First Financial Network, Inc.
transferred from a European Union member country to the United States, in
reliance on the Data Privacy Framework;
about, or pertains to, a specific individual; and
- Can be linked either directly or indirectly to that
How We Collect Information
FFN collects personal data in the following ways:
- Online Registration: We collect your information, including personal
information (information that individually identifies you) directly
through your completed online registration form on www.ffncorp.com, which
may also include your execution of an online confidentiality agreement on
our website. We maintain your digital signature in our files relating to
your execution of the confidentiality agreement. We may request additional
information from you via e-mail or phone. In some cases, the professional
organization you are affiliated with may provide pertinent contact
information to us. This information is collected whether the data subject
is a buyer or seller.
- Portfolio Data: We may receive debt-related data that is provided to us
directly from our clients located within a European Union member country
(“Client”) which may contain personal data.
- IP Addresses: An IP address is a number that is automatically assigned to
your computer whenever you browse the internet. First Financial Network
logs IP addresses of visitors for system administration, security and
troubleshooting purposes as well as tracking relative statistical
information for a specific sale. Web servers automatically identify your
computer by its IP address. When you request pages from any First
Financial Network website, FFN servers log your IP address. First
Financial Network collects these IP addresses for the purpose of
identifying our users' service providers so we can better develop our
- Cookies: A cookie is a piece of data stored on the user’s hard drive
containing information about the user session that tracks online system
behavior and history (if your web browser permits). Cookies can also
enable us to track and target the interests of our users to enhance the
experience on our website. This statistical information may also be shared
with sellers associated with a sale registered by the user and for FFN’s
own internal informational purposes. By visiting
www.ffncorp.com with your browser settings adjusted to
accept cookies, you consent to FFN’s use of your cookies.
- E-mail Address: When a visitor submits an inquiry via e-mail, FFN may log or retain
the email address for FFN’s records.
Notice and Choice
- We notify individuals about the personal data we
collect from them, how we use it and how to contact us with privacy
- We provide such notice through this policy on our
website or other similar documents, and direct communication with
individuals from whom we collect personal data.
- We collect and process personal data about FFN’s
personnel for the purpose of human resources administration and
recruitment following the Data Privacy Framework.
- We collect and process personal data about our
clients and their personnel for the purpose of rendering professional
services to them.
- We collect personal data from individuals only as
permitted by the Data Privacy Framework in accordance with the Principals
- Consent for personal data to be collected, used,
and/or disclosed in certain ways (including opt-in consent for sensitive
data) may be required in order for an individual to obtain or use our
our registration form, and our other agreements with clients or users.
In the case that
FFN receives portfolio data from one of its Clients, the Client is responsible
for receiving consent, providing any required notice to its customers as to
what data is collected and how it is used.
The Way We Use Data
When you register on our site, submit an inquiry or a
comment, we may contact you regarding your registration, inquiry or comment. We
may also use your e-mail address and/or phone number to provide you with
information regarding a specific sale you have registered for or about related
sales, industry information that might be of interest, and/or FFN’s services,
as well as email alerts. We use the information you provide about yourself when
bidding in order to complete the bid and to maintain in FFN’s sale records,
which are internal to FFN.
We may also use aggregate information for business purposes
to enhance FFN’s services and offerings, website, data analysis, and marketing
With Whom We Share/Disclose Your Information
We typically only share your bid information with Client in
order to complete a transaction. We may share your information with appropriate
entities or public authority if we believe it is reasonably necessary to comply
with a law, rule or regulation, reporting requirement, protect the safety of
any person, address fraud, security or technical issues, or to protect FFN’s
legal rights or property.
We may share your information in response to subpoenas,
court orders, or other legal process; to establish or exercise our legal
rights; to defend against legal claims; or as otherwise required by law.
