Last updated on December 22, 2022
- What information we collect
- How and why we use/share your information
- How long we keep your information
- International data transfers
- Your rights
- Contact Details
Please note that the Site or App is not intended for use by anyone under the age of 18 and we do not knowingly collect information about minors. If you believe that we have collected personal information about your child, you can contact us at info@1-FIRST.com and request that we remove the information about your child.
For security reasons and to protect the transmission of confidential content, such as B. the inquiries that you send to us as the site operator, an SSL / TLS encryption. You can recognize an encrypted connection by the fact that the address line of your browser changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
3. What information we collect
3.1 What is personal data?
3.2 How and what types of information we collect from you when you use the Site or App
When you use the Site or App to interact with a wallet, create an account or profile, fill out forms provided on the Site or App, our Services, notifications or newsletters subscribe, or to report a problem with the Site or App, we may collect, store, and use certain personal information that you give us.
The information we collect from you includes but is not limited to: your IP address, IBAN, email address, phone number, feedback and login information.
We will also collect information about you when you visit and interact with the Site or App through the use of technologies such as cookies. The following are examples of information we may collect:
- Information about your device, browser or operating system;
- Time zone setting;
- your IP address;
- Information about interactions you make on the site or with the app (e.g. scrolling and clicks);
- Information about how you use the app and what actions you perform within the app;
- Length of time spent in the app and time spent within certain sections;
- Response times; and
- Download error.
Please see your device’s help documentation for controls you can use to remove cookies, block cookies, or disable IDFA tracking. If you do so, it may affect your use of any website or app, including the 1-FIRST site or app (1-FIRST website or application).
We may also work with third parties who may collect anonymous usage or statistical data through your use of the Site or App (e.g. subcontractors for technical, payment and/or delivery services, business partners, advertising networks , analytics provider).
We may also collect information about how you use the App through Google Play’s Android Advertising ID technology and Apple iOS’s Advertising Identifier. This is only used by us and our trusted third parties (see “Service Providers” below) for advertising and user analytics. The advertising identifier is only linked to personal data if you have given us your express consent. We will respect your user choices for this technology and will not use the data in ways that you do not want. We are committed to complying with the Google and Apple Terms of Service and you can contact us (info@1-FIRST.online), Google or Apple directly if you have any questions about our use of this technology.
3.3 Updating Your Information
If you would like to update the information you have previously given us, you can contact us at info@1-FIRST.online
4. How and why we use/share your information
4.1 Lawful basis for processing your data
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:
- If you have asked us to do so or have given us your consent;
- Where we need to do this in order to perform a contract we have with you;
- Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation; and
- For marketing messages.
You will receive marketing communications from us if you have given us your consent to do so, or if you have provided feedback about our site or app and have not opted out of receiving marketing communications.
To unsubscribe from marketing emails at any time, please click the unsubscribe link at the bottom of each marketing emailail and update your account settings. You can also contact us (info@1-FIRST.com) to let us know if you do not wish to receive marketing material from us.
4.2 Disclosure of your information
Depending on how and why you provide us with your personal information, we may share it in the following ways:
- with every member of our group, i. H. our subsidiaries, our ultimate holding company and its subsidiaries;
- with selected third parties, including business partners, suppliers and subcontractors, in order to perform any contracts we enter into with them or you (see “Service Providers” below); or
- with analytics that help us improve and optimize the site or app.
We may also provide your personal information to third parties in the following cases:
- if we should sell or buy any business or assets; in which case we may disclose your personal information to the prospective seller or buyer of such business or asset;
- if 1-FIRST or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be among the transferred assets; or
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or to protect the rights, property, or safety of our company, our customers, or others. This includes sharing information with other companies and organizations for fraud protection and credit risk reduction purposes.
4.3 Service Provider
Our service providers provide us with a variety of administrative, statistical and technical services. We provide service providers with only the minimum amount of personal information they need to perform the services we request and we require that they protect that information and not use it for any other purpose. We take these relationships seriously and require all our data processors to sign contracts with us that clearly set out their obligation to respect the rights of individuals and their obligation to assist us in exercising your rights as a data subject.
4.4 Other information
During your use of the Site or the App, your app store provider and mobile network operator may also collect personal information about you related to your use of the App, such as: B. Your identity, usage and location.
These third parties act as separate and independent controllers of that personal data and process it in accordance with their own privacy policies.
4.5 Links to Third Party Sites
5. How long we keep your information
We will retain your personal information on our systems only for as long as is necessary to provide you with the products and services you have requested, including to comply with any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period if there is a complaint or if we reasonably believe there is a risk of litigation relating to our relationship with you.
