FirstBatch Inc, Privacy Police

PRIVACY POLICY

  1. Preamble

As FirstBatch, we respect your privacy and are committed to fully explaining how we handle your personal data. This Privacy Policy (“Policy”) describes our practices and policies regarding the use and processing of personal data while providing our services. This Policy further describes the types of personal data we collect, how we use that data, our legal basis for doing so, with whom we share it, your rights, and choices in this regard, and how you can contact us about our privacy practices.

When we refer to FirstBatch, we mean FirstBatch ###, located in ###.

  1. Our Services and Scope of this Policy

As a service provider for compatible platforms, FirstBatch utilizes public profile data from social media handles to generate embeddings and quarriable interest vectors, enabling personalized user experiences while maintaining privacy.

This Privacy Policy outlines how we collect, use, and protect the personal data of users who choose to personalize their experience on compatible platforms. Please read this Privacy Policy carefully to understand our practices regarding your personal data.

Please be aware that this Policy does not govern all the information FirstBatch may process. Our commitment to customers and service providers is governed by a separate data protection and privacy notice.

  1. Acknowledgment of the Policy

By opting to personalize your experience on the compatible platform and connecting your social media handle to FirstBatch, you acknowledge that you have reviewed and understood the practices outlined in this Policy. If you do not consent to the processing activities described in this Policy, please refrain from accessing or using the services provided by FirstBatch.

  1. Definitions

In this Policy, certain terms are used with specific meanings, as defined below, to provide clarity and understanding.

data controller means the legal person which determines the purposes and means of the process of personal data alone or jointly with others
data subject means a natural person who can be identified or rendered identifiable through the personal data related to
GDPR means (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the Processing of personal data and on the free movement of such data (General Data Protection Regulation) (the "EU GDPR"); and (ii) the EU GDPR as saved into United Kingdom law by virtue of section 3 of the United Kingdom's European Union (Withdrawal) Act 2018 (the "UK GDPR"); in each case as may be amended or superseded from time to time
personal data breach means a breach of security whether accidental or on purpose, resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data
personal data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity
host platform means the e-commerce or other compatible platforms where users login and are presented with the option to personalize their experience using FirstBatch
social network(s) mean social networks, such as Twitter, YouTube, and other compatible host platforms that can be utilized FirstBatch to personalize user experiences based on their interests and preferences
third party means any other natural or legal person that is not part of FirstBatch
user refers to an individual who interacts with the host platform and has the opportunity to personalize their experience using FirstBatch via the utilization of their social media profile data
User ID refers to a unique identifier assigned to an individual user on the host platform. It is a specific identification code or alphanumeric value that distinguishes and represents the user within the systems and databases of the host platform. The User ID is used to match the personalized vectors generated by FirstBatch with the corresponding user on the host platform, enabling a tailored and personalized user experience based on their interests and preferences
  1. Personal Data Processed by FirstBatch

FirstBatch processes the public profile data obtained from the user's social media handle, which includes publicly available information such as the user's username (social media handle), public posts, interests, followers, and other publicly shared information from platforms like Twitter, YouTube, or other compatible host platforms. However, it is important to note that FirstBatch does not take, transfer, or store the entirety of the user's social media profile data. Only the necessary data required to generate embeddings and facilitate personalization is processed.

In addition to processing public profile data, FirstBatch also utilizes the User ID provided by the compatible host platforms.The vectors generated from the user's public profile data are transferred to the host platform's backend, where they are matched with the User ID associated with the user on the host platform. This matching process enables the host platform to personalize the user's experience based on the generated vectors without revealing any of the user's social media profile data. This ensures that the user's privacy is preserved, and their social media profile data remains separate from the personalized experience provided by the host platform.

In compliance with its legal obligations, FirstBatch may process;

  • Contact information: This may include the user's name, email address, phone number, and other contact details necessary for communication and responding to data subject requests.
  • Identification Data: This may include information such as the user's unique identifiers (e.g., User ID).
  • Metadata: FirstBatch may process metadata associated with user interactions, such as timestamps, IP addresses, and device information, to ensure compliance with security measures and legal obligations.
  • Communication Data: This includes any personal data exchanged during communications between the user and FirstBatch, such as emails or messages related to data subject requests or inquiries.
  • Security Data: FirstBatch may collect, and process personal data related to security measures, including logs, access control data, and audit trails, to ensure the protection and integrity of user data and comply with legal requirements.
  1. How FirstBatch Uses Personal Data

Personalization

Upon receiving your permission, FirstBatch will process your public profile data to obtained from social media handles, to generate a set of embeddings. These embeddings are mathematical representations of your interests. FirstBatch then utilizes these embeddings to create an interest map and vectorize it. The resulting vectors are transferred to the host platform's backend, where they are matched with your User ID. This enables us to personalize your experience on the host platform based on your interests without compromising your privacy.

By personalizing their experience, users can enjoy tailored recommendations, improved content discovery, and a more customized interaction with the host platform based on their interests and preferences.

Products

Additionally, we utilize Pinecone DB to vectorize products. This allows for enhanced matching and recommendation functionalities to improve your overall experience on the host platform.

Overall, FirstBatch utilizes the public profile data obtained from social media handles to generate embeddings and provide a personalized user experience. The personal data processed is limited to publicly available information, and FirstBatch does not share this data with third parties. Instead, FirstBatch shares the vectorized representations of the user's interests with the host platform's backend, enabling enhanced personalization without compromising the privacy of the user's social media profile data.

Legal Grounds for Processing Activities by FirstBatch

We rely upon several legal grounds to ensure that our use of your personal data is compliant with the applicable law.

  • Consent: FirstBatch relies on the legal basis of consent as provided by the user in order to process their public profile data. By obtaining the explicit consent of the user, as required under the GDPR, FirstBatch processes the data solely for the purpose of generating embeddings and providing personalized experiences. Users have the option to grant or deny consent, and they can withdraw their consent at any time.
  • Performance of a Contract: When you request a personalized service from the host platform, processing activities are based on the legal ground of performing that contract. Personalized experiences and recommendations are provided as part of the services offered by FirstBatch, and processing public profile data is necessary for fulfilling this contractual obligation.
  • Compliance with Legal Obligations: FirstBatch may process personal data to comply with its legal obligations, including obligations imposed by the GDPR. This includes implementing appropriate security measures to protect user data and responding to data subject requests within the required timeframes, as mandated by the applicable regulations.
  1. Sharing of Personal Data by FirstBatch

FirstBatch does not rent or sell your information.

FirstBatch does not share personal data, including the user's social media profile data, with any third parties. However, FirstBatch does share the vectorized representations generated from the public profile data with the host platform's backend. These vectors are transferred to the host platform to facilitate personalized recommendations and enhanced user experiences. The sharing of vectors allows the host platform to tailor its offerings without directly accessing or storing the user's social media profile data. It is important to note that FirstBatch does not transfer or disclose any identifiable information or the original social media profile data itself during this process.

Employees and Authorized Contractors

Our employees and authorized contractors may need to access information about you when they require this information to perform their job. For example, our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise the Services. All our employees and contractors are required to agree to maintain the confidentiality and protect the privacy of your information.

Business Transfers

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share personal data with Third Parties for the purpose of facilitating and completing the transaction. If we do, we will inform such entities of the requirement to handle your information in accordance with this Privacy Policy or inform you that you are covered by a new privacy policy. You will have the opportunity to opt-out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.

Law Enforcement, Government Agencies, and Professional Advisors

We may need to disclose information about you where we believe that it is reasonably necessary to comply with a law or regulation, or if we are otherwise legally required to do so, such as: (i) to comply with applicable law; (ii) to enforce our contractual rights including our Terms and this Privacy Policy; (iii) to protect the rights, privacy, safety, and property of FirstBatch, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence. For governmental data access requests concerning you, we would first attempt to redirect the request to you and/or we would first attempt to notify you unless we are legally prohibited from doing so.

  1. How Our Processing Method Enhances Privacy

We understand the importance of privacy and have implemented measures to ensure the protection of your personal data. The following sections explain how our processing method is privacy-enhancing:

Limited Data Processing:

When you choose to personalize your experience and connect your social media handle to FirstBatch, we only process your public profile data for the specific purpose of generating a set of embeddings. We do not take, transfer, or store any of your social media profile data beyond this scope. This approach ensures that we minimize the amount of personal data we handle, reducing the potential privacy risks associated with data processing.

Anonymized Embeddings:

FirstBatch converts your public profile data into a set of embeddings, which are mathematical representations of your interests. These embeddings do not contain any identifiable information from your social media profile. By utilizing this anonymized representation, we dissociate your personal data from the generated embeddings, providing an additional layer of privacy protection.

Transfer of Vectorized Data:

To personalize your user experience, the generated vectors are transferred to the host platform's backend, where they are matched with your User ID. This transfer ensures that the host platform can provide personalized recommendations and tailor your experience without directly accessing your social media profile data. By separating the vectors from your personal data, we maintain a privacy-conscious approach.

Utilization of Pinecone DB:

We utilize Pinecone DB to vectorize products/contents enabling enhanced matching and recommendation functionalities on the host platform. By utilizing vectorized representations of products/contents, rather than directly sharing sensitive information, we maintain a privacy-enhancing approach. This method allows for effective personalization while minimizing the exposure of personal data.

By adopting these privacy-enhancing measures, we aim to provide a personalized user experience while respecting your privacy and minimizing the collection, processing, and storage of personal data. We are committed to transparency and maintaining the trust you place in us by prioritizing your privacy throughout our operations.

  1. Responsibilities of the Host platforms and Social Networks
  2. Host Platforms

By integrating with FirstBatch, the host platform enables users to enhance their experience by providing personalized recommendations, tailored content, and customized features based on the user's interests. The host platform collaborates with FirstBatch to facilitate the processing of public profile data and the transfer of interest vectors, enabling a more personalized and engaging user experience.

The host platform, where the user logs in and is given the option to personalize their experience using FirstBatch, has specific responsibilities regarding obtaining necessary consent and acting as a data controller:

Consent Collection: The host platform is responsible for obtaining the your consent to connect your social media handle and initiate the processing activities carried out by FirstBatch. The platform should clearly present the option to personalize the user experience and provide information on the data processing activities involved.

Privacy Policy: The host platform should have a comprehensive and transparent privacy policy in place that outlines the processing activities associated with personalized experiences, including the involvement of FirstBatch. The privacy policy should explain the purpose of data processing, the types of data involved, and the third-party services utilized, such as Pinecone DB. You should have access to this policy and be able to review it before granting your consent.

Data Controller Role: As the platform offering the personalized experience, the host platform acts as a data controller for the personal data processed in connection with FirstBatch (i.e., User ID). This means that the platform determines the purposes and means of processing the data collected from users, including the resulting vectors transferred from FirstBatch. As a data controller, the host platform is responsible for complying with applicable data protection laws.

  1. Social Networks

As the social media platform through which the user's public profile data is accessed by FirstBatch, also has responsibilities regarding consent and its data controller role:

Authentication and Consent: When you are redirected to a social media platform, for example, Twitter, for authentication and processing activities, Twitter is responsible for obtaining the your consent for the processing activities performed by FirstBatch. Twitter should present clear information about the purpose and extent of data processing and provide you with the opportunity to grant or deny consent. The consent process should align with applicable data protection laws and guidelines.

Privacy Policy and Terms of Service: Twitter should have a comprehensive and transparent privacy policy and terms of service that outline how user data is processed and shared with FirstBatch. You should have access to these policies and be able to review them before granting consent.

Data Controller Role: As the platform hosting the user's public profile data, Twitter acts as a data controller for this information. Twitter determines the purposes and means of processing the public profile data, including the authentication and subsequent processing performed by FirstBatch. Twitter is responsible for compliance with data protection laws, ensuring user privacy, and implementing appropriate security measures to protect the personal data of its users.

  1. European Union and UK Privacy Information

Your Rights and Choices Under the UK & EU GDPR

FirstBatch undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the UK or EU, to:

  • Right to Access: You have the right to access your personal data, including information about the categories of data held, the purpose and period of processing, and any recipients of the data.
  • Right to Rectification: You have the right to request the correction or updating of your personal data if it is inaccurate or incomplete.
  • Right to Erasure (Right to be Forgotten”): In certain cases, you have the right to request from us the erasure of your personal data such as when you want to delete your account. For the avoidance of any doubt, we may not be able to grant this right to you in certain cases, due to our obligations to fulfill certain legal requirements.
  • Right to Restriction of Processing: You have the right to request from us restriction of processing, for a certain period or in certain situations.
  • Right to Data Portability: You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means. You have the right to receive your personal data from us in a structured format and you have the right to (let) transmit such personal data to another controller.
  • Right to Object: In certain cases, you have the right to object to the processing of your personal data, including with regards to profiling or direct marketing.
  • Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing if such decisions significantly affect you.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant data protection supervisory authority, such as the Irish Data Protection Commissioner or the UK Information Commissioner's Office if you are unhappy with the way we are handling your personal data.
  • Right to Compensation of Damages: In case we breach applicable legislation on the processing of your personal data, you have the right to claim damages from us for any damages such breach may cause to you.

Exercising of Your UK & EU GDPR Privacy Rights

You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. If You are a resident of United Kingdom, You may complain to Information Commissioner’s Office (ICO) regarding your data protection rights. If you are a resident in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

  1. How FirstBatch Protects Your Personal Data

We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your personal data. We employ organizational, technical, and administrative measures designed to appropriately protect your personal data against unauthorized access, destruction, accidental loss, unauthorized alteration, or abuse. If you have a reason to believe that your interaction with us is no longer secure (for example, if you think your social media account is compromised), please contact us immediately.

  1. Retention of Personal Data

FirstBatch retains personal data processed for the purpose of generating embeddings and providing personalized experiences for a limited period of time. The retention period is determined based on the following considerations:

Purpose Limitation: FirstBatch retains personal data only for as long as it is necessary to fulfill the purpose for which it was collected. FirstBatch does not store personal data beyond the processing required to generate embeddings and provide personalized experiences. Instead, FirstBatch initiates the processing activities whenever a user makes a personalization request. This approach ensures that personal data is not retained unnecessarily and minimizes the potential risks associated with data storage.

Upon receiving a personalization request, FirstBatch processes the user's public profile data to generate embeddings and interest vectors. These vectors are then used to personalize the user experience on the host platform. FirstBatch does not retain the original social media profile data or the generated vectors after the personalized experience has been provided.

By adopting this approach, FirstBatch prioritizes user privacy and data minimization. Each personalization request triggers a fresh processing activity, eliminating the need for long-term data retention. This ensures that personal data is processed on-demand and not stored beyond its immediate use, reducing the overall data footprint and enhancing privacy protection.

User Control: Users have the ability to withdraw their consent and request the deletion of their personal data processed by FirstBatch. If you revoke your consent or request the deletion of your personal data, we will delete the vectorized data associated with your User ID from the host platform's backend, unless there are legitimate overriding legal or contractual obligations that require the data to be retained.

You have the right to revoke your consent at any time by adjusting your privacy settings on the compatible platform or contacting us directly. Please note that revoking consent may limit or impact your personalized experience.

Legal Obligations: FirstBatch retains personal data in relation to data subject requests for as long as necessary to comply with legal obligations imposed by the GDPR. This may include retaining certain data for purposes such as fulfilling legal requirements, defending legal claims, or conducting audits.

Data Minimization: FirstBatch follows a data minimization principle, ensuring that it only retains the personal data necessary to achieve the specified purposes. Non-relevant or excessive personal data is not being processed.

It is important to note that while FirstBatch strives to maintain the accuracy and relevance of the personal data it processes, users are encouraged to update or correct their public profile data directly on the respective social media platforms. FirstBatch's processing activities are based on the data available at the time of processing, and any subsequent changes made by users on their social media profiles may not be reflected immediately in the embeddings and vectors generated by FirstBatch.

By adhering to these retention practices, FirstBatch aims to respect user privacy, fulfill legal obligations, and ensure the appropriate management of personal data throughout its lifecycle.

  1. International Data Transfers

Your personal data will be processed by us in the European Economic Area (EEA) ?

  1. Use by Minors

Our services are not directed to individuals under the age of eighteen (18), and they shall not provide personal data through our services. If you have reason to believe that anyone under the age of 18 has provided us with any personal data, please contact us.

  1. Updates to this Policy and Notifications

We may change this Policy from time to time to in response to changing legal, technical or business developments. Any changes are effective when we post the revised Policy. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by GDPR. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

  1. Jurisdiction

FirstBatch focuses on GDPR to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country's laws.

  1. 17. Contact FirstBatch

If you have any questions or complaints about this Policy, or if you wish to exercise your rights under applicable data protection laws, please feel free to contact us by;

  • Sending us an email at
  • Writing to as at FirstBatch ### ATTN: Privacy, ###

By using FirstBatch or choosing to personalize your experience, you signify your acceptance of this Privacy Policy. If you do not agree with this Privacy Policy, please do not use FirstBatch or opt-out of personalization on compatible host platforms.

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