Privacy

PRIVACY POLICY – FIRST.COM.

Last Updated: November 4, 2024

Welcome to FIRST.com, a site operated by UNE FORTE LTD ("we," "us," or "our"), a company registered in England and Wales with company number 14974954, located at Sierra Quebec Bravo, 77 Marsh Wall, London, England, E14 9SH. We are committed to respecting and protecting your privacy and ensuring the safety and security of any Personal Data we collect about you. This Privacy Policy outlines how we collect, use, share, and protect Personal Data when you visit or engage with our website and services. As a website operating within the UK market gambling industry, FIRST.com adheres to relevant privacy laws and regulations, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our aim is to ensure that all Personal Data we handle is processed lawfully, transparently, and securely. We encourage you to carefully review this Privacy Policy to understand our views and practices regarding your Personal Data and how we will treat it. By accessing and using FIRST.com, you agree to the practices outlined in this Privacy Policy. If you do not agree with our practices, please discontinue your use of our website and services.

Please note that this Privacy Policy may be updated periodically to reflect changes in legal requirements, our business practices, or advancements in technology. We will notify you of any significant changes to this policy, and we recommend you check this page regularly for updates.

If you have any questions about this Privacy Policy or how we handle your Personal Data, please contact us at [email protected] or at our registered office address provided above.

DEFINITIONS

Capitalised terms used in this Policy shall have the following meanings:

"Cookie(s)" Denotes a small piece of data stored on the User's device by the web browser, typically used to enhance User experience, track usage patterns, and collect information about the User's interactions with the Website.

"Data Controller" As defined in the UK GDPR, refers to the entity that determines the purposes and means of the processing of Personal Data.

"Data Processor" As defined in the UK GDPR, refers to an entity that processes Personal Data on behalf of the Data Controller. In the context of FIRST.com, Data Processors may include third-party service providers or subcontractors engaged by FIRST.com to assist in the processing of Personal Data collected through the Website.

"Personal Data" Refers to any information that identifies or can be used to identify an individual User, including but not limited to name, email address and any other information provided by the User during registration or use of the Website.

"Website" Denotes the FIRST.com website, including all associated web pages, features, and services provided by us.

"User" Indicates any individual who accesses or uses the Website, including visitors, subscribers, guests, or any other person interacting with the Website.

WHAT INFORMATION DO WE COLLECT?

  1. Personal Data you disclose to us: We collect Personal Data that you voluntarily provide to us when you register on the Website. The Personal Data that we collect depends on the context of your interactions with us and the Website, the choices you make, and the features you use. The Personal Data we collect may include your full names and e-mail address. This processing will be carried out in accordance with applicable privacy laws and regulations such as the UK GDPR and the Data Protection Act (DPA) 2018, to ensure the confidentiality and security of your Personal Data. We are committed to maintaining the privacy and protection of your information, and any processing will be conducted in compliance with our Privacy Policy and applicable legal requirements. 
  2. Google Analytics: To help us understand how visitors interact with FIRST.com and improve our services, we may use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics collects data on user behavior, such as pages visited, time spent on each page, and actions taken on the site. This data is anonymous and does not directly identify you as an individual. Google Analytics uses cookies, which are small files placed on your device, to gather information and generate reports on website usage and activity. The information generated by these cookies, including your IP address, may be transmitted to and stored by Google on servers located outside the UK. Google may use this data to evaluate your use of our website, compile reports on website activity for us, and provide other services related to website and internet usage. We use the insights from Google Analytics to improve FIRST.com and tailor our services to better meet our users’ needs. You can control the collection and use of data by adjusting your browser settings to block cookies or by using Google's own opt-out tools, such as the Google Analytics Opt-Out Browser Add-on. For more information on how Google Analytics processes data, please refer to Google's Privacy Policy.
  3. Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use the Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps”), and hardware settings).
  4. Device and Location Data: We may collect device data such as information about your mobile phone, tablet, or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), unique device identifiers, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. We may also collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Website. We may request to send you push notifications regarding your account or certain features of the Website. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settin

HOW DO WE PROCESS YOUR INFORMATION?

