First Orion’s PrivacyStar App Privacy Policy effective 1.12.2021

First Orion Corp. 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.

This Privacy Policy covers the collection, use, disclosure, and sale of personal information by First Orion in the U.S. and Canada for First Orion’s free or subscription-based PrivacyStar App.

This app has various features and functionality, in addition to those native to your device (such as block a number), which include

- identifying likely scam calls,

- blocking at your request businesses who are likely scammers or other categories of calls such as telemarketers, surveys, or political,

- looking up a telephone number you don’t recognize, and

- filing complaints and reporting call violations to the proper authorities.

Depending on the carrier and the version of the PrivacyStar App that you are using, the app may include additional features such as

- displaying enhanced information on your device about who is calling you and why,

- access to an alternate call log reflecting how the “App” has treated all calls to you,

- conditional call forwarding, and

- a voicemail service allowing you to listen to, share, or delete your voicemail.

Personal Information PrivacyStar App Collects and How It Is Used

When you download PrivacyStar App , it collects identifying information in the form of your phone number and initially uses it for identity validation purposes and to know whom to bill for any fee-based services you may choose to use. – the phone number is not tied to any billing (we use Apple or Google Play billing). Phone number is strictly tied to validating the user.

To identify likely scam calls and other call categories, First Orion’s data scientists analyze all the calls made to you and others who use this service along with the actions you and other users take (such as blocking a call or reporting a problem). First Orion also collects and uses in our analysis identifying information (name, address and phone number) from third parties, including data brokers and publicly available government records, to accurately identify business numbers, to identify those business numbers that are scammers, and to categorize the other calls you receive.

This analysis provides you with the information you need to decide how to treat the call – answer it, send it to voicemail, or block it. You can block individual calling numbers or you can block all calls identified as likely scams or other categories. Another feature of the App allows you to look up a number calling you that you don’t recognize and get a name associated with the number.

In addition, in the U.S. if you believe the party calling you is violating any of the applicable telecommunication laws, you can file a complaint with First Orion and request the violation be reported to the proper authorities. This information will be provided to the appropriate government agencies such as, but not limited to, the Federal Trade Commission (FTC), the Federal Communication Commission (FCC) and the Consumer Financial Protection Bureau (CFPB) to aid in their enforcement activities. We may also use complaint information to assist calling parties in understanding how individuals who are called view their calling practices, and to better understand complaint and call block trends.

Another feature displays enhanced information on your device about who is calling you and why, First Orion provides several services for carriers and callers to use. Our caller name service displays a name in the caller ID instead of just a number or a city and state. Our enhanced caller ID allows the calling party (rather than the carrier) to put their name in the caller ID, and our specially enhanced caller ID service allows the calling party to also display their logo and information about why they are calling. These services use your phone number and other specifications about your device so we know to what device we should deliver enhanced information about the caller and how to properly display the message in a compatible format.

Finally, Conditional Call Forwarding allows users to conditionally forward their calls to the First Orion cloud when the user is either busy, the phone is off, the user has no service, or the user declines the call. Upon setting up Conditional Call Forwarding, users can access the Privacy Star App’s voicemail service where you can listen to the audio, share the voicemail, or delete the voicemail. The audio files are only accessible by the registered user.

When you download PrivacyStar App, you will need to agree to several questions so that it functions properly. The questions may vary depending on whether you are on an Android or iOS device since these operating systems function differently.

Allow First Orion to make and manage phone calls?

This allows the App to perform a number of call management activities such as blocking calls, identifying callers, filing complaints and receiving enhanced caller information about who is calling and why, as well as launching a call from your detail screen when you touch the phone icon.

Allow First Orion to access your contacts?

You will need to allow the App to access your contacts so we can assure that any incoming call from a number already in your contacts displays the name from your contacts on your device instead of the name the caller or carrier has provided and that we do not inadvertently label the caller as a likely scammer. For the App to provide enhanced information about who is calling and why, we dynamically create a contact for incoming calls that display the enhanced information. Once the enhanced call is delivered to your phone, the contact is automatically deleted. Other than phone number and name for these purposes, we do NOT use any information from your contacts for any other purpose.

All personal information relative to PrivacyStar App is stored in the U.S. and retained until it is no longer needed to deliver the functionality provided by PrivacyStar App.

First Orion does not sell any personal information collected in connection with PrivacyStar App. We do sell names for phone numbers you look up in the App that come from carriers and other public and private sources. To remove your name from this sale, go to privacy.firstorion.com.

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.

Children

We do not knowingly collect personal information from children under 13. If a child under 13 submits personal information to First Orion via our website and we learn that that personal information is about a child under 13, we will delete the information as soon as possible.

Your Rights as a Consumer

First Orion takes the privacy of personal information about individuals seriously. Under various federal and state laws, you have certain rights related to how your personal information is collected, used, disclosed and sold. First Orion extends these privacy rights to anyone who is a resident of the United States or Canada.

Verified Requests

Consumers have the right to submit requests to a business to exercise their right to know, their right to delete and in some cases their right to opt-out as described below. A business must verify that the consumer making the request is the consumer about whom the business has collected the personal information before it fulfills the request. Failure to satisfactorily verify the identity of the consumer will prevent the request from being fulfilled in entirety.

Right to Know

Consumers have the right to know what personal information is collected, used, disclosed, or sold by a business and how the information will be used. Upon receipt of a verified request, a business must disclose to the consumer the specific pieces of personal information it has collected, the types of sources from which the personal information is collected, the business purpose for which the personal information is collected, and the categories of third parties with whom the business shares the personal information.

Right to Delete

Consumers have the right to request that businesses delete their personal information in certain circumstances. If a consumer submits a verified request to delete, the business must delete all the consumer’s personal information from its records unless that personal information is necessary for the business to complete the transaction for which the information was collected, to protect against deceptive, fraudulent, or illegal activity, to enable solely internal uses that are aligned with the consumer’s relationship with the business or comply with a legal obligation.

Right to Opt-Out of the Sale of Personal Information

Consumers have the right to direct a business that sells personal information to stop selling that information to a third party. If a consumer submits a verified request to opt-out, the business must stop selling personal information about the consumer to third parties. If, at a later date, the consumer wants to allow the business to sell the personal information, the consumer can send an opt-in request to the business.

Businesses that sell personal information must provide a prominent link on their website (“Do Not Sell My Personal Data”) to a webpage to submit a request.

A business that collects personal information, but does not sell it, must so state in its privacy policy.

Additional Information about a Consumer’s Rights

Personal Information

The rights listed above only apply to a consumer’s personal information - meaning information that identifies, relates to, describes, or could reasonably be linked with a particular consumer (such as your name, your phone number, online identifiers, records of services purchased, purchasing history, browsing or search history, and inferences drawn from any other personal information). Personal information does not include publicly available information that is made available from government records.

Service Providers

If a service provider that processes personal information on behalf of a business receives a request from a consumer, the service provider will inform the consumer that the request should be submitted directly to the business it services and, when feasible, provide the consumer with contact information for that business.

Consumer requests handled by First Orion in the past year:

Year 2020 Total Requests to Exercise Consumer Rights Right to Know (Access Categories and/or Elements of Personal Information) Right to Delete Personal Information Right to Opt-Out of the Sale of Personal Information
Received 1150 328 0 822
Fulfilled 1106 318 0 788
Denied 44 10 0 34

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, please contact us at 1-877-640-4220, https://firstorion.com/contact-general/ or by sending paper mail to:

First Orion Corp.
Attention: Legal Team
520 Main Street, Suite 400
North Little Rock, AR 72114 USA
© 2021 First Orion Corp. All rights reserved.

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