We do not disclose
an individual's personal data to third parties, except when one or more of the
following conditions is true:
- We have the individual's permission to make the
- The disclosure is required by lawful request by
public authorities, including to meet national security or law enforcement
requirements. FFN is also subject to the authority of the Federal Trade
- The disclosure is required by law or mandatory
professional standards. The disclosure is reasonably related to the sale
or other disposition of all or part of our business.
- The information in question is publicly available.
- The disclosure is reasonably necessary for the establishment
of legal claims.
FFN is responsible for the third-party acts within its
control that result in the processing of personal data inconsistent with the Data
Privacy Framework. If we become aware of a third-party processing data covered
by this Data Privacy Framework Policy in a way that is conflict with the Data
Privacy Framework Principles, FFN will take immediate steps to prevent or stop
To prevent unauthorized access, maintain data accuracy,
ensure the appropriate use of information and protect against the loss, misuse
or alteration of information under our control, we have put in place reasonable
physical, electronic and managerial procedures to safeguard and protect the
information we collect online.
While we follow generally accepted standards to protect
personal data, no method of storage or transmission is 100% secure. You are
solely responsible for protecting your password, limiting access to your
devices and signing out of the website after your session. If you have any
questions about the security of our websites, please contact us by using the
information in the “How to Contact Us” section below.
Data Integrity and Access
You have certain rights relating to your personal data.
These rights include:
- To access your personal data (right to access);
- To rectify inaccurate personal data (right to
- To erase/delete your personal data, to the extent
permitted by applicable data protection laws (right to erasure; right to
- To transfer your personal data to another
controller, to the extent possible (right to portability);
- To object to any processing of your personal data
carried out on the basis of our legitimate interests (right to object).
Where we process your personal data for direct marketing purposes, you can
exercise your right to object at any time to such processing without
having to provide a specific reason for such objection;
- To not be subject to a decision based solely on
automated processing, including profiling, which produces legal affects
- To withdraw your consent at any time, without
affecting the lawfulness of the processing based on such consent before
If your personal data is included in portfolio data
obtained by FFN from a Client, you may contact the Client to which you
submitted your data and request access. FFN will then assist in the subject
access request as directed by the Client.
To exercise your rights, please contact FFN’s Data
Protection Officer by sending an email to
firstname.lastname@example.org. Please attach a copy of your ID with your request for
We may request additional identifying information as a
security precaution such as possibly a national identifier (e.g. a Social
Security number). In addition, we may limit or deny access to personal
information where providing such access would be unreasonably burdensome or
expensive in the circumstances, or where the rights of persons other than the
individual would be violated. In some circumstances, we may charge a reasonable
fee, where warranted, for access to personal information.
Some registered users may update their user settings and
profiles by logging into their accounts and editing them on the Account page.
Compliance and Enforcement
We have designated a Data Protection Officer (DPO) to
monitor our adherence to the Data Privacy Framework and to address questions
and concerns regarding our adherence.
Individuals may file a complaint with Data Protection
Officer in connection with FFN’s processing of their personal data under the Data
With respect to any dispute relating to this policy that
cannot be resolved through our internal processes:
- Individuals may file a claim with Judicial
Arbitration and Mediation Services (JAMS). To contact JAMS and learn more
about submitting a complaint, please
visit: https://www.jamsadr.com/dpf-dispute-resolution. JAMS will
provide independent dispute resolution and, should it determine it
appropriate, can also assess sanctions, including damages, for violation
of the Principles outlined in the Data Privacy Framework.
- An individual may under certain conditions invoke
binding arbitration. Please see the
Framework website for more information on conditions giving rise to binding
are significant, we will provide a prominent notice to you. So long as we
adhere to the Data Privacy Framework, we will not amend our policy in a manner
inconsistent with the Data Privacy Framework.
If you have any questions, please contact us via email or
in writing at:
Data Protection Officer
First Financial Network, Inc.
9211 Lake Hefner Parkway, Suite 200
Oklahoma City, OK 73123
Last Updated October 20, 2023