Website Privacy Policy

Applies to: facilityfirst.com

Related terms: Website Terms and Conditions; Code of Ethics

1. Scope of This Policy

1.1 Facility First, Inc. (“Facility First,” “we,” “us” or “our”) is a facility maintenance and repair program management company headquartered at 407 Lincoln Road, Miami Beach, FL 33139. This Privacy Policy describes how Facility First collects, uses, discloses and protects personal information obtained through the website located at facilityfirst.com, including its pages in languages other than English (the “Website”).

1.2 This Policy also applies to personal information a person provides when contacting Facility First by email or telephone using contact details published on the Website, to the extent the information relates to an inquiry or request.

1.3 This Policy does not govern information Facility First collects from clients, Service Providers, employees or job applicants through separate business, employment or operational channels, including service requests and work orders submitted through the client or Service Provider login, information exchanged under a Service Agreement or Service Provider Agreement, and job applications submitted through third-party job platforms linked from the Website. Those activities are subject to separate privacy notices, agreements and policies, and job platforms process applications under their own terms and privacy policies. In this Policy, “Service Provider” means an independent local contractor that Facility First engages to perform maintenance, repair or other trade work at client facilities, and “Service Agreement” and “Service Provider Agreement” have the meanings given in the Website Terms and Conditions.

1.4 Facility First, Inc. is responsible for the personal information collected through the Website. Where a law uses terms such as “controller,” “business” or “person carrying on an enterprise,” that term refers to Facility First for purposes of this Policy.

1.5 Use of the Website constitutes acknowledgment of the practices described in this Policy. This Policy should be read together with the Website Terms and Conditions.

2. Information Collected

2.1 Information provided by visitors

When a visitor submits an inquiry or proposal request through a Website form, Facility First may collect:

• name, company name and job title;
• work email address and telephone number;
• the number of locations, the countries or states, the industry, the services and trades needed, and the current maintenance arrangements described, including any current provider the visitor chooses to mention; and
• any other information the visitor chooses to include.

When a business applies through the Website to join the Service Provider network, Facility First may collect:

• company name, contact name, job title, work email address, telephone number and website;
• the trades and markets served, licenses held, number of technicians and availability; and
• any other information the applicant chooses to include.

Visitors should not submit Social Security numbers, financial account information, government identification numbers, health information, alarm or access codes or other sensitive personal information through Website forms. Facility First does not use Website forms to collect payment card information or identification documents.

Website forms are not monitored for emergencies. Clients must submit service requests, including urgent requests, through the channels set out in their Service Agreement. In an emergency involving a risk to life, health or property, contact 911 or local emergency services.

2.2 Information collected automatically

When a visitor uses the Website or submits a form, Facility First’s systems and service providers may automatically record:

• Internet Protocol (IP) address and approximate location derived from it;
• browser type, device type and operating system;
• pages viewed, the referring page and the date and time of each visit; and
• interactions such as clicks on telephone, email and proposal request links, and form submissions.

Security and bot-protection services that protect the Website may also process IP addresses, browser characteristics and request details to detect and block malicious or automated traffic.

3. How Information Is Used

3.1 Facility First uses information collected through the Website for legitimate business purposes, including to:

1. respond to inquiries and requests for information;
2. provide service information, proposals and quotations;
3. review applications to join the Service Provider network, including verifying business registration, licenses and insurance, and communicate with applicants about the network;
4. follow up about Facility First’s services;
5. communicate with prospective and existing business contacts;
6. evaluate business opportunities and service requirements;
7. maintain records of inquiries, applications and communications;
8. measure Website traffic and improve Website content and performance;
9. protect the security of the Website and detect and prevent spam, fraud and unauthorized activity; and
10. comply with applicable legal, tax and regulatory obligations.

3.2 Facility First does not sell personal information collected through the Website, does not share it for cross-context behavioral advertising and does not use it to serve targeted advertising.

3.3 Facility First does not use personal information collected through the Website to make decisions based solely on automated processing that produce legal or similarly significant effects for the visitor.

4. How Information Is Shared

4.1 Service providers. Facility First uses service providers to host and secure the Website, store form submissions, deliver email and measure Website traffic. These providers process information on Facility First’s behalf and only as necessary to perform their services, subject to contractual and legal obligations. In this Policy, “service providers” (lowercase) means vendors that support the Website and does not refer to Service Providers in the Facility First network.

4.2 Security services. Security services in Facility First programs are provided by McCray Global Protection Corp., a separate company. When a visitor requests security services or describes security needs in an inquiry, Facility First may share the inquiry with McCray Global Protection Corp. so that it can respond. McCray Global Protection Corp. handles that information under its own privacy policy.