  1. We process your Personal Data for a variety of reasons, depending on how you interact with the Website. We may process your information (i) to enable you create and log in to your user account, as well as keep your account in working order; (ii) to provide you with the requested services; (iii) to respond to your inquiries and solve any potential issues you might have in connection with the use of the Website; (iv) to send you details about the Website and our related products and services, changes to our services, terms, and other similar information; (v) if you choose to use any of our service offerings that may allow for communication with other users; (vi) where necessary to request feedback and to contact you about your use of the Website; (vii) as part of our efforts to keep the Website safe and secure, including fraud monitoring and prevention; (viii) when we believe it is necessary to identify usage trends, and to evaluate and improve our services, products, and your experience, unless you have opted against receiving this information; (ix) to conduct scientific research studies related to our services, cognitive science, education, or other relevant research fields; when necessary to safeguard or protect an individual's vital interest, such as to prevent harm.
  2. In addition to the foregoing, we may use and process your information to comply with our legal obligations, respond to lawful requests or court orders, defend our legal rights and enforce our terms and conditions. This includes protecting our rights, safety, and property, as well as the rights, safety, and property of our users or any other third parties. We may aggregate and anonymise your information to create statistical or aggregated data that does not personally identify you. This aggregated and anonymised data may be used for various purposes, such as analysing usage patterns, improving our services, or conducting market research, or sharing with third parties for lawful purposes.

The GDPR requires us to explain the valid legal bases we rely on in order to process your Personal Data. As such, we may rely on the following legal bases to process your Personal Data:

a. With your consent. We may process your information if you have given us express permission (i.e. consent) to use your Personal Data for a specific purpose e.g. for providing access to the Website. You may withdraw your consent at any time by contacting us with the information provided in the “CONTACT US” section below.

b. Performance of a Contract. We may process your Personal Data when we believe it is necessary to fulfil our contractual obligations to you, including providing our services or at your request prior to entering into a contract with you.

c. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your Personal Data for some of the purposes described in order to:

  • Send users information about special offers and discounts on our services;
  • Develop and display personalised and relevant advertising content for our users;
  • Analyse how our services are used so we can improve them to engage and retain users;
  • Support our marketing activities;
  • Diagnose technical problems and/or prevent fraudulent activities; and
  • Understand how our users use our services so we can improve user experience.

d. Payment Processing. We may process your information for payment processing purposes through third-party payment processors. This includes handling payment transactions, managing refunds, and ensuring the security of payment data. We do not store or collect your payment card details. Your payment information is provided directly to our third-party payment processors, and their use of your personal information is governed by their privacy policies. These payment processors usually comply with the standards set by PCI-DSS as managed by the PCI Security Standards Council, a collaboration of brands such as Visa, Mastercard, American Express, and Discover. The PCI-DSS requirements help ensure the secure handling of payment information.

e. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Additionally, we may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party such as situations involving potential threats to the safety of any person.

We are committed to upholding the rights and protections afforded by the GDPR. Users are encouraged to review this Policy for comprehensive details on the legal bases for processing Personal Data, including their rights and options in managing their Personal Data within the Website.

WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may need to share your Personal Data in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of our company assets, financing, or acquisition of all or a portion of our business to another company. We will notify you via email or through a prominent notice on our website of any change in ownership or the use of your Personal Data. The acquiring entity will be required to comply with the terms of this Privacy Policy, unless you are provided with a new privacy policy and given the opportunity to opt-out.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour the terms of this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Service Providers and Business Partners. We may disclose your information to trusted third-party service providers and business partners who assist us in operating our business and providing our Services. These entities may include payment processors, IT service providers, customer support providers, marketing agencies, and analytics providers. We enter into agreements with these third parties to ensure that they handle your information securely and in accordance with applicable privacy laws and regulations. 
  • Legal Compliance. We may disclose your information if required to do so by law, regulation, or legal process, including to respond to a subpoena, court order, or government request. We may also disclose your information to exercise or defend our legal rights or to protect the rights, property, or safety of our users, employees, or others.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. No purpose in this Policy will require us keeping your Personal Data for longer than twelve (12) months past the termination of the user's account unless we have a legal basis to do so. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise such information, or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

COOKIES AND OTHER TRACKING TECHNOLOGIES

The Website uses cookies to enhance your browsing experience and to collect data that may be considered Personal Data under applicable data protection laws. Cookies are small files stored on your device that enable us to recognise you, remember your preferences, and gather information about your interactions with our website. We utilise various types of cookies to optimise your experience on our site. When you visit our website, you will have the option to accept or customise your cookie preferences. Most browsers also allow you to manage cookies directly through browser settings, including enabling, disabling, or deleting cookies. Please note that disabling certain cookies may impact your ability to access all features on our website. We may work with third-party service providers that set cookies on our website for purposes such as analytics and advertising. These third-party cookies are subject to the privacy policies of the respective providers, and we recommend reviewing these policies for additional information on how your data is handled. For more detailed information on how we use cookies, please refer to our cookies policy. This provides some information on the types of cookies we use, their purposes, how long we keep them and how you can manage your preferences.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any Personal Data we process. 

