection. First Line Data employs Digital Certificates, to authenticate that you are transacting with First Line Data online, used for the SSL encryption are provided by GoDaddy and automatically use AES 256 bit encryption and TLS 1.2. 

At no time is any secure information sent using email or any insecure means. Some Web browsers and some firewalls will not permit a secure connection. If your Web browser will not permit a secure connection, you can use a standard server connection to complete your transaction, but this method may not be secure. To check that your browser is in secure mode, check that a “lock” or a “key” icon is displayed in the lower left-hand corner of your browser window. You can also check by looking at the URL bar on top of your browser. This line will typically show the first characters as “https” when a secure connection has been established rather than “http” which indicates a connection that is not secured. 

Cookies First Line Data collects information about the user and the use of the site through the use of cookies. “Cookies” are small computer files that are stored by the user’s browser on the user’s computer hard drive. Cookies contain no personal information and are not used to monitor activity once you leave the First Line Data website. Cookies are used to determine whether a user is unique or whether the user has viewed the First Line Data website before. Cookies are required and the application will not run without them. The information in the cookies is not stored in clear text. It is encrypted using an encryption algorithm and then encoded. 

Subscription Services To opt-out of receiving communications you have expressly requested (such as e-mail newsletters, product updates, etc.), please follow the opt-out instructions included in each subscription communication; or return to the Web page(s) where you originally registered your preferences and follow the opt-out instructions; or contact reports@firstlinedata.com and include your name, e-mail, and relevant information about your subscriptions and registrations; or contact us by telephone at (800) 400-6806. 

Links to Third Party Site You may be able to access Internet Websites owned by third parties (“Third Party Sites”) available through links from this Site. You understand and agree that your use of such Third Party Sites will be governed by the privacy policies of those sites and not by this Privacy Statement. First Line Data shall not be responsible for the actions of any Third Party Site operators. 

Protecting Children’s Privacy First Line Data’s products and services are not designed for or directed toward children. First Line Data does not knowingly collect Personal Information from minor children. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Statement by instructing their children to never provide Personal Information on this Site without their permission. First Line Data respects national and international laws, including the Children’s On-line Privacy Protection Act (“COPPA”), which applies in the United States. 

Information Provided by You Any personally identifiable information you provide to First Line Data via this Site is protected by First Line Data’s Privacy Statement. First Line Data does not want you to, and you should not, send any confidential or proprietary information to First Line Data except as specifically noted in First Line Data’s shopping areas and these Terms of Use. You agree that any information or materials that you, or individuals acting on your behalf, provide to First Line Data will not be considered confidential or proprietary except as specifically noted in First Line Data’s shopping areas. By providing any such information or materials to First Line Data, you expressly grant First Line Data an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, publicly perform, transmit and distribute such information and materials, and you further agree that First Line Data is free to use any ideas, concepts or know-how that you or individuals acting on your behalf provide to First Line Data. 

User Registration and Password You are responsible for maintaining the confidentiality of any password you may receive. You are responsible for all uses of your password, whether or not authorized by you. You agree to notify First Line Data immediately of any unauthorized use of your password. 

Tell-a-Friend If you choose to use First Line Data’s referral service to inform a friend about our Site, products, or services, First Line Data will ask you for your friend’s name and email address. First Line Data will send your friend a one-time e-mail inviting them to visit the site. First Line Data may store this information for the purpose of sending this one-time e-mail and tracking the success of our referral program. Your friend may contact the First Line Data Webmaster at reports@firstlinedata.com to have their information removed from First Line Data’s database. 

Changes in this Privacy Statement If we decide to change our privacy policy, we will post those changes to this Privacy Statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice. First Line Data may terminate, change, suspend or discontinue any aspect of the Site, including the availability of any features of the Site, at any time. First Line Data may also impose limits on certain features and services or restrict your access to parts or all of the Site without notice or liability. First Line Data may terminate the authorization, rights and license given above and, upon such termination, you shall immediately destroy all materials licensed to you by First Line Data through your use of the Site. 

Residents of California (added 1/10/2020) 

California residents have certain rights in relation to your personal information pursuant to the California Consumer Privacy Act (CCPA). These include the right to: 

  • Request information about the personal information that we collect about you and the manner in which we process and disclose that information 
  • Obtain the specific pieces of personal information that we have collected about you in the 12 months preceding your request 
  • Delete certain personal information that we have collected about you 
  • Opt-out of disclosures of your personal information to third parties under certain circumstances 
  • Not be discriminated against as a result of exercising any of the aforementioned rights 

California residents should be aware that this section does not apply to: 

Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act of 1994; or other information subject to a CCPA exception. 

California law requires that we verify the requests we receive from you when you exercise certain of the rights listed above. To verify your request, we will check the information you provide us in your request against third party identity verification tools. As part of this process, we may call you after you submit 

your request to verify information. You may also designate an authorized representative to exercise the rights listed above on your behalf by providing the authorized representative with power of attorney pursuant to the California Probate Code. If an authorized representative submits a request on your behalf, we will contact you to verify that they represent you. 

Contacting First Line Data If you have any questions about First Line Data, the Terms or First Line Data’s Privacy Statement, please contact us by calling 1-800-400-6906, send us an email at reports@firstlinedata.com or write to us at First Line Data, 2400 Central Ave, Ste G, Boulder, CO 80301. We use email links located on various areas of the Site to allow you to contact us directly with any questions or comments you may have. We read every message sent in and will reply promptly to everyone. We use the information you provide to respond directly to your questions or comments. We may also retain your comments to help us improve the site and any programs offered on the Site. Your personal information is only shared with persons not affiliated with First Line Data with your explicit permission.