Privacy Policy

FirstLoading Limited and its affiliates (“we,” “us,” “FirstLoading,” or the “Company”) respects your (“you” or “your”) concerns about privacy. This Privacy Policy (“Privacy Policy”) applies to personal information we obtain about you, including on FirstLoading’s ELinehub (“ELinehub”), accessed by Application (“App”), FirstLoading’s Website and through the software or services that we offer through the Website (the “Services”). We describe the types of personal information we obtain, how we may use the information and the purposes for which we may use it, with whom we may share it and the choices available to you below. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

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Please note that this Privacy Policy is incorporated by reference into End User License Agreement (“EULA”). The Terms of ELinehub EULA can be found here: [https://www.elinehub.com/EULA].

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Collection of Information

We may obtain personal information about you in different ways: (1) information you provide to us; (2) information we collect and receive from others; and (3) information we collect when you use the App, Website and/or the Services, i.e., using “cookies” and other technologies to assess how you use the Services.

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Information You Provide to Us

When you register with, log on or visit our App or Website, when you participate in activities on our App or Website, and when you contact us by phone, email, via our App or Website or any other way, you may provide personal information, such as your first and last name, photo identification, business email address and phone number, the first and last name of the business owner, information about your company, postal address, business license, liability insurance, and proof of Original Equipment Manager (OEM) subscription or programming tool.  You may also provide us with other information, such as your gender, age, personal interests and marketing and communications data, including your preferences for receiving mailings from us.  If you purchase products or services from us, we may collect information about the type of services or products ordered or purchased, and the date of the order or purchase. 

 

When you choose to interact with us or log in via social media platforms or other online platforms (such as Facebook and Google) we may automatically collect information such as your profile picture, contact list, education, work history, events, relationship status, likes, gender, location, URL, biography, or any additional image or information.

 

Our App and Website may allow other users and the public to view your profile page, as well as other features through which you may provide us with user content and submissions. Any comments or information you submit or share on public areas of the App or Website, such as a description of your business, can be read, collected, or used by other users and the public. We are not responsible for the information you choose to submit or share on the public areas of our App or Website, such as your public profile.

 

Information We Collect or Receive from Others 

We may update and supplement personal information that we have collected directly from you with other information that we obtain from third parties. We also may collect information about you from public records and third-party sources of information, including information that you have made public on websites associated with you or on social media platforms and from other third parties, such as third-party analytics or advertising providers. In addition, we may obtain personal information about individuals who are not yet users of our App or Website or our Services. When we associate information that we obtain from third parties with personal information that we have collected under the terms of this Privacy Policy, we will treat the acquired information in the same way we treat that information according to the terms of this Privacy Policy.  

 

Information We Collect Automatically

When you use or interact with the App, Website and/or Services, or view our emails, we may, ourselves or through a third-party vendor, automatically collect, store and use information about your visits to our App or Website, such as:

 

• technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location;

• information about your visits and use of the App, Website and/or the Services, including the full Uniform Resource Locators (URL), clickstream to, through and from our App and/or Website, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), and website navigation and search terms used;

• mobile network information, such as the unique device identifier assigned to your mobile device, mobile carrier, operating system, and other device attributes, when you access the App and/or Website via a browser on that device;

• information collected by cookies, web beacons (including pixels and tags) and other technologies (collectively “Cookies”) (for more information on Cookies, please see the section on Cookies below).

 

We use this data to (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with the App, Website and/or the Services; (3) personalize your visit to the App and/or Website and when you use the Services; (4) measure the usability of the App, Website and/or the Services and the effectiveness of our communications; and (5) otherwise manage and enhance the App, Website and/or the Services.

 

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COOKIES AND OTHER TECHNOLOGIES

 

Cookies may be set and accessed on your computer or mobile device. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to servers and may be used to transmit information collected through Cookies back to a web server. We refer to all of these technologies as “Cookies” for purposes of this notice.

 

We, or our service providers, use Cookies to customize and improve users’ visits to our App and/or Website, to deliver content tailored to users’ interests and the manner in which they browse our App and/or Website, and to manage our App and/or Website and other aspects of our business.  Below is more detail about the types of Cookies that we use:

 

• Required Cookies are required for the functioning of the App and/or Website and may be used to implement security features or embed video or sound files. Disabling these Cookies will encumber the App and/or Website’s performance and may make certain Services and features unavailable.

 

• Functional Cookies allow the App and/or Website to help maintain your session and remember choices you have made in order to provide functionality for your benefit. For example, functional “session” Cookies allow the App and/or Website to remember settings specific to you, such as whether you have previously visited the App and/or Website and clicked to acknowledge our Cookie banner, which ultimately improves your web experience. Functional Cookies also include persistent Cookies which are used to remember your preferences when you subsequently visit our App and/or Website.