4.3 Service Providers. Facility First may share the locations and service needs described in an inquiry with Service Providers when needed to prepare a proposal or quotation.

4.4 Legal requirements and protection. Facility First may disclose information when reasonably necessary to:

1. comply with applicable law, regulation or legal process;
2. respond to valid subpoenas, court orders or government requests;
3. protect the rights, property, safety or security of Facility First, its clients, its Service Providers, its personnel or others; or
4. investigate suspected fraud, unauthorized activity or violations of law.

4.5 Business transactions. If Facility First is involved in a merger, acquisition, restructuring, financing or sale of assets, personal information may be transferred as part of that transaction, subject to applicable privacy requirements.

4.6 Facility First does not disclose personal information to third parties for their own advertising or marketing purposes.

5. Cookies, Analytics and Similar Technologies

5.1 Necessary technologies. The Website uses technologies that are necessary to operate and protect it, such as storing a visitor’s cookie choice in the browser and security tools that distinguish human visitors from automated traffic. These technologies do not require consent.

5.2 The Website does not currently use analytics or advertising cookies. If Facility First adds analytics in the future, they will be activated only after a visitor selects Accept in the cookie banner, and this Policy will be updated before they are used.

5.3 Global Privacy Control and Do Not Track. When a visitor’s browser sends a Global Privacy Control signal, the Website treats it as a choice to decline optional cookies. There is no common industry standard for “Do Not Track” browser signals, so the Website does not respond to them.

5.4 Advertising. The Website does not use advertising cookies, and Facility First does not use Website analytics information for targeted advertising.

5.5 Third-party sites. The Website may link to third-party websites and platforms, including the McCray Global Protection website, government sites, job platforms, and professional networking and social media services such as LinkedIn. Their privacy policies and terms govern their collection and use of information. Facility First is not responsible for their privacy practices, security or content.

6. Data Retention

6.1 Facility First retains personal information collected through the Website only as long as reasonably necessary for the purposes described in this Policy. As a general guideline:

1. general inquiries and contact submissions may be retained for up to three years;
2. business inquiries associated with prospective or existing client relationships may be retained for the duration of the relationship and a reasonable period afterward; and
3. Service Provider applications that do not result in an engagement may be retained for up to three years, and applications from engaged Service Providers may be retained for the duration of the relationship and a reasonable period afterward.

6.2 Information may be retained longer when required to comply with legal obligations, resolve disputes, enforce agreements, or establish, exercise or defend legal claims. When information is no longer reasonably necessary, Facility First takes appropriate steps to delete, destroy or anonymize it, subject to applicable legal and operational requirements.

7. Information Security

7.1 Facility First uses reasonable administrative, technical and organizational safeguards designed to protect personal information collected through the Website against unauthorized access, disclosure, alteration or destruction. These measures include encrypted connections (HTTPS), access controls, administrative restrictions and security monitoring of the Website.

7.2 No method of electronic transmission or storage is completely secure. Although Facility First takes reasonable steps to protect personal information, it cannot guarantee absolute security.

8. Privacy Rights

8.1 Depending on location and applicable law, visitors may have rights regarding personal information collected through the Website, including the right to:

1. request access to personal information Facility First maintains about them;
2. request correction of inaccurate personal information;
3. request deletion of personal information, subject to applicable exceptions;
4. request a copy of certain personal information in a portable format;
5. withdraw consent where processing is based on consent, without affecting processing that took place before the withdrawal;
6. object to or restrict certain processing, including processing for direct marketing; and
7. file a complaint with a data protection or privacy authority.

8.2 Requests may be submitted by email to legal@mccraygp.com or by telephone at (833) 832-6647. Facility First may need to verify the requester’s identity before responding and will respond within the time required by applicable law. An authorized agent may submit a request on a person’s behalf with written permission signed by that person, and Facility First may ask the person to verify his or her identity directly. Certain requests may be subject to legal exceptions or limitations.

8.3 If Facility First declines a request, the requester may appeal by replying to Facility First’s response and stating that he or she is appealing the decision. Facility First will review the appeal and respond within the time required by applicable law.

8.4 Facility First will not discriminate or retaliate against anyone for exercising privacy rights.

9. U.S. State Privacy Rights

9.1 Residents of certain U.S. states may have additional rights under state privacy laws. Depending on the applicable law and whether Facility First is subject to it, these may include the right to know, access, correct and delete personal information; to obtain a portable copy; to opt out of the sale of personal information, targeted advertising or certain profiling; and to appeal a decision on a privacy request. The availability and scope of these rights depend on applicable law, including applicability thresholds and exemptions. Qualifying requests will be handled in accordance with applicable law.

