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Privacy Shield Policy

First Performance Corporation Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how First Performance Corporation (“First Performance”) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (“EEA Personal Data”). This Policy supplements our Privacy Policy located at https://firstperformance.com/privacy-policy/, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.  Our Privacy Policy describes the categories of EEA Personal Data that we may receive in the US as well as the purposes for which we use that EEA Personal Data.

First Performance recognizes that the EEA has established strict protections regarding the handling of EEA Personal Data, including requirements to provide adequate protection for EEA Personal Data transferred outside of the EEA.  To provide adequate protection for certain EEA Personal Data about consumers, corporate customers, clients, suppliers, business partners, job applicants, and employees received in the US, First Performance has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (“Privacy Shield”). 

First Performance complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (including Iceland, Liechtenstein, and Norway) transferred to the United States pursuant to Privacy Shield.  First Performance has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, First Performance is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.  Upon request, we will provide you with access to the personal information that we hold about you.  You may also correct, amend, or delete the personal information we hold about you.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to info@firstperformance.com.  If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.  To request to limit the use and disclosure of your personal information, please submit a written request to info@firstperformance.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

First Performance’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, First Performance remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Privacy Shield Principles, unless First Performance proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, First Performance commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union individuals with Privacy Shield inquiries or complaints should first contact First Performance by email at  info@firstperformance.com or by using the information listed in the “How to Contact Us” section of the First Performance Privacy Policy.

First Performance has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction