Privacy Policy​

Introduction and Acceptance

Welcome to the FirstLink Business Solutions’ website located at https://firstlinktt.org/ (the
“Website”) which includes all subdomains present and future, including without limitation the
FirstLink Business Solutions blog found at http://blog.firstlinktt.com (the “Blog”).

We hope you enjoy your visit and / or use of the Website. By visiting and / or using the Website
you agree to be bound by the terms of the present Privacy Policy (the “Policy”).

The Website is owned and operated by FirstLink Business Solutions Limited., a duly
incorporated company in the Republic of Trinidad and Tobago. Where the present Policy refers
to “FirstLink”, it may refer to the Website or FirstLink Business Solutions Limited (and / or its
officers, directors, employees, agents or representatives) or both, depending on the context.

The Policy was last modified on March 1, 2020. FirstLink reserves the right, at any time and
without prior notice, to modify or replace any of this Policy. Any changes to the Policy can be
found at this URL. It is your responsibility to check the Policy periodically for changes. Your use
of the Website following the posting of any changes to the Policy constitutes acceptance of
those changes.

The Policy should be read in conjunction with the Terms of Use, as both these documents
govern your use of the Website.

In this Policy, a Website visitor or user may be referred to as “you”. FirstLink may sometimes be
referred to as “we” or “us”.

If you have any questions about the Policy, or if you wish to inquire about and / or access any
personal information FirstLink holds about you, please email legal@firstlinktt.org.

General Statement of Privacy and Protection of Personal Information

FirstLink takes your privacy and security of personal information very seriously. We have
provided a secure environment and this strict Policy that describes the limited ways the
information is used and the limited access to such information.

What Does This Privacy Policy Cover?

This Policy covers the treatment of personally identifiable information (“Personal Information”)
and other information gathered by FirstLink when you are using or accessing the Website. This
Policy also covers FirstLink’s treatment of any Personal Information that FirstLink may share with
its business partners or other third parties under very limited circumstances.

This Policy does not apply to the general practices and treatment of information (whether personal or not) by third parties that FirstLink does not own or control, including but not limited to any third party websites or services that you elect to access through the Website or via a link from the Website (“Third Party Website”), or to individuals that FirstLink does not manage or employ. While we attempt to facilitate access or link to only to those Third Party Websites that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Websites. We encourage you to carefully review the privacy policies of any Third Party Website you access. We have named and provided links to the most important of these Third Party Websites further in this Policy.

Finally, this Policy does not cover any Personal Information you send to FirstLink via any nonsecured mode of communications such as email, instant messenger, Facebook or LinkedIn, as communications via these methods may be subject to interception, loss, or alteration. While we welcome your comments, inquiries and suggestions sent to us in this manner, we encourage you to carefully examine what Personal Information you send to FirstLink via these methods.

No Collection of Personal Information as a Matter of Course

FirstLink does not, as a matter of course, gather any of your Personal Information while you are
visiting or using the Website, unless you are asked to provide such information, for example by
signing up to Schedule a Free Consultation. Personal Information is only gathered with your
informed consent. Where you have provided Personal Information, it will only be used for the
stated purpose, for example to respond to your inquiry or for signing up for a newsletter.

Security and Encryption of Information

FirstLink uses only industry best practices (physical, electronic and procedural) in keeping any
data collected (including Personal Information) secure. In addition, FirstLink uses third party
vendors and hosting partners to provide the necessary hardware, software, networking, storage,
and related technology required to run the Website, and these third parties have been selected
for their high standards of security, both electronic and physical.

Limited Gathering of Information for Statistical, Analytical and Security Purposes

FirstLink automatically collects certain information using third-party analytics programs Google
Analytics, Freshworks, and HubSpot to help us understand how our users use the Website, but
none of this information identifies you personally. For example, each time you visit the Website,
we automatically collect your IP address, browser and computer type, access times, the web page from which you came, and the web page(s) you access (as applicable). We use information collected in this manner only to better understand your needs and the needs of the Website users in the aggregate. FirstLink also makes use of information gathered for statistical purposes to keep track of the number of visits to the Website and the specific pages on the Website with a view to introducing improvements.

Your IP address and other relevant information may be used in order to trace any fraudulent or
criminal activity, or any activity in violation of the Terms of Use.

Non-disclosure of Personal Information to Third Parties

Except as provided in the next paragraph and the next section in this Policy entitled Third Party
Services, FirstLink does not divulge any Personal Information gathered via the Website to third
parties. Moreover, FirstLink does not sell, rent, trade or license any Personal Information
regarding its users to third parties. Only the employees, representatives, subcontractors, officers,
agents, or assigns of FirstLink are responsible for the management and development of the
Website, and only these individuals have access to the information collected there. These
employees, representatives, subcontractors, officers, agents or assigns all have been instructed
to comply with the Policy.

