Privacy policy


January 1, 2020


Introduction.


FIRST-HOLD (“FIRST-HOLD,” “we,” “our,” or “us”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personal information we obtain from users of our website, www.first-hold.com (“Site”).


FIRST-HOLD is defined as the network of websites and services that are owned and operated by FIRST-HOLD and its subsidiaries, which includes the Venue Listings, and does not include the websites of any of FIRST-HOLD’s participating Venues accessed from the Venue Listings via links. Unless otherwise noted on the Site, each site included within FIRST-HOLD that links to this Privacy Policy is governed by this Privacy Policy.


Our Privacy Policy outlines the types of information we collect and receive from you while you are visiting the Site and using the Service, as well as ways in which we process and, sometimes, share such information and how you can correct or change such information.


IF YOU WISH TO RESERVE A VENUE OR A FACILITY MADE AVAILABLE BY A PARTICIPATING VENUE MANAGER, ANY INFORMATION THAT YOU PROVIDE DIRECTLY TO A PARTICIPATING VENUE MANAGER OUTSIDE OF THE SITE WILL BE GOVERNED BY THE TERMS AND CONDITIONS OF THAT PARTICIPATING VENUE MANAGER’S OWN PRIVACY POLICY. PLEASE REFER TO THE PRIVACY POLICY OF THAT PARTICIPATING VENUE MANAGER TO DETERMINE HOW THAT PARTICIPATING VENUE MANAGER USES THE INFORMATION THAT YOU PROVIDE TO IT.


1. How FIRST-HOLD Collects “User Information”.


A. Personal Information is any information that can be used to identify a specific individual, such as your name, email address, home address, and phone number. FIRST-HOLD asks you to provide such personal data to it in various places throughout the Site.


In addition, we may ask that you provide FIRST-HOLD with additional information about you and/or your personal preferences, including, for example, marital status, household income, education and employment status, or how often you plan events, details about the types of facilities or venues you prefer to host your events, how you choose a venue, etc.


Some of these areas where the collection of such information takes place are listed below.


User Registration and Online Forms:


In order to use many of FIRST-HOLD's features, tools and services, we ask you to register for a Venue or a Facility or ask you to register for an account with your own username and password. During this User registration process, we ask you for certain Personal Information. If you have contact us through online forms available on our Site, we ask for certain Personal Information to allow us to respond to your inquiry or communication.


By using the Service or registering as a User of the FIRST-HOLD Service, you agree that FIRSTHOLD may provide to you information about Venues and Facilities offered by participating Venue Managers for you to review.


Surveys, Polls and Questionnaires:


FIRST-HOLD may offer to you via e-mail online surveys and questionnaires that ask you for Personal Information such as your opinion on various issues and feedback on any Venues or Facilities that you have reserved, including the hold process and any booked and completed events at Venues or Facilities. Occasionally, we request Personal Information such as demographic information (like zip code, age or gender) when you answer a survey. Such surveys are voluntary.


B. “Web Activity Information” gathered by FIRST-HOLD and its third-party service providers


When you visit the Site and interact with the services and tools that reside there, FIRST-HOLD collectsinformation on your actions at the Site or “Web Activity Information.” In doing so, FIRSTHOLD may utilize the services of certain third party service providers.


This type of Web Activity Information is generally collected from two sources. One is from the server log files and the other is from cookies. 


  •  IP Address 

Your IP address is a number that is assigned by your ISP (Internet Service Provider) to your computer to identify its location. We use your IP address to help diagnose problems with our server and to administer our Site. We also sometimes use IP addresses to communicate with Users and possibly even ban those Users who are not complying with our FIRST-HOLD Agreement FIRST-HOLD Agreement or disable cookies for certain Planners or Users located outside the United States. 


  • Cookies 

Our Site may use a feature of your browser to set a "cookie" on your computer (however, this feature may be disabled in certain circumstances for Planners or Users located outside of the United States). Cookies are small packets of information that a site's computer stores on your computer. FIRST-HOLD can then read the cookies whenever you visit the Site. We use cookies to save your password so you don't have to re-enter it each time you visit our Site, to deliver content specific to your interests, to track the pages you've visited, and to make sure you don't see the same ads repeatedly. These cookies allow us to use the Web Activity Information we collect to customize your FIRST-HOLD experience so that your visit to the Site is as relevant and as valuable to you as possible. 

You may modify your browser preference to provide you with choices relating to cookies. You have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies.


If cookies have been disabled for you or you choose to reject cookies, you may be unable to use that part of the Service that requires registration in order to participate or will have to sign in each time you visit the Site. 


C. Other Information We Separately Collect 


From time to time, we also purchase certain marketing data in order to verify your household information that you provide to us by zip code. We obtain this information so that we may better serve you with respect to offering to you information about the Venues or Facilities from the participating Venue Managers. 


D. Online Tracking 


FIRST-HOLD does not use or record any information about Users as they view and move across third-party websites. 



2. Guidelines Regarding Children. 


FIRST-HOLD does not encourage participation or visitation by children. 


