PRIVACY POLICY

What information does First Direct Corp collect from you? In order to better provide you with numerous products and services, First Direct Corp collects two types of information about its visitors: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our site.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. Personal information is requested when you order a product or service, register for a Gift List, enter contests or sweepstakes, apply for credit, fill out surveys, and send us feedback. For example, this information might include your name, billing address, shipping address, telephone number, e-mail address, credit card or other payment information, and product details. With this information, First Direct Corp can fill your orders and better provide you with personalized services.

Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you shop on our site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. For example, this information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet, browse and shop.

Where do we collect information from you and how do we use it? Our primary goal in collecting personal information is to provide First Direct Corp’s visitors with a superior customized online experience. We use the customer contact information to fill orders, contact purchasers to inform them of their order status, to send promotional information, to enhance the operation of our site and administer our systems.

Demographic data also may be collected at our site from third party advertising servers or content servers, who provide us with the zip code and area code associated with a visitor’s server, along with pages viewed on our site. We review the actions of the First Direct Corp visitors on an aggregate basis to determine customers’ preferences. First Direct Corp also does research on our visitors’ demographics, interests, and pages viewed based on the information provided to us during ordering, a promotion, from our server log files, from contests, drawings or surveys. We will use this data to tailor the visitor’s experience at our site, to improve our marketing and promotional efforts, to statistically analyze site use, to improve our product offerings, and to customize our site’s content, layout, and services.

We gather information in the following ways:

Shopping: We collect IP addresses for the purposes of system administration, to gather broad demographic information, to enable ads to be served on our site, to report Non-Personally Identifiable Information to our advertisers, and to monitor the level of activity on our site. We collect information from visitors to our site regarding the URLs they came from, domain types (e.g., .com or .org), their IP addresses, the date and time of their visit or order, the number of visits and orders, the number of visits per browsing session, the server type, the operating system and browser type used to come to the site, the country, state and telephone area code where their servers are located, the pages and page titles of our site that visitors viewed during their visit, whether the visitor’s computer is enabled for Java or cookies, browser language, applications and plug-ins, and any search terms entered on our site.

Ordering: When you order from us, we collect personally identifiable information from you. If you order one of our products or services, we will collect and maintain your name, e-mail address, billing address, shipping address, telephone number, product selections, credit card or other payment information, order number, referring URL, IP address, page you bought from and a password. We collect this, and other information, as disclosed in this Policy, in order to fill your order, to communicate with you about your order and to send you promotional materials. Before confirming your order, you will have the opportunity to review the product order form and make changes and additions to the information it contained and these changes will be automatically kept for future use.

Online Surveys and Polling: In order to improve our services to you, we ask some of our customers to voluntarily complete surveys, which may be collected by an independent third party. Individual survey answers are confidential, although Non-Personally Identifiable Information is collected and disclosed to third parties. If you do not wish to participate in a survey, simply decline to participate when asked.

Contests and Sweepstakes: When you enter a contest or other promotion, we may ask you for contact information such as your name, address and e-mail address in order to administer the contest, to send you promotional e-mails, notify winners and make the winners list publicly available pursuant to certain states laws. Your consent to such promotional use and disclosure of this information is a condition of your participation. As a condition of receiving any prize, you will be required to submit an Affidavit of Eligibility for us to ensure that you are eligible to receive the prize according to the Contest Rules.

Newsletters & Promotional E-mails: We offer free newsletters and promotional e-mails as a service to our customers. We will send you newsletters and e-mails periodically listing current specials and deals. To stop receiving our newsletter, send an e-mail to us at info@1stdirect.com.

Contact Information and Third Party Data: If you contact First Direct Corp or our customer service representatives by telephone, e-mail or letter, we may keep a record of your correspondence or comments. If you report a problem with our site, we may collect such information in a file specific to you. If you contact us through our feedback area or by calling one of our customer service representatives, we may ask for your name, e-mail address and order information in order to send you a reply. If other users or third parties send us correspondence about your activities or purchases on our site, we may keep the information in a file specific to you.

Customer Service: We provide customer service. In order to help you most effectively, we may keep a record of your correspondence or comments. If you report a problem with our site, we may collect such information in a file specific to you.

We also track customers’ traffic patterns throughout their online session, including which pages, information and advertisements a customer views while using the site and what items they place in their basket or purchase. We use your IP address to diagnose problems with our servers, software, to administer our site and to gather demographic information.

We may share aggregated statistics about pages viewed on our site, sales and other shopping information with third parties.

Cookies

Cookies: We use cookies and allow others to use cookies in the operation of our site.

With whom do we share your information? Fulfillment: The information collected by First Direct Corp is used for processing orders, keeping you informed about your order status, for statistical purposes, for improving our site and its performance, to serve ads, and to notify you of products or special offers that may be of interest to you. We will disclose your Personally Identifiable Information to third parties to charge your credit card, fill your order, deliver your order, provide customer service, provide you with credit and deliver promotional e-mails to you from First Direct Corp. For example, we must release your credit card information to the card-issuing bank to confirm payment; and release your address and telephone information to the delivery service to deliver products that you ordered.

Other Parties: We do not sell, trade, or rent your Personally Identifiable Information to others without your consent. We may provide Non-Personally Identifiable Information about our customers’ sales, traffic patterns, and related site information to third parties, but these statistics do not include any Personally Identifiable Information. We may release account information when we believe that such release is reasonably necessary to enforce or apply our Terms and Conditions or to protect the rights, property, and safety of First Direct Corp, our users, or others. If customers do not pay us for products ordered, we may submit their account information to a third party collection agency.

Data Analysis Agents: The information collected by or for First Direct Corp may be provided to an outside company for the purpose of analysis. That analysis is to help us to improve our site and product selection, and to notify you of special offers that may be of interest to you. That data analysis agent may not share any Personally Identifiable Information with others, or use it for any other purpose than to help First Direct Corp.

Compliance with Service of Process or Law Enforcement: Occasionally First Direct Corp may be asked by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation, without prior notice to you. First Direct Corp fully cooperates with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

How can you update or correct your Personally Identifiable Information? We believe you should have the ability to access and edit the personal information that you have provided to us. During the online ordering process you can review, change, or delete the information that you have submitted. You may change any of your personal information in your account online at any time. We encourage you to promptly update your information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past purchases, you cannot delete information associated with past purchases. Also, as a security measure we “back up” the data stored on our systems, and such prior information cannot be completely removed from our databases. As a result, you should not expect that all of your Personally Identifiable Information will be completely removed from our backed-up databases.

What are your choices regarding collection, use, and distribution of your information? Email: We may from time to time send you e-mail or other communications regarding current promotions, specials and new additions to the First Direct Corp site. You may “opt-out” or unsubscribe from our newsletters by following the unsubscribe instructions in any e-mail you receive from us, or by sending an e-mail to info@1stdirect.com. After doing so, First Direct Corp users will not receive future communications or mailings unless they open a new account or enter a contest.

Ad-servers and other Content Servers: You may also set your browser so that it will not accept “cookies” to prevent assignment from the ad server of a unique identifier; however, you will be unable to shop on our site if you do so.

What security precautions are in place to protect against the loss, misuse, or alteration of your information? In order to most efficiently serve you, credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.

When you access your account information, the information is kept on a secure server. All of the customer data we collect is protected against unauthorized access by physical security means.

A special note about children’s privacy You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors under 18 years of age. If you are the parent or guardian of a minor under 18 years of age and believe that they have disclosed personally identifiable information to us, please contact us at support@1stdirect.com so that we may delete the minor’s information.

You should carefully review privacy policies of any third party sites accessible from First Direct Corp. Other sites accessible through our web site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. First Direct Corp is not responsible for the policies or practices of third parties. Please be aware that this site may contain links to other sites on the Internet that are owned and operated by third parties. The information practices of those web sites linked to First Direct Corp are not covered by this Privacy Policy. These other sites may send their own cookies to users, collect data, or solicit personal information. Additionally, other companies that place advertising on our site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

On behalf of various sponsors, First Direct Corp provides sponsored links to third-party web sites. If you click on a sponsored link or banner ad, a “window” or “frame” containing a third-party’s web site may appear in the foreground with the First Direct Corp web site in the background. Unless you are on buy.com’s web site, any time that you have moved to a window, you should assume that your personal information is being collected, used and disclosed in accordance with the windowed site’s privacy policy (if any). If you are unsure as to whose privacy policy applies, please contact us by eMail at support@1stdirect.com , or by sending a letter to the address below.

Contacting First Direct Corp about privacy questions or concerns If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at (800) 935-4386.

You may also contact us by e-mail at support@1stdirect.com

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