Privacy Policy

Effective Date: 10/22/2023

This Privacy Policy ("policy") applies to the website: www.firstpagedigitaltrack.com (the "Website", "Site") owned and operated by First Page Digital Pte Ltd (collectively "First Page Digital", "we", "us", "our"). This Privacy Policy describes how First Page Digital collects, uses, shares and secures the personal information you provide, as well as any personal information transferred to us for processing on behalf of our clients ("Client Data"). It also describes your choices regarding use, access and correction of your personal information.

By visiting our website, visiting a First Page Digital client's website that provides notice of its use of our products and/or this policy, or registering for our service, you acknowledge that you accept and consent to the practices outlined in this Privacy Policy.

Information We Collect

Visitors to First Page Digital's Website

If you are a visitor to our Website or a First Page Digital client ("Client") who registers or signs in to our website, we may collect the following information about you which may include information that can itself be used to identify and/or contact you ("Personally Identifiable Information"):

We also automatically collect certain information via technology:

Visitors to First Page Digital's Clients' Websites

Our Clients may use customized and proprietary code, software and/or services ("Service(s)") to obtain information regarding the activities that users engage in while visiting their web pages ("Client Data"). When a user visits a website that uses First Page Digital's Services, code contained on the website contacts First Page Digital's servers and enables First Page Digital to collect Client Data. Some Clients may also use their own code to obtain Client Data and then send such information to First Page Digital's servers. Client Data may include Personally Identifiable Information, including, but not limited to, the types of information listed above.

Client Data is stored on First Page Digital's web servers and databases (including those hosted on third party servers on behalf of First Page Digital) for use in performing analysis, producing reports, and providing notifications or other services for the applicable First Page Digital Client. In addition, First Page Digital itself uses First Page Digital's services in order to obtain insights into visitors' activities on its own Website.

First Page Digital's collection and analysis of Client Data helps our Clients to understand and improve their websites, to understand and improve their marketing campaigns, and to identify, investigate and deter fraudulent, illegal or unauthorized activity. First Page Digital's Clients determine the types of Client Data that are sent to First Page Digital's servers for analysis. This data may include or be linked to Personally Identifiable Information depending on how the Client uses First Page Digital's Services on its website(s).

First Page Digital's Clients are contractually prohibited from sending personally sensitive Client Data (e.g. personal health information, political opinions, religious or philosophical beliefs) to First Page Digital and First Page Digital does not knowingly receive such data.

In addition, First Page Digital may collect certain information about a Client's visitor automatically, including: the Operating System (OS) running on their device, Internet Protocol (IP) address, geo location based on their IP address, Internet service provider (ISP), access times, browser type and version, screen size, language, and the website they visited before Client's website. We also collect information about what files viewed on Client's website (HTML pages, graphics, etc), what links they've clicked on and what page elements they've interacted with. Such information may be collected and shared with the First Page Digital Client even though not specifically requested by the Client.

How We Use the Information We Collect

Visitors to First Page Digital's Website

We use the information collected through our site to:

Visitors to First Page Digital's Client's Websites

Except as described in the "Who We Share Information With" section below, First Page Digital never sells or shares any Client Data with individuals or companies other than the specific Client whose website transmitted the Client Data to First Page Digital. Clients may direct us to automatically share their Client Data with their sub-processors, such as the Client's email marketing service provider.

First Page Digital does not link any Personally Identifiable Data across multiple, different websites that are operated by different Clients, nor does it use any Client Data for purposes of behavioral advertising. However, First Page Digital may analyze Client Data in the aggregate for purposes of internal research and/or to determine overall trends or metrics concerning how users are engaging with websites, and may report such general trends publicly, without disclosing any Client Data.

First Page Digital contractually requires its Clients to abide by all applicable laws, rules and regulations relating to privacy and data collection ("Applicable Laws"). First Page Digital also contractually requires its Clients to obtain any necessary consents from visitors to its website(s) for the Client's use of First Page Digital's services, comply with all Applicable Laws with respect to the transfer of Personally Identifiable Information of EU or Swiss subjects through the Service, and to post an online privacy policy that provides each visitor with clear notice of its practices regarding data collection, use, and disclosure (including the Client's use of First Page Digital's Services), along with a link to the First Page Digital Privacy Policy and to the First Page Digital Service Opt-Out (discussed below).

First Page Digital cannot be held responsible for any Client's failure to make these disclosures on its website or for any Client's use or collection of Client Data that is not permitted under this Privacy Policy or otherwise.

Who We Share Information With

1. With Third Parties:

We may share your information with third-party business partners for the purpose of enhancing our products and services. We may share the names and logos of current clients with prospective clients, or on our website. If you do not want us to share your personal information with these companies, contact us at the contact information below.

2. With Service Providers:

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. These services may include:

3. With Public Authorities or Law Enforcement:

In certain situations, First Page Digital may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to our Terms of Service, to protect your safety or the safety of others, to investigate fraud, or respond to a government request.

Security

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We restrict access to personal information to First Page Digital employees, contractors and agents who need to know that information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

If you have any questions about the security of your personal information, you can contact us at the contact information below. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Access

Upon request First Page Digital will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

With respect to our analytics platform and other services First Page Digital provides to clients, First Page Digital acknowledges that you have the right to access your personal information. First Page Digital has no direct relationship with the individuals whose personal information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the First Page Digital's client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Choice

First Page Digital offers choices and means to limit the use and disclosure of your personal data:

Certain state laws require us to indicate whether we honor "Do Not Track" settings in your browser. First Page Digital adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

Our Policy Toward Children

Our Site and Services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13 or from websites that are targeted to children under 13. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us as provided below. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our servers.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account), through an in-app message, or by means of a prominent notice on this website. We encourage you to periodically review this page for the latest information on our privacy practices.

Privacy Questions/Feedback

First Page Digital commits to resolve any complaints about your privacy and our collection, use, or disclosure of your personal information. If you have any inquiries or complaints regarding this Policy, you should first contact First Page Digital at:

First Page Digital Pte Ltd
120 Robinson Road, #05-01
Singapore 068913
P: +65 6270 2193
E: [email protected]

First Page Digital has further committed to refer unresolved privacy related complaints to an alternative dispute resolution provider located in Singapore. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may visit Singapore Mediation Centre (SMC) for more information or to file a complaint. To facilitate fast and convenient resolution of complaints, you agree to participate in online dispute resolution through SMC Online Mediation.