In certain circumstances you can ask us to erase your data: see “Your rights” below for more information.
We may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposesen; in which case we may use this information indefinitely without further notice to you.
1-FIRST takes the protection of your data very seriously. We have put in place reasonable physical, electronic and managerial safeguards to prevent your personal information from being accidentally lost, used or accessed, altered or disclosed by unauthorized means, including the use of secure servers, passwords and industry-standard encryption for data on both the transmission as well as in idle state.
If we have given you a password or PIN code that enables you to access certain parts of our site or app, you are responsible for keeping that password or PIN code confidential. We ask that you do not share a password or PIN code with anyone.
When you interact with a wallet, 1-FIRST never has access to users’ private keys and/or funds. You are solely responsible for keeping your private keys confidential. We strongly advise against sharing your private keys with others. If you lose or share your private keys, you risk losing assets.
We limit access to your personally identifiable information to those employees, contractors or potential third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. International Data Transfers
Please note that some of our service providers may be based outside the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, fulfilling your request for information, products and services, processing your payment details and providing support services.
Where we transfer your data to a service provider outside the EEA, we try to ensure that appropriate safeguards are in place to ensure that your personal data is held securely and that your rights as a data subject are protected . Transfers of personal data are carried out either:
- to a country recognized by the European Commission as offering an adequate level of protection; or
- to a country that does not offer an adequate level of protection, but the transfer of which has been regulated by the European Commission’s Standard Contractual Clause or by the implementation of other appropriate solutions for cross-border transfers that offer an adequate level of protection.
By submitting your personal information, you consent to this transfer, storing or processing.
If you would like more information about the mechanism by which your personal information is transferred, please contact info@1-FIRST.com.
8. Your Rights
As a data subject, you have a number of rights in relation to your personal data. Below we have described the various rights you have and how you can exercise them.
8.1 Access Authorization
You can request access to the personal information we hold about you at any time (you may have heard of this right, known as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal information we hold about you so that you can check that it is accurate and to ensure that we keep it process personal data lawfully. It is not a right that allows you to request personal information about another person, or a right to request certain documents from us that do not relate to your personal information.
You can exercise this right at any time by writing to us (info@1-FIRST.com) and telling us that you are making an “Access Request”. You don’t have to fill out a specific form to make this type of request.
8.2 Ihr Right to rectification and erasure
You may, at any time, request that we correct any personal information we hold about you that you think is incorrect or inaccurate. Please note that we may ask you to verify any new information you provide to us and we may take our own steps to verify that the new information you have provided to us is are correct.
You can also ask us to erase personal information that we control if you don’t think we need to keep it (you may have heard of this right, known as the “right to being forgotten”). Although we will do everything we can to respect your request and your personal data, it may not always be possible to delete all your personal data as there may be legal requirements to retain certain personal data or technical restrictions on the data that we can delete.
There may also be legitimate interests in retaining certain data, including where the data is necessary for the app to function. If this is the case, we will continue to process this data.
If erasure is not technically possible, or we believe we have a good legal reason to continue processing the personal information you ask us to erase, we will notify you of that and our reasons for doing so Let us know when your request will be answered.
You can exercise this right at any time by writing to us (info@1-FIRST.com) and telling us that you require the correction or deletion of your personal data and on what basis you make this request put. If you want us to replace inaccurate data with new data, you should tell us what the new data is. You don’t have to fill out a specific form to make this type of request.
8.3 Your right to restrict processing
Where we are processing your personal data on the basis of a legitimate interest, you have the right to ask us to stop processing in this way if you feel that our further processing would violate your fundamental rights and – freedoms are affected or you believe that these legitimate interests are not valid.
You can also ask us to stop processing your personal data (a) if you contest the accuracy of that personal data and you want us to verify the accuracy of the data; (b) where it has been determined that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal information (and would otherwise dispose of it) but you wish us to continue storing it to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe we have a good legal ground to continue processing personal data that you ask us to stop processing, we will notify you what that reason is, either at the time we first respond to your request or after we’ve had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us (info@1-FIRST.com) and telling us that you are making a request for us to stop processing the relevant aspect of your personal data and describe which of the above conditions you think are relevant to this request. You don’t have to fill out a specific form to make this type of request.
8.4 Your Right to Portability
If you wish to transfer certain personal data that we have stored about you and that is processed automatically to a third party, you can write to us and ask us to provide you with this data in a commonly used, machine-readable format to ask.
