Privacy Policy

Effective as of: September 1, 2023

The following Privacy Policy governs your use of the FirstWho.co website and all content, services and products available at or through the website ("Platform") by the user ("user" "you" "your"). The Platform is owned and operated by Mission Focused Tech, LLC d/b/a FirstWho ("FirstWho" "we" "us" "our"). This Privacy Policy may be updated from time to time for any reason. FirstWho provides notice via email to users whenever updates to this policy are made. It is the responsibility of all users of FirstWho.co, however, to revisit this page to check for changes. Please read this Privacy Policy carefully before accessing or using the Platform. By accessing or using any part of the Platform, you agree to become bound by the terms and conditions of this Agreement. If you do not agree to this Privacy Policy, then you may not access the Platform or use any services.

By using FirstWho.co you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing” means using cookies on a computer or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which activities will take place in the United States. If you reside outside the United States (“U.S.”), your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By visiting our Platform and providing information to us, you consent to such transfer to, and processing in, the U.S.

The Chief Technology Officer shall review and approve any material changes to this policy as necessary. Any questions, concerns, or comments regarding this Privacy Policy or our use of your personally identifiable information, please contact us at support@firstwho.co.

FirstWho may collect information about you, when you interact with the Platform, including, your name, email address, time zone, and other data as specifically described herein.

You may provide us with this personal information when you:

1. Register for a FirstWho account;

2. Sign up for email communications;

3. Submit a job posting, job application or inquiry;

4. Submit information through any contact form on the Site;

5. Request customer support or send FirstWho any other communication; and/or

6. Make use of FirstWho’s social media widget features.

Depending on which services you choose to use, FirstWho may require additional information, such as a your chosen pronouns, business name, a telephone number, a physical address, state/regional identification, billing information, links to various online profiles, professional history/Resume/CV, cover letter, work authorization status, photos, education history, including degrees, dates and locations of attendance, grades, extracurricular accomplishments and educational institute affiliations, biographies, demographic information (gender/ethnicity), military service information, and/or salary information. FirstWho may contact users to confidentially request more information and/or to ensure compliance with FirstWho’s rules.

If you send information through the application, our contact forms, customer service, and/or messaging functions on the Platform. You will be asked to provide your name and email. In communicating with us, you will also have an opportunity to share additional information with FirstWho, in your sole discretion, which may include personal information. This information is seen only by FirstWho and is not publicly available. Use discretion when sharing information through chat functions, emails, and contact forms.

You have the right to obtain our confirmation of whether we maintain personal information relating to you. You may access, review, update, erase, or block any information in your account dashboard on the Platform, as permitted by applicable law and FirstWho policies. Deletion or removal of certain information may prohibit you from utilizing the Platform or FirstWho services.

FirstWho uses the information you provide to:

1. Provide the features and functionality of the Platform and to improve FirstWho’s products and services;

2. For FirstWho’s internal business purposes, including, but not limited to data analysis, and audits;

3. Provide paid-for services to Customers;

4. Contact you concerning your account activity;

5. Fulfill your requests for FirstWho’s products and services;

6. Communicate with you concerning FirstWho’s products and services; and/or

7. Send you information about FirstWho’s products and services.

FirstWho uses non-personally identifiable information to monitor the use and performance of the Platform so that FirstWho can learn more about how people use the Platform which helps us improve FirstWho’s services and significantly enhance your experience on the FirstWho Platform.

In addition to providing you services, we may use your contact information to market to you, and provide you with information about our products and services, including but not limited to services on FirstWho.co. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications.

When you visit the Platform, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”) on the Platform. This Log Data may include information such as your IP address and aggregated anonymous information concerning your activity on the Platform. We use Log Data to monitor the use of the Platform and of our Service, and for the Platform’s technical administration. We do not associate your IP address with any other personally identifiable information to identify you personally, except as required to enforce this Privacy Policy and the Terms of Use for the Platform, or as necessary to protect the rights, property, or safety of FirstWho, its employees, customers, or other users.

Personal Information Accessible by Customer. By becoming a Candidate, and engaging in the recruitment services facilitated on the Platform, you authorize your personal information in the form of your name, professional information, resume, application answers, voluntary self identification information (gender, ethnicity, race, disability, and veteran status—to the extent you choose to provide such information) and contact information (in the form of your email address, phone number and physical address) to be made available to the Customer.

Personal Information Accessible by Third Parties. Your information may be disclosed to our third-party vendors or affiliates, otherwise FirstWho will not sell or disclose your name, email address or other personal information to third parties without your explicit consent, except as may be specified in this policy from time to time. FirstWho may prepare and share aggregate non-personally identifying information about our users with third parties, such as advertisers or partners, for research, academic, marketing, commercial, and/or promotional purposes.  For example, FirstWho may share demographic data that describes the percentage of our users who work in a particular industry or field. FirstWho or our third-party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other user to be personally identified.

