Effective Date: October 10, 2026
Last Updated: October 10, 2026
Introduction
First Layer Tech (“First Layer Tech,” “we,” “our,” or “us”) is an IT consulting company specializing in Microsoft products, Microsoft 365 services, software licensing, and license optimization.
We are committed to protecting the privacy and confidentiality of personal information entrusted to us. This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information when you visit our website, contact us, engage our consulting services, or communicate with us through our SMS text messaging program.
This policy applies to information we handle in connection with our website, business operations, customer relationships, and consulting services. Additional contractual terms may apply to information we process on behalf of our clients.
Information We Collect
We may collect the following categories of information, depending on your relationship with First Layer Tech and the services we provide.
A. Contact and Business Information
We may collect names, business email addresses, phone numbers, company names, job titles, mailing addresses, and other contact information provided through our website, email, telephone calls, meetings, or other business communications.
B. Client and Consulting Information
When providing IT consulting and license optimization services, we may receive or access information such as:
- Microsoft 365 subscription details, license assignments, license utilization reports, and licensing configurations.
- Business account identifiers, user names, business email addresses, and directory information.
- Microsoft tenant settings, administrative configurations, service information, and technical reports.
- Client-provided documentation, support requests, project records, and other business information relevant to a consulting engagement.
- Information reasonably necessary to assess software licensing requirements, identify optimization opportunities, and provide technical recommendations.
The information available to us depends on the services requested, the permissions granted, and the scope of our engagement.
C. Technical and Website Information
When you visit our website, we may collect technical information such as IP addresses, browser types, device information, pages visited, and website usage data through server logs or similar technologies.
Cookies, analytics tools, or other tracking technologies may also collect information if they are implemented on our website.
D. SMS Messaging Information
If you participate in our SMS messaging program, we may collect your mobile phone number, subscription preferences, consent records, opt-in and opt-out dates, and information relating to message delivery and your requests for assistance.
How We Use Personal Information
We may use personal information for legitimate business purposes, including to:
- Respond to website inquiries and requests for information.
- Establish and manage client relationships and consulting engagements.
- Provide Microsoft product consulting, Microsoft 365 support, licensing analysis, and license optimization recommendations.
- Access and administer client systems when authorized and necessary to perform contracted services.
- Review licensing assignments, subscription usage, configurations, and related technical information.
- Communicate project updates, service notifications, support responses, and other operational information.
- Administer our SMS messaging program and honor messaging preferences.
- Maintain business records, manage billing where applicable, and fulfill contractual obligations.
- Protect our systems, investigate suspected misuse, and comply with applicable legal requirements.
- Improve our website, internal processes, and service delivery.
We do not use client information obtained through administrative access for unrelated marketing purposes.
We will not use personal information for purposes materially different from those described here without providing additional notice or obtaining consent where required by law.
Client Data and Microsoft Environment Access
First Layer Tech may maintain ongoing administrative or delegated access to client Microsoft environments when authorized by the client and necessary to provide contracted services.
Depending on the engagement, this access may include Microsoft 365 administration portals, tenant settings, licensing management tools, user and directory information, subscription records, and related technical systems.
We follow these principles when handling client information:
- Authorized access: We access client environments for legitimate business purposes within the scope of the permissions and authorization granted to us.
- Purpose limitation: We use client information to deliver contracted consulting, administration, troubleshooting, licensing, and optimization services.
- Confidentiality: We treat nonpublic client information as confidential and limit disclosure to authorized purposes.
- Restricted use: We do not sell client data or use information obtained through client administrative access for unrelated advertising or marketing.
- Appropriate handling: We take reasonable steps to protect client information against unauthorized access, disclosure, alteration, or loss.
Clients remain responsible for authorizing access to their environments, maintaining appropriate control over their accounts, and determining which permissions are appropriate for their business.
First Layer Tech will not intentionally access client information beyond the scope of its authorization. If we identify an apparent access or security issue, we will address it in accordance with applicable agreements and circumstances.
Where a client engagement involves processing personal information on the client’s behalf, the client agreement, applicable data processing agreement, or other contractual terms may establish additional requirements regarding permitted processing, security, retention, deletion, and incident notification.
Credentials and Authentication Information
In providing IT consulting and administrative services, First Layer Tech may use authorized accounts, delegated permissions, and authentication mechanisms to access client systems.
We seek to limit the collection and handling of passwords, authentication codes, recovery codes, and other sensitive credentials. Where possible, clients should grant access through appropriate administrative delegation or other secure access mechanisms rather than transmitting shared credentials.
SMS Text Messaging Privacy
First Layer Tech may offer SMS text messaging to communicate operational and service-related information to individuals who have subscribed or otherwise provided the required consent.
Information We Collect
We collect your mobile phone number and may maintain information relating to your subscription, messaging preferences, consent, and interactions with our SMS program.
How We Use SMS Information
We use SMS information to administer our messaging program and send operational or service-related communications, such as relevant service updates, support notifications, appointment or project coordination messages, and other communications consistent with the purpose for which you subscribed.
We do not use our operational SMS program to send unrelated promotional marketing messages.
Message Frequency
Subscribers will receive no more than five (5) automated SMS messages per month under our current program. Message frequency may vary depending on service activity and communication needs, but will not exceed this stated limit.
Opt-Out Instructions
You may opt out of SMS messages at any time by replying STOP to a First Layer Tech text message. We will process opt-out requests in accordance with applicable requirements.
You may also contact support@firstlayertech.com to request assistance with your messaging preferences.
Help and Support
For assistance with our SMS program, contact support@firstlayertech.com.
Message and Data Rates
Message and data rates may apply depending on your wireless carrier and service plan. Wireless carriers are not responsible for delayed or undelivered messages.
SMS Data Sharing
Mobile phone numbers, SMS opt-in data, and SMS consent records will not be sold, rented, or shared with third parties or affiliates for their own marketing or promotional purposes.
We may share the information necessary to operate our messaging program with service providers that deliver SMS messages or support related communications on our behalf. These providers may use such information only as necessary to perform their services and as otherwise permitted by applicable law.
Consent to receive SMS messages is not a condition of purchasing goods or services from First Layer Tech where prohibited by applicable law or where required to be offered as a separate choice.
How We Share Personal Information
First Layer Tech does not sell personal information for monetary consideration. We may disclose information in the following circumstances:
Service Providers
We may share relevant information with trusted service providers that assist with website hosting, cloud infrastructure, business communications, customer support, security, administrative tools, and SMS delivery.
We seek to limit the information shared to what is reasonably necessary for the services provided and to use appropriate contractual or other safeguards.
Client-Authorized Activities
We may access, process, or disclose information within a client’s environment as necessary to perform authorized consulting services or follow the client’s documented instructions and applicable agreements.
Legal and Safety Requirements
We may disclose information when reasonably necessary to comply with applicable law, respond to valid legal process, protect rights or safety, investigate suspected fraud, or safeguard our systems and business.
Business Transactions
Information may be transferred in connection with a merger, acquisition, restructuring, financing, or sale of all or part of our business, subject to applicable legal requirements.
With Authorization or Consent
We may disclose information when directed by the relevant client or individual, or when consent or another lawful basis permits the disclosure.
We do not disclose client data for third-party marketing purposes.
Microsoft and Other Third-Party Services
First Layer Tech provides independent consulting services relating to Microsoft products and services, including Microsoft 365 and associated licensing and administration tools.
Unless expressly stated otherwise, First Layer Tech is an independent consulting company and is not Microsoft Corporation.
Microsoft and other third-party providers may independently collect or process information when you use their products or services. Those activities are governed by the providers’ applicable terms and privacy documentation, rather than solely by this Privacy Policy.
For information about Microsoft’s privacy practices, please visit:
https://www.microsoft.com/privacy
Microsoft’s product-specific contractual data protection terms may also apply to the relevant services. Clients should review the terms applicable to their Microsoft subscriptions and agreements.
Cookies and Website Analytics
If our website uses cookies, analytics tools, or similar technologies, these technologies may collect technical information about your device, browser, and interactions with our website.
We may use such information to maintain website functionality, understand website traffic, improve performance, and troubleshoot technical issues.
You may be able to control cookies through your browser settings or any preference tool available on our website. Disabling certain cookies may affect website functionality.
Where required by applicable law, we will obtain consent before using nonessential cookies or similar tracking technologies.
Data Security
First Layer Tech takes reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.
The safeguards appropriate to a particular engagement may depend on the nature of the information, the systems involved, contractual obligations, and applicable legal requirements.
No electronic transmission or storage system can be guaranteed to be completely secure. Accordingly, we cannot guarantee absolute security.
Clients should notify us promptly of suspected unauthorized access involving our consulting activities or information entrusted to us so that the matter can be addressed appropriately.
Data Retention and Deletion
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, subject to applicable agreements and legal requirements.
Retention periods may vary based on the type of information, the duration of a client relationship, business recordkeeping needs, dispute resolution requirements, and applicable law.
For client information accessed through Microsoft environments, retention, return, and deletion may be governed by the applicable consulting agreement, data processing agreement, client instructions, and system limitations.
When information is no longer required, we will take reasonable steps to delete it, destroy it, or de-identify it where appropriate and technically feasible, subject to legal and contractual retention requirements.
We may retain limited records of SMS opt-outs and suppression requests to ensure that individuals’ messaging preferences continue to be respected.
Your Privacy Rights and Choices
Depending on your location and applicable law, you may have the right to request access to, correction of, or deletion of certain personal information, or to receive a copy of certain information in a portable format.
You may also have rights to withdraw consent or opt out of certain data processing activities where applicable.
To submit a privacy request, contact support@firstlayertech.com with the subject line Privacy Request.
We may need to verify your identity or authority before responding. We will process eligible requests within the timeframes required by applicable law, subject to lawful exceptions.
Where First Layer Tech processes information on behalf of a client, the client may be responsible for responding to requests relating to that information. We will handle such requests in accordance with our applicable agreements and legal obligations.
You may opt out of SMS messages at any time by replying STOP, regardless of whether you exercise any other privacy rights.
Children’s Privacy
Our website and consulting services are intended for business and professional use and are not directed to children under 13.
We do not knowingly collect personal information online from children under 13. If we learn that we have collected such information in circumstances requiring parental consent or deletion, we will take appropriate action in accordance with applicable law.
U.S. State Privacy Laws
Certain U.S. state privacy laws provide additional rights and impose obligations on businesses that meet their applicable criteria.
Where such laws apply to First Layer Tech, we will provide applicable disclosures and honor relevant consumer rights, subject to statutory exceptions.
The applicability of these laws depends on factors such as the nature and volume of information processed, business activities, and statutory thresholds or exemptions. This policy does not represent that every state privacy law applies to First Layer Tech.
To submit a privacy request or ask a question about our practices, contact support@firstlayertech.com.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business, consulting services, information-handling practices, technology, or legal obligations.
We will update the “Last Updated” date when changes are made. Where required by law, we will provide additional notice or obtain consent for material changes.
We encourage you to review this policy periodically.
Contact Information
For questions, concerns, or requests regarding this Privacy Policy or First Layer Tech’s handling of personal information, contact:
First Layer Tech
Email: support@firstlayertech.com
Website: https://firstlayertech.com