Due to the nature of our work and the systems we use, we do not consider this right to be particularly relevant to the majority of the people with whom we interact. However, if you wish to have your data transferred from us to a third party, we are happy to accommodate such requests.
8.5 Your right to object to processing
You can object to the processing of your personal data if we uns rely on a legitimate interest for the processing of this personal data. We will comply with your request unless we have an overriding legitimate interest in processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
8.6 Your right to stop receiving communications
To unsubscribe from communications at any time, please click the “unsubscribe” link at the bottom of each email and update your notification preferences in the app. For details of your rights to ask us to stop sending you various types of communications, please contact us (info@1-FIRST.com).
8.7 Your right to object to automated decision-making and profiling
You have the right to be informed about the existence of automated decision-making and profiling of your personal data and, where appropriate, meaningful information about the logic involved and the significance and likely consequences of such processing affecting you , to get.
8.8 Withdrawal of Consent
Where we are relying on consent to process your personal data, you can withdraw your consent at any time. However, this does not affect the lawfulness of the processing that took place before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will let you know if this is the case when you withdraw your consent.
8.9 Exercising your rights
If you send us a written request to exercise your rights, we may ask you to prove that you are who you say you are. We may ask you to provide copies of relevant identification documents to help us verify your identity.
It will help us to process your request if you clearly state what right you wish to exercise and, where relevant, why you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can process your request. If you do not provide us with sufficient information, we may delay processing your request until you have provided us with additional information (and if you do so, we will let you know).
9. Use of Services
9.1 Use of Google Maps
This website uses Google Maps. This enables us to display interactive maps directly on the website and enables you to conveniently use the map function. By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. This happens regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be assigned directly to your account. If you do not wish to be assigned to your profile on Google, you must log out before activating the button. Google stores your data as usage profiles and uses them for advertising, market research and/or needs-based design of its website. Such an evaluation is carried out in particular (also for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, although you must contact Google to exercise this right. You can find more information on the purpose and scope of data collection and processing by Google, as well as more information on your rights in this regard and setting options for protecting your privacy, at: www.google.de/intl/de/policies/privacy.
9.2 Use of Google Remarketing
This website uses the remarketing function of Google Inc. to present interest-based advertising to website visitors within the Google advertising network. A so-called “cookie” is stored in the browser of the website visitor, which makes it possible to recognize the visitor when he visits websites that belong to the Google advertising network. On these pages, the visitor may be presented with advertisements related to content previously viewed by the visitor on websites that use the RemarUse Google’s keting function.
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited. If the person responsible for data processing on this website is located outside the European Economic Area or Switzerland, Google Analytics data processing is carried out by Google LLC. Google LLC and Google Ireland Limited are hereinafter referred to as “Google”.
We can use the statistics obtained to improve our offer and make it more interesting for you as a user. This website also uses Google Analytics for a cross-device analysis of visitor flows, which is carried out using a user ID. If you have a Google user account, you can deactivate the cross-device analysis of your usage in the settings there under “My data”, “Personal data”.
The legal basis for the use of Google Analytics is Art. 6 Para. 1 lit. f GDPR (EU General Data Protection Regulation). The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. We would like to point out that on this website Google Analytics has been extended by the code “_anonymizeIp();” in order to ensure that IP addresses are recorded anonymously. This means that IP addresses are processed in abbreviated form so that personal reference is excluded. If the data collected about you contains a personal reference, this will be excluded immediately and the personal data will be deleted immediately.
Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator.
You can also prevent the use of Google Analytics by clicking on this link: Disable Google Analytics. As a result, a so-called opt-out cookie is stored on your data carrier, which prevents the processing of personal data by Google Analytics. Please note that if you delete all cookies on your end device, these opt-out cookies will also be deleted, i.e. you must set the opt-out cookies again if you want to continue to prevent this form of data collection. The opt-out cookies are set per browser and computer/device and must therefore be activated separately for each browser, computer or other device.
9.4 Newsletters – Mailchimp
The newsletter is sent via the mail service provider ‘MailChimp’, a newsletter mailing platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the data protection regulations of the shipping service provider here. The use of the shipping service provider is based on our legitimate interests in accordance with Article 6 Paragraph 1 Letter f GDPR and an order processing ordinanceAccording to Art. 28 Para. 3 GDPR.
The shipping service provider can use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve their own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter or for statistical purposes . However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass them on to third parties.
You can prevent the data processing described here by not using certain tools or fundamentally object to data processing before entering the site by clicking the No button.
11. Contact Details