FirstCOUNSEL | Website Terms of Use

FirstCOMPANY Privacy Policy

A. Application of the Policy.

The following paragraphs explain:

- how we collect, use or otherwise handle information that you provide or make

available to us;

- the circumstances in which we transfer your personal data; and

- the rights that you have in relation your personal data held by us.

We will comply with the Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (“GDPR”).

B. How, when and why do we collect and use your personal data?

1. Personal data that we collect.

We collect the following information about you:

(a) your name;

(b) your email address;

(d) your contact phone number;

(e) any information that you choose to provide to us when filling in a contact form on our

website;

(f) your IP address or any other technical information that tells us how you use our website.

Where you provide us with any personal data of third parties, you confirm that you have obtained all necessary consents to do so, and that we may collect, use and disclose such personal data for the purposes set out below, in accordance with the PDPA.

2. Legal basis and purposes of use of your personal data.

We may collect, use and/or disclose personal data from you for our business purposes as follows:

- to manage our business;

- to communicate with you;

- to provide legal services to you;

- to notify you about changes in our services;

- to analyse how our website is being used;

- for the detection and prevention of fraud and other criminal offences; -

- for risk management;

- to protect our rights, property, and our personnel.

If you are an EU resident, we are required to disclose the legal basis for processing your personal data under the GDPR. We process your personal data for these purposes on the following legal basis:

- to comply with our legal and regulatory obligations;

- to perform a contract, such as engaging to provide legal services to you; -

- for our legitimate interests in;

responding to your queries;

providing services and/or information to you;

carrying out surveys in order to obtain feedback on our services; and our business purposes as set out in this paragraph.

You can object to processing based on our legitimate interests at any time by contacting us.

3. Cookies.

We may use third party cookies on this website. By accessing our website, you agree that we can place cookies on your device. Our website may allow third parties to download cookies to your device. These third-party cookies are not under our control.

4. Information from other sources.

Where permissible under applicable laws, we may combine information that you have provided to us with other information that we already hold about you and which we have collected for a compatible purpose.

C. How and when do we share your personal data?

We may disclose your personal data to our affiliated entities, third party service providers and agents, with whom we are dealing on your behalf, any necessary governmental authorities and other third parties including the counsel for an opposing party.

1. Google Analytics.

We may use Google Analytics to monitor and analyse the use of our website.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

2. Sharing with third parties.

We may share your personal data with trusted third parties in accordance with our contractual arrangements with them, including:

- our accountants, auditors or similar advisers when we ask them to provide us with

professional advice;

- suppliers to whom we outsource certain support such as counsels and experts;

- any other third party if we are under a duty to disclose or share your personal data in order

to comply with any legal obligation; or

- any other third party for the purposes of acting in accordance with the requirements of a

court, tribunal, regulator or government agency, for example, to comply with a search warrant or court order.

3. Transfer of personal data.

Where your consent has been provided, the personal data you provide to us may be transferred to third parties as may be advised to you, either within or outside Singapore, as may be necessary for any of our business purposes stated above. We will comply with our obligations under the PDPA in relation to such transfer, or processing for as long as the data remains within our possession or control.

If you are a European Union (“EU”) resident, please note that we transfer personal data to Singapore and process it there. We will comply with the requirements set out in the GDPR pursuant to the transfer of the personal data outside of the European Economic Area (“EEA”), such as putting in placed appropriate safeguards to ensure that your personal data is protected.

D. How long do we store your personal data? How do we secure your personal data?

1. Period of storage of your personal data.

We maintain your personal data for the period necessary to carry out the purposes outlined in this policy, unless a longer retention period is required or permitted by law.

For EU residents, we will endeavour to delete data within 30 days of a request for deletion or contact you if it will take longer.

2. Security

The security of your data is important to us, and we will be making reasonable and practical security arrangements to protect the personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar. However, as the transmission of information via the Internet is not completely secure, we cannot guarantee the security of information transmitted by you to our website.

E. What rights do you have with regard to your personal data?

The following section explains your rights. The various rights are not absolute and are subject to certain exceptions or qualifications.

Under the PDPA, you have the right by a written request to us, ascertain whether the information we hold about you is accurate and current, and you may also access and correct your personal data.

Rights

1. The right to access

- You have the right to know whether we process data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

2. The right to correction or rectification

- You may request us to correct any data held about you that is inaccurate.

3. Withdrawal of consent to use your personal data -

You may withdraw your consent for us to use your personal data at any time by contacting us as directed below.

If you are an EU resident, you have the following rights in regard to your personal data held by us.

Rights

1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.

2. The right of access

You have the right to obtain a copy of your personal date, if we are processing it, and other certain information about how we used it.

3. The right to be forgotten

In certain circumstances you can ask us to erase from our records your personal data that we hold. There are exceptions, for example, where we need to use your personal date for the establishment, exercise or defence of legal claims.

4. The right to restrict processing

You may request to receive the data we collect from you in a structured, commonly used and machine-readable format if processing of the data had been carried out by automatic means, and a right to request that we transfer such data to another party.

5. The right of data portability

6. The right to object

You may, at any time, object to us processing the data we hold about you for direct marketing purposes, including where we build profiles for such purposes and we will stop processing the data for that purpose.

7. The right to lodge a complaint with a supervisory authority

You are entitled to file a complaint with a supervisory authority, if you believe that the processing of your personal data infringes the GDPR.

F. How can you contact us?

You are entitled to file a complaint with a supervisory authority, if you believe that the processing of your personal data infringes the GDPR.

If you wish to request further information or exercise any of your rights described above, contact us our Data Protection Officer at: dpo@firstcompany.co. Please allow us reasonable time to respond and effect any change.

If you currently receive marketing emails from us which you do not wish to receive, please email us at updates@firstcompany.co with the subject "Unsubscribe". All email messages sent to and from Collyer Law LLC may be monitored to ensure compliance with internal policies and to protect our business.

G. Changes to this Privacy Policy.

We reserve the right to modify this Privacy Policy. When we make minor changes to our Privacy Policy, we will publish the updated Privacy Policy on our website.

If we make any material changes, we will take additional steps to inform you of these, so that you can be aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.