  1. Data Security: We employ industry-standard security measures to safeguard our user’s Personal Data. This includes encryption protocols and access controls that help ensure the confidentiality and integrity of the information entrusted to us.
  2. Consent: User consent is a cornerstone of our data management practices. Whether it involves marketing communications or the use of cookies, we seek and respect the consent of our users, promoting transparency and user control.
  3. SSL Encryption: Secure Sockets Layer (SSL) and Transport Layer Security (TLS) certificates are implemented to encrypt the data transmitted between users' browsers and our web servers. This encryption ensures the secure conveyance of sensitive information, protecting it from unauthorised access during transit.
  4. User Data Minimisation: We only collect and retain information that is essential for the core functionality of our website. This approach avoids the unnecessary storage of extraneous user information, promoting privacy by design.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Data, transmission of Personal Data to and from our Website is at your own risk. You should only access the Website within a secure environment. In the event of a data breach or security incident, we have established an incident response plan to promptly and effectively respond to and mitigate the impact of such incidents. Our response plan includes assessing the scope and nature of the incident, notifying affected individuals and authorities as required by applicable laws and regulations, and taking appropriate measures to prevent any further unauthorised access or breaches. While we implement these security measures, your cooperation is vital in maintaining the security of your Personal Data. You are responsible for keeping your account credentials secure and confidential. Please refrain from sharing your account information with others and promptly notify us if you suspect any unauthorised access or use of your account.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to and stored on servers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction. If you are located outside of the United Kingdom and choose to provide information to us, please be aware that we transfer the data, including Personal Data, to the United Kingdom for processing. Similarly, if you are located within the United Kingdom and provide information to us, please note that we may transfer the data, including Personal Data, to locations within Europe and outside of Europe for processing. By consenting to this Privacy Policy and submitting your information, you agree to these transfers. We will take all reasonable steps necessary to ensure that your data is treated securely and in accordance with this Policy. We will not transfer your Personal Data to any organisation or country unless adequate controls are in place, including the security of your Personal Data and other personal information.

WHAT ARE YOUR PRIVACY RIGHTS?

  1. You have certain rights under applicable data protection laws. These include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your Personal Data. You may make such a request by contacting us by using the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. If you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection authority.
  2. Consent. If we rely on your consent to process your Personal Data, you have the right to withdraw this consent at any time. You may withdraw your consent at any time by contacting us by using the contact details provided below or updating your preferences. Please note however that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  3. Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
  4. Account Information: If you would at any time like to review or change the information in your account or terminate your account, you may Log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
  5. Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, note that this could affect certain features of the Website.

FILING A COMPLAINT

If you are not satisfied with how we manage your Personal Data or have concerns about your privacy rights, you have the right to make a complaint. In the first instance, please contact us directly at [email protected] or at our registered address. We will do our best to resolve your complaint promptly and address any concerns you may have. If you remain unsatisfied after contacting us, you also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK's data protection authority. You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane Wilmslow Cheshire SK9 5AF; ICO Website: https://ico.org.uk/concerns/. The ICO can provide further information on your rights and options regarding your Personal Data and privacy concerns.

The Website may include links to third-party websites that are not operated by us. If you click on a link to a third-party site, you will be directed to their site. We recommend reviewing the Privacy Policy of every site you visit. We do not have control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services.

AGE RESTRICTIONS AND VERIFICATION

The online betting and gaming services we offer on FIRST.com are strictly prohibited for individuals under 18 years of age or below the legal age of consent for online betting and gaming in the jurisdiction where they are located. Consequently, minors are not permitted to register or play on our site. To comply with these requirements, we have implemented a rigorous age verification process, which includes collecting proof of identification from our users. By registering for an account, you consent to undergo these security checks to confirm your eligibility to use our services. If we discover that any user under the legal age is gambling on FIRST.com, we will immediately block their account. Additionally, we reserve the right to conduct periodic security reviews to validate user identity and age. Registration of an account on FIRST.com authorises us to perform these reviews and compare the information you provide against third-party databases.

CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Policy.

USER-GENERATED CONTENT

If you choose to submit or post user-generated content on our Website, such as reviews, comments, or photos, please be aware that this content may be publicly accessible. We are not responsible for any Personal Data you include in your user-generated content, so please exercise caution when sharing Personal Data within the Website.

CHANGES TO OWNERSHIP OR CONTROL

In the event of a change in ownership or control of our Company, such as through a merger or acquisition, your Personal Data may be transferred to the new owners. We will notify you of any such change and provide choices regarding your Personal Data.

DO WE MAKE UPDATES TO THIS POLICY?

From time to time, we may update this Policy indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Policy frequently to be informed of how we are protecting your information.

CONTACT US 

If you have questions or comments about this notice, you may contact us by email at [email protected], or by post at:

UNE FORTE LTD

Sierra Quebec Bravo, 

77 Marsh Wall, 

London, England, E14 9SH

Never miss out, subscribe to FIRST here
Follow us on socials to keep your finger on the pulse