 

• Analytics Cookies are used to gather statistics about the use of the App and/or Website in order to improve the performance and design of the App and/or Website and the Services. For these purposes, analytics Cookies collect information about your device type, operating system type, browser type, domain, other system settings, IP-address, referring URLs, information on actions taken on the App and/or Website and the dates and times of your visits, as well as the country and time zone in which your device is located. These Cookies are provided by third-party analytics providers, including [Google Analytics], and the information obtained through these Cookies will be disclosed to or collected directly by these third-party service providers.

 

• Advertising Cookies are used to control and manage advertisements and our marketing initiatives. These Cookies may collect information about how you interacted with our App and/or Website, whether you interacted with an advertisement, and whether you visited another website. Such Cookies help us to offer you content that may be of interest to you and provide targeted information that seems more relevant to your interests. They also help us to measure the effectiveness of our advertisements and to control and limit the frequency of advertisements and other information being displayed to you. Some of these Cookies are persistent Cookies, which remain on your computer or other Internet-connected device for a certain period of time after you end your browsing session, unless you delete them. These Cookies are provided by third parties such as [LinkedIn, YouTube and Google Ads].

 

You may restrict or disable the use of Cookies through your web browser, although doing so may prevent you from using the full features of the App and/or Website. Each type of web browser offers ways to restrict and delete Cookies. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device or browsers. [You may also decline consent to cookies usage from the cookie banner that appears at the bottom of our Website when you first arrive on the Website.]

 

Our App and/or Website may include social media features, such as Facebook or Twitter buttons. These features may collect your IP address, which page you are visiting while using the App and/or Website, and any Facebook cookies on your device (including your Facebook ID). These features may set Cookies to enable the feature to function properly. Please note that the social media services may collect this information, even if you are not logged in to the relevant social media account when you are using the App and/or Website. Your interactions with these features are governed by the privacy policy of the company providing it.

 

 

How We Use the Information We Obtain

 

We use the information we collect about you in order to improve our App, Website and/or our Services and provide you with features that interest and work well for you. In particular, we use the information to:

• Provide our App, Website and/or Services, including but not limited to the fulfillment or facilitation of orders;

• Manage and improve the content of our App, Website and/or Services and enhance your experience;

• Send correspondence about the App, Website and/or Services, including by sending you information regarding changes to our policies, terms and conditions, as well as other information, including newsletters, announcements, information about FirstLoading, special offers or promotional materials on our behalf or on behalf of third parties;

• Personalize your use and interaction with our App, Website, and/or Services;

• Analyze trends and statistics;

• Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our App, Website and/or our Services; managing and evaluating the effectiveness of our communications; and performing other internal functions);

• Enforce this Privacy Policy, the EULA, and any other terms that you have agreed to;

• Maintain and enhance the safety and security of our App, Website and/or Services and prevent misuse;

• Comply with and enforce applicable legal requirements, relevant industry standards and policies; and

• Maintain and service accounts, provide customer service, verify customer information, process and complete payments and transactions on the App, Website and/or via our Services;

• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and

• Otherwise manage and enhance our App, Website and/or Services.

 

Disclosure of Information We Obtain

 

We do not share personal information about you except as described in this Privacy Policy. We may share information collected about you in the following ways:

 

• With third parties providing services on our behalf, including service providers, sellers, and partners to perform functions, process your transactions and your data and to help operate the App, Website and/or the Services, including hosting and storage providers, email service providers, and payment processors. In addition to using your information to help us provide the App, Website and/or the Services, service providers may use your personal information internally to improve their own services and may share it in connection with a sale, divestiture, or transfer of business assets; to protect their rights; or to comply with the law. In addition, our providers may share your personal information with their own third-party service providers.

 

• With analytics service providers and advertisers to collect information about how you use our App and/or Website over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. Some companies may use information collected on our App, Website and/or our Services to deliver advertisements on behalf of us or other companies, targeted to your interests and preferences, on other websites or apps you may visit or on your social media feed and to gauge their effectiveness.

 

• With third parties for legal reasons, namely if we reasonably believe that disclosing the information is needed to (a) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (b) investigate, remedy, or enforce potential violations of our EULA or this Privacy Policy; (c) protect the rights, property, and safety of us, our users, or others; (d) detect and resolve any fraud or security concerns; or (e) otherwise with your consent.

 

• With third parties as part of an acquisition or liquidation, namely if we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings.

 

We may also share with third parties, such as advertisers, aggregated or de-identified information and we do not limit our third-party providers from using, selling, licensing, distributing, or disclosing de-identified data.

 

We do not sell personal information, and we will not sell personal information except as described in this Privacy Policy or if we provide you with notice and a right to opt-out of such sale.

