Last Updated: September 9, 2020
This Policy is part of the Terms & Conditions Agreement. Please read it carefully as it describes what information We collect, why We collect it, and what We do with it. By using the First Launch Offerings, You acknowledge that First Launch will handle Your Information and other personal information as described in this Policy. Your use and/or access of any First Launch Offerings, and any dispute between You and Us, is subject to the Agreement, including this Privacy Policy, which may be amended by First Launch from time-to-time.
We collect information in two ways: directly from You and automatically through Your usage of the First Launch Offerings.
We collect Your Information directly from You, when You register with Us or when You upload or otherwise provide Us with information. This includes Your contact information (such as name, address and email); login information (such as your password and username); and information about Your customers (such as name, address, email and other details as permitted by the First Launch Offerings. Bank/credit card information is not collected or stored by First Launch and First Launch does not have access to the bank or credit card information of any person. This means that, for the purposes of First Launch, the First Launch Offerings and the Agreement (including this Privacy Policy), Your Information does not include any bank or credit card information; We encourage You to review the privacy policy of the Payment Processor to learn more about how it collects and secures bank and credit card information. First Launch Offerings are designed to require a parent or guardian to provide oversight and supervision of any use of the First Launch Offerings by minors. Only a parent or guardian may download or install a First Launch Offering; this means that only parents or guardians may provide Your Information and all such information refers to the parent or guardian or other adult, such as a customer. We do not knowingly collect information from minors under the age of 13.
Some information about Your use of First Launch Offerings is collected automatically, using technologies like cookies, web beacons, analytics and other methods as further discussed below (“Automatically Collected Information” and, together with Your Information, “Collected Information”). Automatically Collected Information may include user IP addresses, information about Your browser/mobile device, and other similar items. It also includes any automatically collected navigational and other analytic information that We use at an aggregated level to manage, operate, maintain and improve the First Launch Offerings and users’ experiences. Automatically Collected Information is handled in accordance with this Privacy Policy, but it is not Your Information. First Launch owns all right, title and interest in and to any Automatically Collected Information and may use such Automatically Collected Information for any legal purpose.
We use the Collected Information to provide the First Launch Offerings, to communicate with You, to provide You with technical support when necessary, and for other internal research, analytic and business purposes to better understand how You and other users access and use the First Launch Offerings so that we can improve them and provide better services generally.
We may also provide the Collected Information in order to comply with legal obligations, to respond to a court order/subpoena, or when We determine using the information is necessary in order to investigate, prevent or otherwise handle any illegal activities or in other circumstances were We reasonably believe the safety or security of any person or system is at risk. We may also use the Collected Information to protect Our rights and to enforce the Agreement and this Privacy Policy.
We do not sell Your Information to any third party for marketing purposes.
We do share Your Information as necessary with third parties providing any services to You through the First Launch Offerings, such as with the third party payment processor, vendors providing hosting/maintenance services related to First Launch Offerings and other similar third parties. Sharing Your Information with these limited third parties is necessary in order for You to access and use First Launch Offerings and to receive payment using the First Launch Offerings.
We may also share, disclose or transfer Your Information in connection with a Corporate Change and We may transfer Your Information, in whole or in part (either during due diligence or upon the consummation of the Corporate Change), to the relevant third part(ies) and, if such Corporate Change actually occurs, Your Information will then be subject to the privacy policies of such third part(ies).
We may also use and disclose Collected Information as required by law, when We believe it is appropriate to comply with law enforcement requests, and/or to enforce this Privacy Policy or the Agreement, or otherwise to protect Our and Our users’ rights, property or safety.
We may use Collected Information in an aggregated form for any purpose permitted by law. Your Information, if included in such aggregation, will be anonymized.
While We do not currently use Your email address to send You any periodic email or newsletter communications on topics generally relevant to Our users, We reserve the right to do so in the future. In that event, We will provide You with an opportunity to opt-out and/or unsubscribe to such communications.
First Launch is a U.S. company; all information collected (whether Your Information, Automatically Collected Information or any other information) will be stored and processed in the United States. First Launch Offerings are intended to be used in the United States. If You are not a citizen or resident of the United States, please click here.
Without limiting the above, First Launch Offerings are maintained in the United States, and Collected Information will be processed and shared in the United States, where the laws and protections regarding data and information may be different from those of other countries. If You (or anybody authorized by You to use Your account) are a located in a country other than the United States, please be aware that Your Information will be transferred to the United States and, by providing such information, You consent to such transfer.
We use a variety of technologies and methodologies to collect, track and use information. These technologies and methodologies may include the following:
The security of Collected Information is important to Us. First Launch has established administrative, physical and technical safeguards in compliance with applicable law and general industry standards to protect all information collected, including Your Information. While We have established these administrative, physical and technical safeguards in compliance with applicable law and general industry standards, to safeguard and secure Your Information from unauthorized access or disclosure, We do not and cannot guarantee that any information, including Your Information, is 100% secure. You understand that no storage, processing or transfer of Your Information, any Automatically Collected Information or any other information can be guaranteed to be completely secure.
First Launch Offerings may provide public functionality (such as forums or other community areas) or permit You to upload documents or pictures, or share information with other users (collectively, “Community Functionality”). Community Functionality should not be considered private and We cannot prevent any Community Functionality postings from being seen, copied or otherwise used by other users in a way that is in violation with this Privacy Policy. Please consider this carefully before posting anything with Community Functionality. Community Functionality may include messaging functionality, as described in the Agreement. If You elect to use that functionality the provisions of this paragraph apply to Your use of such functionality and to any messages.
We do not sell Your Information.
As of the date of the last update of this Privacy Policy, the California Consumer Privacy Act (“CCPA”) does not apply to First Launch. If it subsequently applies to First Launch, then California residents may have additional rights; namely the right to know about the personal information a business collects about them and how it is used and shared; the right to delete personal information collected (with some exceptions); the right to opt-out of the sale of their personal information and the right to non-discrimination for exercising these rights. In the event the CCPA becomes applicable to First Launch, We will update this Privacy Policy accordingly.
First Launch reserves the right to modify this Privacy Policy from time-to-time. We will notify You of any changes by indicating the date of last update of this Privacy Policy. We encourage You to re-visit this Privacy Policy occasionally so that You are aware of the most current version. Your use or access of any First Launch Offering after such change is deemed to be Your acceptance and agreement of the change.
If you have any questions about this Privacy Policy, or if You want to request the deletion of Your Information upon the termination of the Agreement, please contact us at firstlaunchapp@mystudentbusiness.com. Please note, even when deleted, We may retain a copy of Your Information for backup, archival or legal purposes.