3. How FIRST-HOLD Works and How FIRST-HOLD uses the “User Information” it collects. 


FIRST-HOLD uses the Personal Information and Web Activity Information you provide for several purposes, such as to communicate with you and to give you a better experience when visiting the Site by personalizing tools, content, services and email messages. FIRST-HOLD also uses this “User Information” to build new services and develop Venues or Facilities that FIRSTHOLD believes are relevant and valuable to you. 


More specifically, when you register with FIRST-HOLD and provide us with Personal Information, we provide you with information about Venues or Facilities that have been provided to us by our participating Venue Managers. You may select from these Venues or Facilities and inquire as to whether certain Venues or Facilities may be made available to you. Our participating Venue Managers will receive Personal Information about you from us in order to determine what Venues or Facilities are available to you. If you reserve a Venue or Facility, FIRST-HOLD will provide your name and e-mail address to the participating Venue Manager that offers the Venue or Facility. The participating Venue Manager will then contact you directly and may request additional Personal Information, including your credit card information, directly from you in order for you to actually confirm the Reservation. We may use and share information that has been deidentified or aggregated without limitation. 


We do not use automatic decision-making (i.e., making decisions solely by automated means without any human involvement) or profiling (i.e., automated processing of personal information to evaluate certain aspects of an individual).


Where we intend to process your User Information for a purpose other than the purpose for which it was collected, we will provide you with information regarding the purpose for the processing, as well as other relevant information, prior to processing your User Information for the new purpose. 


4. Your Opt-In for Disclosure of “User Information” to Certain Third Parties.


FIRST-HOLD does not sell or otherwise share any User Information with unaffiliated third parties without your consent (Please see “FIRST-HOLD’s Opt-In/Opt-Out Policy” below), except in the following instances: 


(i) disclosure of your Personal Information to participating Venue Managers in order for participating Venue Managers to determine what Venues or Facilities are available to you; 


(ii) disclosure of your name and e-mail address and other identifying information to participating Venue Managers when you confirm that you would like to reserve a Venue or a Facility; 


(iii) disclosure as required by applicable law or pursuant to a court or similar order; 


(iv) as deemed necessary, in FIRST-HOLD's discretion, to protect the legal rights or the property of FIRST-HOLD, a User or third party, or to prevent personal injury; and/or 


(v) in the event of a sale, merger, assignment, joint venture or other transfer or disposition of a portion or all of the assets or stock of FIRST-HOLD or its affiliated entities (including, without limitation, in connection with any bankruptcy or similar proceedings). 


In addition, FIRST-HOLD may provide Personal Information to third parties who are providing technical or fulfillment services on behalf of FIRST-HOLD when such disclosure is required in order to provide those services, provided that such third parties agree to be bound by FIRSTHOLD's Privacy Policy. 


FIRST-HOLD also reserves the right to share any User Information which you provide to (or which is gathered from) FIRST-HOLD with any or all of its subsidiaries and affiliates (collectively, our "Affiliates") (subject to the “opt-out” right described in FIRST-HOLD’s OptIn/Opt-Out Policy below, with respect to disclosures of User Information to Affiliates for their direct marketing uses). FIRST-HOLD will also have access to any information you provide to (or which is gathered from) the web sites of any of our Affiliates. 


In each of the instances described above, you have provided your consent under the terms of this Privacy Policy for FIRST-HOLD to share your Personal Information with the third-parties that are described above. In particular, if FIRST-HOLD discloses your name and e-mail address to participating Venue Managers when you confirm that you would like to reserve a Venue or  Facility, the participating Venue Manager may then contact you about the Venue or Facility. Please see FIRST-HOLD’s Opt-In/Opt-Out Policy below to see your ability to exercise a cost free right to opt out of FIRST-HOLD’s sharing of your personal information with Venue Managers and Affiliates. 


5. International Visitors 


This section applies to those that visit our Site from the European Economic Area or Switzerland. 


FIRST-HOLD processes Personal Information with your consent (e.g., FIRST-HOLD processes personal information to provide goods and services you request). 


On other occasions, FIRST-HOLD may process Personal Information when it needs to do this to fulfill a contract (e.g., to fulfill the contractual obligations we have with our clients) or where required to do this by law. 


If necessary, FIRST-HOLD may also process Personal Information when it is in FIRST-HOLD’s legitimate interests to do this (e.g., for customer service) and when these interests are not overridden by your data protection rights. You have a right to the following: 


  • To request access to the Personal Information we hold about you; 
  • To request that we rectify or erase your Personal Information; 
  • To request that we restrict or block the processing of your Personal Information;
  • Under certain circumstances, to receive Personal Information about you that we store and transmit to another without hindrance from us, including requesting that we provide your Personal Information directly to another, i.e., a right to data portability; and 
  • Where we previously obtained your consent, to withdraw consent to processing your Personal Information. 


To exercise these rights, contact [“our Data Protection Officer” or “us”] using the “Contact Information” section below. Please be aware that FIRST-HOLD may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. 


Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence.


 6. Retention 


We will process and store your information only for the period necessary to achieve the purpose of the storage, or as permitted by law. The criteria used to determine the period of storage of information is the respective statutory retention period or one calendar year. After expiration of that period, the corresponding information is