 

Your Rights with Respect to the Personal Information We Have Collected

 

You may have the right to:

 

• Know what personal information we have about you and request a copy of the same;

• Update or change any incorrect personal information;

• Ask us to stop collecting, processing and using your personal information in certain ways;

• Request the portability of your personal information; and

• Raise concerns regarding automated decision-making processes.

 

If you wish to do any of the above, please send an email request to [support@elinehub.com]. We may refuse to comply with a request if the request is manifestly unfounded, excessive, or repetitive in nature or if the request is for erasure of personal information, i.e., where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims or for record-keeping and research purposes. We also may be entitled to refuse your request, wholly or partly, where exceptions under the applicable law apply.

 

Protection of Personal Information

 

We are committed to using our best efforts to maintain the security of your personal information. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of information, we adhere to industry standard practices and procedures to help safeguard and secure the information we collect.  Although we use our best efforts to protect the security of your personal information and our system, due to the inherent open nature of the Internet, we cannot assure you that personally identifiable information that we collect will never be disclosed in a manner inconsistent with this Privacy Policy. Inadvertent disclosures may occur. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to us, and you do so at your own risk.

 

CHILDREN

 

FIRSTLOADING is committed to children's privacy. FIRSTLOADING does not knowingly permit any person less than 18 years of age to register on the APP AND/or the WEBSITE or to access and use the services. if you are a parent or guardian and discover that your child under the age of 18 has a registered account with the app AND/or webSite without your consent, please alert FirstLoading at [support@elinehub.com] to either provide consent, request that we change your child’s account settings, or request that FirstLoading remove the child’s Personal Information. Please provide the child’s name, address, and e-mail address. We strongly encourage parents to monitor their children's use of apps and the Web.

 

Information From Users Outside of the USA and Consent to Transfer Jurisdiction

 

The App and Website and its servers are operated in the United States. If you are located outside of the United States, please be aware that any personal information you provide to us will be transferred to the United States. By using the App, Website and/or the Services, and by providing us with personal information, you hereby consent to this transfer and our use of the personal information in accordance with this Privacy Policy. By using the App, Website and/or our Services you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and to those third parties with whom we share it as described in this Privacy Policy.

 

PAYMENT PROCESSING

 

All media containing credit card information is stored at third-party datacenters with physical access controls in place that meet PCI (payment card industry) standards and is subject to those third-party policies regarding data privacy and security. On-line credit card payments are made through Stripe, Inc. (“Stripe”).  Stripe’s privacy policy can be found here: https://stripe.com/privacy.

 

LINKS TO OTHER WEBSITES and SERVICES

 

For your convenience and information, our App and/or Website may contain links to other online services, and may also include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently of FirstLoading. The privacy practices of these third parties, including details on the information they may collect about you, is subject to their own privacy policies or notices, which we strongly suggest you review. We urge you to review the privacy policies of such entities before providing any personal information. To the extent permitted by applicable law, we are not responsible for the privacy policies of these third parties, including our vendors, or the privacy practices of other service providers. 

 

The providers of third-party apps, tools, and plug-ins on our App, Website and/or our Services also may use automated means to collect information regarding your interactions with these features. These third parties may collect information about your online activities over time and across third-party websites. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, we are not responsible for these providers’ information practices.

 

MODIFICATIONS

 

Please note that we may modify this Privacy Policy at any time, at our sole discretion, by posting the modified policy on our Website. The modifications will be effective upon posting, unless some other date is specified. You should review this Privacy Policy periodically so that you are aware of any modifications.  Your use of our App and/or Website constitutes your full acceptance of the Privacy Policy in its then-current form.

 

CALIFORNIA RESIDENTS

 

As a California resident, you may have certain rights to delete any personal information about you which the business has collected from you, to request that a business that collects personal information about you disclose to you certain information or to opt-out of the sharing of personal information with third parties for marketing purposes. You may submit a request to us through e-mail at [support@elinehub.com].

 

We may not be able to honor each request that we receive and may not be required to do so under applicable laws, but if we are unable to do so, we will respond to let you know our reasons. We will not discriminate against you if you choose to exercise any of your rights as described in this section.

 

EU DATA SUBJECT RIGHTS

 

Under the General Data Protection Regulation ("GDPR"), if you are an EU resident and we are processing your personal information, you have the following rights:

 

• Right of access: You have the right to request a copy of the information that we hold about you.

• Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.

• Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.

• Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.

• Right to withdraw consent: If you have provided consent for the processing of your information you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

• Right of portability: In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.

• Right to object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).

• Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling (to the extent applicable).

• Right to lodge a complaint: You have the right to lodge a complaint to your country's data protection authority if you believe that we have not complied with the requirements of the GDPR with regard to your personal information.

 

QUESTIONS OR COMMENTS

 

If you have any questions, comments or concerns regarding this Privacy Policy and/or the practices described herein, please email us at [support@elinehub.com].