First Financial Network, Inc. (“FFN” or the “Company”) complies with the EU-U.S. Data Privacy Framework (DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. FFN has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles. If there is any conflict between the terms in this privacy policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework, and to view our certification, please visit https://www.dataprivacyframework.gov. This policy applies to personal data we handle. For purposes of this statement, "personal data" means information that:
FFN collects personal data in the following ways:
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.
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
analysis.
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:
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
such processing.
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.
You have certain rights relating to your personal data.
These rights include:
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
dpo@ffncorp.com. Please attach a copy of your ID with your request for
verification purposes.
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.
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
Privacy Framework.
With respect to any dispute relating to this policy that
cannot be resolved through our internal processes:
This Privacy Policy is subject to change from time to time.
We will post any applicable Privacy Policy changes on this page. If the changes
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