Owner and Data Controller
U-First S.r.l. - Via Giovanni Amendola, 46 - 00185 Roma RM (Italia) - P.IVA 12753241004
Owner contact email: admin@ufirst.com
Types of Data collected
Among the types of Personal Data that www.ufirst.com collects, by itself or through third parties, there are:
Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address; username; phone number.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using www.ufirst.com.
Unless specified otherwise, all Data requested by www.ufirst.com is mandatory and failure to provide this Data may make it impossible for www.ufirst.com to provide its services. In cases where www.ufirst.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by www.ufirst.com or by the owners of third-party services used by www.ufirst.com serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through www.ufirst.com.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of www.ufirst.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Access to third-party accounts, Analytics, Remarketing and behavioral targeting, Registration and authentication, Managing contacts and sending messages, Social features, Hosting and backend infrastructure, Handling payments, Contacting the User, Advertising, Tag Management and User database management.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Facebook permissions asked by www.ufirst.com
Www.ufirst.com may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows www.ufirst.com to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows www.ufirst.com to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows www.ufirst.com to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me.
Place of processing: United States – Privacy Policy.
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on www.ufirst.com, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside www.ufirst.com. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Facebook Audience Network (Facebook Ireland Ltd)
Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd In order to understand Facebook's use of Data, consult Facebook's data policy.
Www.ufirst.com may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.
Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Lookalike Audience (Facebook Ireland Ltd)
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook Ireland Ltd that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of www.ufirst.com or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Ad Manager (Google Ireland Limited)
Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of www.ufirst.com and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of www.ufirst.com, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for www.ufirst.com (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google Ireland Limited)
Google Analytics on www.ufirst.com has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics) with anonymized IP (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of www.ufirst.com, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
User ID extension for Google Analytics (Google Ireland Limited)
Google Analytics on www.ufirst.com makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by www.ufirst.com.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Cookies.
Place of processing: Ireland – Privacy Policy – Opt Out.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
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Contacting the User
Feedback collection with Trustpilot
The Data Controller may contact the Users via email to invite them to review any services and/or products they received from the Data Controller in order to collect their feedback and improve its services and products (the “Purpose”). The Data Controller use an external company, Trustpilot A/S (“Trustpilot”), to collect their feedback which means that it will share your name, email address and reference number with Trustpilot for the Purpose. If the Users want to read more about how Trustpilot process your data, they can find their Privacy Policy at the following link: https://uk.legal.trustpilot.com/end-user-privacy-terms. The Data Controller may also use such reviews in other promotional material and media for its advertising and promotional purposes.
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Handling payments
Payment processing services enable www.ufirst.com to process payments by credit card, bank transfer or other means. To ensure greater security, www.ufirst.com shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Braintree (PayPal (Europe) S.a.r.l. et Cie, S.C.A.)
Braintree is a payment service provided by Braintree, a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Braintree privacy policy – Privacy Policy.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable www.ufirst.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of www.ufirst.com.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Firebase Cloud Functions (Google Ireland Limited)
Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Firebase Hosting (Google Ireland Limited)
Firebase Hosting is a hosting service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Firebase Cloud Messaging (Google Ireland Limited)
Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow www.ufirst.com to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, www.ufirst.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Firebase Authentication (Google Ireland Limited)
Firebase Authentication is a registration and authentication service provided by Google Ireland Limited.
To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; username.
Place of processing: Ireland – Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows www.ufirst.com and its partners to inform, optimize and serve advertising based on past use of www.ufirst.com by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Google Signals (Google Ireland Limited)
Www.ufirst.com uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from www.ufirst.com with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of www.ufirst.com with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook Ireland Ltd)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of www.ufirst.com with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Social features
Firebase Dynamic Links (Google Ireland Limited)
Firebase Dynamic Links is a social feature provided by Google Ireland Limited.
Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within www.ufirst.com.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on www.ufirst.com in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker.
Place of processing: Ireland – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to www.ufirst.com, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving www.ufirst.com.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on www.ufirst.com.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Cookie Policy
Www.ufirst.com uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of www.ufirst.com or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, www.ufirst.com may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, www.ufirst.com and any third-party services may collect files that record interaction with www.ufirst.com (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within www.ufirst.com and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through www.ufirst.com (or third-party services employed in www.ufirst.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use www.ufirst.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using www.ufirst.com who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of www.ufirst.com. The Data Controller, unless otherwise specified, is the Owner of www.ufirst.com.
www.ufirst.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by www.ufirst.com as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to www.ufirst.com, if not stated otherwise within this document.