Notwithstanding anything in the Policy to the contrary, we may share any information we have
collected about you or that you have submitted: (1) in response to subpoenas, court orders, or
legal process, or to establish, protect, or exercise our legal rights or defend against legal claims
or demands; (2) if we believe it is necessary in order to investigate, prevent, or take action
regarding illegal activities, fraud, or situations involving potential threats to the safety of any
person, or any violation of the Terms of Use; (3) if we believe it is necessary to investigate,
prevent, or take action regarding situations that involve abuse of the Website infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to
compromise the security of the Website infrastructure or the Website generally); (4) to a parent
company, subsidiaries, joint ventures, or other companies under common control with FirstLink
(in which case we will require such entities to honour this Policy); (5) if FirstLink is acquired by or
merged with another entity (in which case we will require such entity to assume our obligations
under this Policy, or inform you that you are covered by a new privacy policy).

Third Party Services

FirstLink uses certain third party services in order to augment the Website. Personal information
may be transferred from FirstLink to these third party services, but only to the extent required in order for them to function properly, and only upon your express submission of such information. These third party services include Facebook, LinkedIn and Google+ for sharing of content, specifically Blog posts. If you are not already logged in to these third party services, your Personal Information required to log in to those accounts is transferred securely from FirstLink to the third party services. When your Personal Information is transferred to these third party services, it iscovered by their respective privacy policies, which we encourage you to read.

In addition, FirstLink uses certain third party services to add functionalities to the Website. Personal information may be transferred from FirstLink to these third party services, but only to the extent required in order for them to function properly, and only upon your express submission of such information. These third party services are limited to: (1) Freshchat for live chat and messages; (2) Zendesk for customer service inquiries; and (3) Freshsales for Customer Relationship Management (CRM) which accepts data (including Personal Information) directly
from the Contact form, Free Assessment form, and Blog comment form. While we store Personal Information collected via these forms with HubSpot’s CRM software, this information is only used
to respond to your inquiries and / or to follow-up as required. All FirstLink’s email activities are in compliance with Trinidad and Tobago’s Data Protection Act, Chapter 22:04. FirstLink also uses
MailChimp to send out their newsletter, and we store your email address with HubSpot and Freshsales for that purpose.

The third party services listed in this section are currently the only third party services used on
the Website at the present time. However, FirstLink reserves the right to add additional third party
services in the future. In the event we add third party services, this section will be updated
accordingly.

Access and Deletion of Personal Information

If you wish to review the Personal Information FirstLink holds about you, and / or have all your
Personal Information permanently deleted from our records, please contact us using the online
form or the contact information further up in this Policy

Tracking Technology (“Cookies”)

FirstLink uses tracking technology (“cookies”) on the Website and by using the Website you
agree to their use. Cookies are small text files placed on your hard drive when you visit a
website, in order to track use of the site and to improve the user experience by storing certain
data on your computer. The Website uses “session cookies,” which improve your user
experience by storing certain information from your current visit on your computer. Other
cookies are also used, for example to store your email address or other information (such as
your name) in certain form fields so it does not have to be re-entered in other forms.

Your browser can be set to refuse cookies or delete them after they have been stored. Please
refer to your browser’s help section for instructions. Please note that deleting these cookies may
reduce your user experience on the Website by requiring you to re-enter certain information,
such as your email address. FirstLink shall not be held responsible for any function that may not
operate after you delete cookies, or any damages (pecuniary or otherwise) arising from those
functions not operating, or having reduced functionality.

Risks Associated with the Internet

Despite FirstLink’s best efforts to ensure that third parties will not access or obtain your
Personal Information through your use of the Website, complete confidentiality and security
cannot currently be guaranteed on the Internet. Communication via the Internet is subject to
interception, loss, or alteration. You acknowledge and agree that FirstLink cannot be held
responsible for damages resulting from the transmission of confidential information or Personal
Information over the Internet and that such communications are at your own risk.

Limitation of Liability

FirstLink, and / or its respective officers, directors, owners, officials, partners, partnerships,
principals, employees, affiliates and other related entities, servants, agents, representatives,
successors and assigns, will not be held liable for any damages, direct or indirect, pecuniary or
otherwise, resulting from the misuse of any information collected by any third party, or any
misuse of any information collected through the Website not in violation of the Policy.