9.2 California. To the extent the California Consumer Privacy Act applies to Facility First, the following information is provided for California residents. In the preceding 12 months, Facility First collected the following categories of personal information through the Website: identifiers (such as name, email address, telephone number and IP address); professional information (such as company name, job title, trades, licenses and insurance information); commercial information (such as the services requested); internet or other electronic network activity (such as pages viewed and interactions with the Website); and approximate geolocation derived from IP addresses. Facility First collects this information from visitors directly and automatically from their devices, uses it for the purposes described in Section 3, discloses it for business purposes to the categories of service providers described in Section 4.1 and, at a visitor’s direction, to the recipients described in Sections 4.2 and 4.3, and retains it as described in Section 6. Facility First does not sell or share personal information, does not use sensitive personal information for purposes that would give rise to a right to limit its use, and does not knowingly sell or share the personal information of consumers under 16 years of age. California residents may exercise their rights as described in Section 8.

9.3 Nevada. Facility First does not sell covered information as defined under Nevada law.

10. Visitors in the European Economic Area, the United Kingdom and Switzerland

10.1 For visitors whose personal information is protected by the EU General Data Protection Regulation, the UK General Data Protection Regulation or the Swiss Federal Act on Data Protection, Facility First relies on the following legal bases:

1. taking steps at the visitor’s request before entering into a contract, and Facility First’s legitimate interests in responding to business inquiries and requests and in reviewing Service Provider applications, for inquiries, proposal requests and Service Provider applications;
2. consent, for optional cookies, if used;
3. Facility First’s legitimate interests in operating and securing the Website, preventing spam and fraud, and keeping business records; and
4. compliance with legal obligations.

10.2 Where Facility First relies on legitimate interests, a visitor may object to the processing as described in Section 8. Providing information through Website forms is voluntary, but Facility First may be unable to respond to a request or review an application without it.

10.3 These visitors may lodge a complaint with the data protection authority in the country where they live or work or where an alleged infringement took place.

11. International Transfers

11.1 The Website is operated from the United States. Information submitted from outside the United States is transferred to, processed and stored in the United States and in other countries where Facility First’s service providers operate, where data protection laws may differ from those in the visitor’s jurisdiction. Information stored in another country may be accessible to the courts, law enforcement and national security authorities of that country under its laws.

11.2 Where the law of a visitor’s jurisdiction requires a transfer mechanism, Facility First relies on appropriate safeguards, such as standard contractual clauses approved by the European Commission or the equivalent terms approved for the United Kingdom and Switzerland, or a service provider’s certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions, or on another basis permitted by law, such as a transfer necessary to respond to a request the visitor has made. Further information about these safeguards is available on request.

12. Visitors in Canada

12.1 Facility First has designated a Privacy Officer, who is the person in charge of the protection of personal information for purposes of Quebec’s Act respecting the protection of personal information in the private sector. The Privacy Officer can be reached at legal@mccraygp.com or at the mailing address in Section 16.

12.2 Visitors in Canada may request access to and correction of their personal information and may withdraw consent, subject to legal or contractual restrictions. Visitors in Quebec may also request that computerized personal information they provided be communicated to them in a structured, commonly used technological format.

12.3 The Website does not use technologies that identify, locate or profile visitors; if any are added, they will remain off unless the visitor chooses to accept them, as described in Section 5.

12.4 Concerns may be raised with Facility First’s Privacy Officer. Visitors who are not satisfied with Facility First’s response may contact the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.

13. Children’s Privacy

13.1 The Website is intended for adults acting in a business or professional capacity and is not directed to children. Facility First does not knowingly collect personal information from children under 13, or under 16 where local law sets a higher age. If Facility First learns that such information has been submitted, it will take reasonable steps to delete it.

14. Translations

14.1 This Policy may be made available in languages other than English for convenience. If there is any conflict or inconsistency between the English version and a translation, the English version controls to the extent permitted by applicable law.

15. Changes to This Policy

15.1 Facility First may update this Policy to reflect changes in the Website, business practices, technology or legal requirements. The revised Policy will be posted on this page with an updated effective date. Where a change is material, Facility First will also provide notice on the Website or by other appropriate means.

16. Contact

16.1 Questions about this Policy and privacy requests should be directed to:

Facility First, Inc.
Attn: Privacy Officer, Legal Department
407 Lincoln Road
Miami Beach, FL 33139
United States
legal@mccraygp.com
(833) 832-6647

Requests should include enough information for Facility First to understand and respond. Facility First may contact the requester to verify identity or obtain additional information.