Privacy Policy

1. Who We Are

First Page Digital Solutions Limited trades as First Page Digital. We are a company registered in Ireland (CRO No: 726197, VAT No: IE4059389CH) and provide services to businesses in both Ireland and New Zealand.

We are the data controller responsible for the personal information we collect through our own website and business activities, as described in Section 2. Where we process personal information on behalf of a client as part of a service, the client is generally the data controller and we act as their data processor or service provider.

2. Our Role When Processing Personal Information

Our role depends on the relationship and the context in which the information is processed.

First Page Digital as Data Controller

We generally act as the Data Controller where we determine the purposes and means of processing personal information. This includes information relating to:

• visitors to our own website;
• enquiries made to us;
• prospective clients;
• existing clients;
• consultations and audits;
• marketing communications we send;
• suppliers; and
• business contacts.

In these situations, we are responsible for that information in accordance with this Privacy Policy and applicable data protection law.

First Page Digital as Data Processor / Service Provider

We may act as a Data Processor or service provider when we process personal information on behalf of our clients through services such as websites, CRM, forms, automation, email, AI Chat and AI Voice.

In these situations, our client is generally the Data Controller and is responsible for that information. We process it on their instructions and in accordance with our agreement with them. If you have interacted with one of our clients through a service we provide, please see Section 17.

3. Information We May Collect

The types of personal information we may collect include:

• name;
• business name;
• email address;
• phone number;
• billing and company details;
• information you provide through forms, enquiries or onboarding;
• communications between us;
• website usage data, such as pages visited, device type, browser and approximate location; and
• information processed on behalf of clients through the services we provide, such as enquiry details, messages, appointment information and conversation records.

4. How We Collect Personal Information

We collect personal information in a number of ways:

• Directly from you when you contact us, complete a form, request an audit, subscribe, or complete an intake or onboarding questionnaire.
• Automatically when you visit our website, through cookies and similar technologies (see Section 8).
• Through our services when we process information on behalf of a client, such as enquiries, messages and conversations handled through websites, forms, CRM, booking, chat or voice tools.
• From third parties where permitted, such as where a client provides information to us for the purpose of delivering a service.

5. How We Use Personal Information

Where we act as Data Controller, we may use personal information to:

• respond to enquiries and requests;
• provide consultations, audits and proposals;
• deliver and manage our services to clients;
• communicate with you about our services;
• send marketing communications where permitted;
• process billing and payments;
• improve our website, services and customer experience;
• maintain records and comply with legal obligations.

Where we act as Data Processor, we process personal information on behalf of and on the instructions of our client, in accordance with our agreement with them.

6. Our Legal Bases for Processing

Where the GDPR applies, we rely on the following legal bases:

• Consent where you have given consent for a specific purpose.
• Performance of a contract where processing is necessary to provide a service you have requested.
• Legal obligation where we are required to process information to comply with the law.
• Legitimate interests where we have a legitimate reason to process information in a way that is reasonable and does not override your rights.

Where the New Zealand Privacy Act 2020 applies, we collect and use personal information for the purposes described in this policy and in accordance with the Information Privacy Principles.

7. Marketing Communications

We may send marketing communications where permitted by applicable law. You can unsubscribe at any time using the link in any email we send, or by contacting us at hello@firstpagedigital.ie.

We will not send marketing communications where you have opted out or where the law does not permit it.

8. Cookies, Analytics and Advertising

We use cookies and similar technologies on our own website. Some are essential for the site to function. Others, such as analytics and advertising cookies, are only activated with your consent.

For details of the specific technologies currently in use and to manage your preferences at any time, please see our Cookie Policy and the cookie consent controls available on our website.

9. Our Technology Providers

We use trusted technology providers to help deliver our services. The principal platform supporting relevant First Page Digital services, including CRM, websites, forms, workflows, communications, calendars and AI functionality, is HighLevel.

Where SMS services are separately activated, the following providers may be used:

• ClickSend / Sinch for applicable Irish SMS services.
• TNZ Group Limited for applicable New Zealand SMS services.

These SMS providers are not necessarily used for every client. SMS is an optional or separate service and is not included as standard within Ignite Core in Ireland.

We take reasonable steps to ensure our providers process personal information appropriately and in accordance with applicable law.

10. Artificial Intelligence

AI-enabled functionality supplied through Ignite is delivered through the HighLevel platform. This may include AI Chat, AI Voice, enquiry handling, lead qualification, communication assistance, summarisation and workflow assistance.

Where AI functionality is used on behalf of a client, the client is generally the Data Controller and we act as their Data Processor. AI providers are engaged as authorised downstream technology providers used by HighLevel, rather than as our direct processors.

We take steps to ensure AI functionality is used responsibly and in line with applicable law, including the EU AI Act and ePrivacy requirements where relevant. For more information, see our AI Compliance & Ethics page.

11. Sharing Personal Information

Where we act as Data Controller, we may share personal information with:

• technology providers we use to deliver our services;
• professional advisers where necessary;
• authorities where required by law or to protect our rights; and
• successors in the event of a sale, merger or reorganisation of our business.

Where we act as Data Processor, we share personal information with providers only as instructed by our client and as necessary to deliver the service.

12. International Processing

We provide services to businesses in Ireland and New Zealand, and our technology providers may process personal information outside of those countries.

Where the GDPR applies, we use appropriate transfer mechanisms where required, including applicable adequacy decisions, Standard Contractual Clauses or another legally recognised mechanism.

For New Zealand, we take account of applicable New Zealand privacy requirements, including Information Privacy Principle 12 where relevant, when personal information is disclosed overseas.

13. How Long We Keep Personal Information

We keep personal information only for as long as is necessary for the purposes described in this policy, to comply with legal obligations, to resolve disputes and to enforce our agreements.

Where we act as Data Processor, retention is generally determined by our agreement with the client and the client's instructions.

14. Security

We take reasonable steps to protect personal information using appropriate technical and organisational measures. However, no method of transmission or electronic storage is completely secure, and we cannot guarantee absolute security.

15. Your Rights — Ireland and EEA

If you are in Ireland or the EEA, you have the following rights under the GDPR in relation to personal information where we act as Data Controller:

• the right to be informed;
• the right of access;
• the right to rectification;
• the right to erasure;
• the right to restrict processing;
• the right to data portability;
• the right to object;
• the right to withdraw consent at any time; and
• rights relating to certain solely automated decision-making and profiling where applicable.

You also have the right to lodge a complaint with the Data Protection Commission in Ireland or your local data protection authority.

16. Your Rights — New Zealand

If you are in New Zealand, you have rights under the Privacy Act 2020 in relation to personal information where we act as an agency, including:

• the right to request access to personal information we hold about you;
• the right to request correction of personal information you believe is inaccurate, incomplete or misleading;
• where a requested correction is not made, the right to request that a statement of correction is attached to the information where applicable; and
• the right to complain to the Office of the Privacy Commissioner about our handling of your personal information.

17. Requests Concerning a First Page Digital Client

If you have interacted with one of our clients through a service we provide, such as a website, CRM, booking system, chatbot or similar tool, that client business is generally responsible for your information and is the Data Controller.

In that situation, you should normally contact the client business first. We will assist the client where required and will respond to requests in accordance with our agreement with the client and applicable law.

18. Children

Our services are directed at businesses rather than children. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to remove it.

19. External Websites and Services

Our website and services may contain links to or integrations with third-party websites and services. We are not responsible for the privacy practices or content of those external sites. We encourage you to review their privacy policies.

20. Privacy Complaints

If you have a concern about how we handle personal information, please contact us using the details in Section 22. We will investigate and respond to your concern.

You also have the right to complain to the relevant regulator: the Data Protection Commission in Ireland, or the Office of the Privacy Commissioner in New Zealand.

21. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will update the "Last updated" date at the top of this page when we do. We encourage you to review this policy periodically.

22. Contact Us

If you have any questions about this Privacy Policy or how we handle personal information, please contact us:

• First Page Digital Solutions Limited
  Trading as First Page Digital
  CRO No: 726197
  VAT No: IE4059389CH
  Ireland
• Email: hello@firstpagedigital.ie
• Website: firstpagedigital.ie