FirstWho uses essential cookies on the Platform to improve the quality of the Platform and services to you. A cookie is a string of information that a website stores on a user’s computer and the user’s browser provides to the website each time the user returns. FirstWho uses cookies to help FirstWho identify and authenticate users of the Platform. Cookies do not collect or store personally identifiable information. Rather, the cookie stores a token which uniquely identifies a particular user at a particular time. That token is then linked to the user information in FirstWho’s secured databases. FirstWho visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using FirstWho’s Platform, with the drawback that certain features of FirstWho’s Platform may not be available to you or may not function properly without the aid of cookies.

Do Not Track:

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. FirstWho does not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

Your California Privacy Rights:

In addition to other rights provided for herein, if you live in California and have an established business relationship with us, you can request a list of the personal information we have shared with third parties for their marketing purposes. We will also give you a list of the third parties that have received your information. You can make a request one time each year. To exercise your rights, you can email us or write to us at the address below. Mention in your letter that you are making a "California Shine the Light" inquiry. We will respond within 30 days.

You may also request that we provide you with an accounting of your personal information held by FirstWho. You may also request that FirstWho delete your personal information.You may submit that request via email at support@firstwho.co, or mail at 39 Church St, Malden MA 02148. Upon verification of your identity and within 45 days, we will provide you with a paper copy of your personal information via the United States Postal Service. FirstWho will not discriminate against any end user for exercising their rights under the California Consumer Privacy Act.

We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, database storage and management, and Platform feature sets. We will share data and/or personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data, by (i) agreeing to provide adequate protections for personally identifiable information that are no less protective than those set out in this Privacy Policy; and (ii) notifying FirstWho in the event that such third party is no longer able to provide sufficient protections.

The Service Providers engaged by FirstWho, and links to their individual privacy policies, are listed at our third-parties page and may be updated from time to time.

If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

For residents of the EU, Switzerland, the UK, or other countries with data privacy laws substantially similar to GDPR, FirstWho remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

FirstWho may also release your information when FirstWho, in FirstWho’s sole discretion believes that such release is necessary or appropriate to:

1. comply with law;

2. comply with subpoenas, warrants, court orders, government investigations, or other legal process;

3. enforce or apply the terms of this policy;

4. investigate or respond to allegations of fraud, intellectual property infringement, or other unlawful activity;

5. investigate fraud or similar claims;

6. protect the rights, property or safety of FirstWho, FirstWho’s users, or others;

7. to protect FirstWho’s operations; or

8. to permit FirstWho to pursue available remedies or limit the damages that FirstWho may sustain.

FirstWho also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. In cases of onward transfer to third parties of data of EU or UK individuals received pursuant to GDPR or Swiss individuals received pursuant to Swiss global data privacy laws, FirstWho is potentially liable.

FirstWho may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. You will be provided with notice in the event of such sale or transfer and have the opportunity to opt out of any such transfer.

FirstWho believes in the privacy of our website users. We safeguard the confidentiality of your personally identifiable information. We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. We will make any legally-required disclosures of any breach of security, confidentiality, or integrity of your unencrypted electronically-stored personal data to you via email or conspicuous posting on this Platform in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of government authorities, including to meet national security or law enforcement requirements or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

The Platform may contain links or references to other websites. FirstWho cannot control and cannot be held responsible for the content that appears on those sites, and is not an endorsement, authorization, or representation of our affiliation with that third party. Furthermore, FirstWho is not responsible for the privacy policies of any third-party site or for how they treat information about their users. These third-party sites may place their own cookies on your computer, collect data, or solicit personal information. You may be consenting to those websites through use of ours. We encourage you to read the privacy policies or statements and terms of service for each of the other websites you visit.

The security of your personal information is important to us. FirstWho uses the TLS Protocol to secure all communications on the Platform, and encrypts all data at rest. FirstWho employs industry standard precautions designed to protect your information from unauthorized access. FirstWho will make any legally-required disclosures concerning any breach of the security, confidentiality, or integrity of transmitted personal data on the Platform via email to the affected users or conspicuous posting on this Platform in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Remember that no method of transmission over the internet or method of electronic storage is 100% secure. Firstwho cannot promise, and you should not expect, that your personal information or private communications will always remain private. FirstWho cannot guarantee complete security.

FirstWho currently stores user information via secure cloud based web hosting services, provided by Amazon Web Hosting, and the information is stored on servers located within the United States.

FirstWho retains personal information when we have an ongoing legitimate business, legal, or compliance need to do so. Our retention periods will vary depending on the type of personal information. The general factors we consider in determining whether to retain personal information are:

• Whether we have a legal or contractual need to retain the information

• Whether the information is necessary to provide our services or for functionality of Site features

• Whether our account holding users have the ability to access and delete the information from their accounts

When FirstWho has no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, when personal information has been stored in backup archives), then FirstWho will securely store such personal information until deletion of such information is possible.

The Platform is not directed to persons under 18. 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 at support@firstwho.co. We will take actions to promptly remove such data. We do not knowingly collect personally identifiable information from children under 18. If we become aware that a child under 18 has provided us with personally identifiable Information, we will delete such information from our files.

Unless otherwise required by GDPR, disputes concerning this policy shall be addressed as provided in the FirstWho Terms of Use. If you have any inquiries or complaints regarding this privacy policy should first contact FirstWho at:

FirstWho, Inc. Attn: Privacy Policy Inquiries, support@firstwho.co