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First Mode Privacy Policy

Updated October 10, 2023

This Privacy Notice describes the personal information First Mode Holdings, Inc., (“First Mode”, “we”, “us”, or “our”) collects, how we use this information, with whom we share it, and the choices you have in connection with this.

APPLICABILITY
This Privacy Notice applies to: (i) the First Mode website www.firstmode.com (the “Website”); (ii) our interactions and communications with you; and (iii) our offline services (collectively, the “Services”).

CONTROLLER AND CONTACT DETAILS
When you use the Services, your personal information is collected and processed by First Mode as the data controller.  For questions or concerns with respect to this Privacy Notice, please email us at privacy@firstmode.com or write to us at: 542 First Avenue South, Suite 300 Seattle, WA 98104, USA.

We are registered with the Information Commissioner’s office in the UK and the Information Regulator in South Africa.

What information do we collect and process about you, what do we do with it, and why?

When you visit our website
First Mode collects information automatically via cookies as you use the Website and Platform (the “Online Services”). To learn more about the cookies on our website, please read our Cookie Notice.  Particular third-party cookies to note on the Online Services include:

  • Google Analytics: We use Google Analytics to conduct analytics.  In doing so, Google Analytics may set cookies on your browser or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to our Online Services or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Notice. To prevent your information being used by Google Analytics, you can download the Google Analytics opt-out browser add-on.

When you contact us
If you get in touch with us – whether that is by phone, email, post or in person – you may provide us with personal information. For example, if you use our contact form, we ask for your name, email address and contact phone number. Only information that is needed to deal with your enquiry may be shared internally or with selected third parties. We may use the information you provide to deal with your enquiry and for no other purpose. We justify this processing on the basis of your consent.

When you enter a contract with us
If we do enter a contract or engagement, we collect your business information (business name, business address) and identifiers of your business representative (name, email address, telephone number). This information is used to communicate with you, to manage the relationship, and to facilitate the performance of the contract. We justify this processing on performance of the contract.

When you apply for a job with us
When you apply for a position at First Mode, the personal information you provide to us includes: your name, contact information (email and phone), location (city), job and career history, educational background, professional membership, whether you will require immigration sponsorship for work authorization (including what kind of Right to Work documentation you have), whether you are a citizen or permanent resident of Cuba, Iran, North Korea or Syria (to comply with US export control laws), and other information provided in your CV and cover letter. If you continue past the initial application stage, we may collect further information as described in our applicant privacy notice that will be provided with your job application. We process the information you provide to us on the basis of discussing a possible contract of employment.

For benchmarking
First Mode may deidentify or aggregate your personal information for benchmarking purposes. To the extent required by applicable data protection law, we justify this processing under our legitimate interest in the improvement of our business and Services. Once information is deidentified or aggregated, First Mode may share this information with third parties or use it for marketing purposes.

When you visit our offices
When you visit our offices, we may collect your identifiers (name, phone number), your identification information (a copy of your government-issued identification), and video recordings may also be captured through CCTV. This information is used to ensure the security of First Mode personnel and property. The legal basis for this processing is our legitimate interest in securing our business and people against burglary, theft, or vandalism.

Information collected from survey participants
First Mode may collect and use your personal information as a survey participant in the following instances:

Participate in a candidate survey:
When you participate in a survey, we may collect your identifiers (name, email address), and answers to survey questions. To the extent required by applicable data protection law, the legal basis for this processing is your consent.  You can withdraw your consent at any time by emailing us at privacy@firstmode.com.  We share candidate experience data with Greenhouse Software, our third-party hiring software provider (which we use to administer candidate experience surveys).  We share internal survey data with our third party internal survey provider (depending on the survey, this may be MS Forms, Google Forms, or Qualtrics Forms).  This survey information is used to assess and analyse the experience of survey participants.

Participate in a survey for an event:
When you participate in a survey in advance of attending one of our events, we may collect your identifiers (name, email address), and your dietary restrictions.  We share this event survey data with our third-party internal survey provider (depending on the event, this may be MS Forms, Google Forms, or Qualtrics Forms).  This information is used to facilitate your attendance at the event.

INFORMATION SHARING
First Mode may share the personal information identified in this Privacy Notice in the following instances:

  • Within First Mode: Where necessary, First Mode may share your personal information within First Mode to efficiently carry out and improve our business and to the extent permitted by law. To the extent required by applicable data protection law, the legal basis for this sharing is our legitimate interest in carrying out our business operations efficiently.
  • With service providers: First Mode may share your personal information with service providers that perform services on First Mode’s behalf in connection with the Services. To the extent required by applicable data protection law, the legal basis for this sharing is our legitimate interest in providing the Services more efficiently. The categories of service providers we share with includes: IT support, payment processing, email vendors, website hosing and development, online recruitment platform and HR providers, CRM providers, smart manufacturing platform providers, remote signature software providers, online calendaring providers, equity management platform providers, payroll providers, survey providers, visitor management providers, and background check providers. Please contact us if you require detailed information about our processors.
  • In the event of a corporate reorganization: In the event that First Mode enters into, or intends to enter into, a transaction that alters the structure of First Mode, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our assets, First Mode may share your personal information with third parties for the purpose of facilitating and completing the transaction. First Mode may also share your personal information with third parties if First Mode undergoes bankruptcy or liquidation, in the course of such proceedings. To the extent required by applicable data protection law, the legal basis for this is our legitimate interest in carrying out our business operations.
  • For legal purposes: First Mode may share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights; as required to enforce our terms of use or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. We justify this processing under legal obligation and our legitimate interests.

INTERNATIONAL TRANSFERS
First Mode operates in the USA, Australia, the UK, Chile, and South Africa. This means that your personal data may be viewed by First Mode employees who may not be in the same country as you. As all countries do not have the same levels of protection for personal data, we have put in place an intragroup agreement which contains standard contractual clauses to safeguard the transfers of personal data between our various operations. Please note your personal data will only be viewed if necessary and only by people who need to.

CORRECT OR VIEW YOUR INFORMATION
Clients, website users, or other users of our Services may email us at privacy@firstmode.com to correct or view certain personal information of yours in our possession.

RIGHTS OF THE INDIVIDUAL
Subject to applicable law, your rights in your personal data may include:

  • Right to access: You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process.
  • Right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Right to erasure: You have the right to request erasure of your personal information. For example, you can request us to delete personal data if: (i) we no longer need the data for the purpose it was collected for, (ii) we process the data based on your consent and you revoke your consent, (iii) you object to our processing based on legitimate interest (and we do not have an overriding legitimate interest), or (iv) you object to our processing the personal data for direct marketing purposes. We may not be able to immediately erase your personal information if we have a lawful reason or a legal or contractual obligation to retain the information or continue the processing.
  • Right to restrict processing: If you believe that your personal data is inaccurate, that our processing is unlawful, or that we do not need the information for a specific purpose, you have the right to request that we restrict the processing of such personal data. You also have the possibility to request that we stop processing your personal data while we assess your request. If you object to our processing (per your right to object below), you may also request us to restrict processing of that personal data while we make our assessment.
  • Right to object to processing: You have the right to object to processing of your personal data which is based on our legitimate interest. You also have the right to object to our use of your personal data for direct marketing purposes. When you object to our use of your data for direct marketing purposes (i.e. let us know that you no longer wish to receive direct marketing from us), we will stop sending you direct marketing correspondence. You can resubscribe at any time.
  • Right to withdraw consent. Where you have given consent, you have the right to withdraw it at any time.
  • You have the right not to be subjected to automated processing of your data in a way which will have a material impact on you. We do not use automated processing.
  • Right to lodge a complaint: You have the right to lodge a complaint with the relevant Supervisory Authority. A list of Supervisory Authorities in the European Commission is available here. 

To exercise these rights, please contact us at privacy@firstmode.com.

NEVADA RESIDENTS
If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales as defined under Nevada law by contacting us at privacy@firstmode.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

INFORMATION SECURITY
First Mode implements and maintains appropriate security measures, including access controls and encryption, to protect personal information we hold. We have strict contracts with anyone with whom we share information to ensure they take appropriate care of your data, in line with applicable data protection law. We will always obey both the letter and the spirit of the data protection laws that apply to us.

RETENTION
First Mode will retain your personal information for as long as necessary for the purposes we collected it for, including for the purposes of complying with any legal, accounting or reporting requirements and, where required, for First Mode to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been finally resolved.

If you want to learn more about our specific retention periods for your personal data established in our retention policy, you may contact us at privacy@firstmode.com.

AGE RESTRICTION
The Services are not intended for individuals under the age of eighteen (18). If we learn that we have collected or received personal information from individuals under the age of eighteen (18), we will delete the personal information. If you believe we have personal information on individuals under the age of eighteen (18), please contact us at the contact information provided below.

DO NOT TRACK
The Online Services does not support Do Not Track (DNT). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

CHANGES
We may amend this Privacy Notice in our sole discretion. If we make changes, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you via email and/or by prominently posting notice on the Services and obtain your consent, if required.

CONTACTING US
If you have any questions, comments, or complaints about our Privacy Policy or practices, please contact us at:

Privacy Officer
First Mode
542 First Avenue South, Suite 300
Seattle, WA 98104 | USA
info@firstmode.com
+1 206-420-6030