Privacy Notice
Summary
Life can be hectic and instead of producing a privacy notice where we expect everyone to read through pages and pages, we at FIRST.com thought it would be useful to provide a helpful summary at the top of privacy notice. Of course, this is just a summary and we’d always recommend that everyone reads the full notice properly!
When you visit and use FIRST.com, we will collect certain personal data about you, and we will process this personal data in accordance with those purposes that we set out in our privacy notice. The main two purposes which we process your personal data are: (i) to send you direct marketing when you have requested to receive this; and (ii) when you click on a link to an operator’s site we share and receive information with the operator as this is primarily how we generate revenue – by advertising operator sites.
Hopefully that all makes sense, but please do read below for more information.
About this Privacy Notice
This privacy notice applies to the personal data we process in connection with our website, www.FIRST.com (the Website).
This privacy notice may change from time to time and, if it does, the up-to-date version will always be available on the Website. We will also tell you about any important changes to our privacy notice.
Who we are
We are Une Forte Limited (we, our or us). Our company number is 14974954 and our registered address is Sierra Quebec Bravo, 77 Marsh Wall, London, England, E14 9SH.
What personal data do we collect about you
If you subscribe to our newsletter then we will collect your email address.
If you follow any of our social media pages – X, Instagram, Facebook and YouTube – we will see your social media handle as well as any comments or likes that you include on our posts.
If you contact us, we will collect your email address as well as any personal data that you include in any communication.
If you enter any promotions or competitions, we will also collect information about your entry and your email address.
The above are all instances where we collect personal data from you directly.
We will also collect certain information from you when you visit our Website and interact with its features, including information about your device, your IP Address and the areas of the Website that you navigate to and interact with.
If you click on an operator link – such as ‘bet now’ or ‘visit site’ – in relation to odds or offers that we include on our Website, we will collect information about this interaction as well as information from the operator where you make a deposit money, place a bet or play a game after navigating to their site from our Website.
Additionally, we also collect, use and share Aggregated Data such as statistical or demographic data for our business purposes. Aggregated Data is not considered personal data in law as this data does not directly or indirectly reveal your identity. An example of Aggregated Data would be where we data about your (and others) usage of the Website to calculate the percentage of users accessing a specific blogs, links and features of our Website.
We do not seek to collect Special Category Data which means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data; and personal data related to criminal offences or criminal records.
Finally, where we use cookies, we will collect information via these cookies based on your interaction with the Website and possibly other sites. Please see our section on Cookies for more information.
Purposes for which we will use your personal data
This section explains how we will use personal data you provide to us in order to carry out the activities relevant to the provision of the Website and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose / Activity | Lawful basis for processing (including basis of legitimate interest) |
| To provide you with our services via Website | Performance of a contract with you |
| To understand when you have navigated to an operator site and your activity on that site | Necessary for our legitimate interests (to be able to receive remuneration for direct traffic to such sites) |
| To manage our relationship with you (including notifying you about changes to our terms or privacy notice) | Performance of a contract with you |
| To review and support the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Necessary for our legitimate interests (for running our business, ensuring that the Website operates as intended, administration and IT services) |
| To use data analytics to improve the Website | Necessary for our legitimate interests (to understand better how users interact with the Website so that it can be improved) |
| To send you direct marketing via | Consent |
| To personalise direct marketing | Necessary for our legitimate interests (to ensure that marketing is of most interest to you) |
| To share information with social media platforms to advertise our services to you and those who are similar to you | Necessary for our legitimate interests (to reach a more engaged audience) |
| To receive, consider and respond to any communications you send to us | Necessary for our legitimate interests (to respond to your communication) |
| To send customer satisfaction surveys | Necessary for our legitimate interests (to understand how we can improve our Website and offering) |
In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this privacy notice accordingly, when we do this.
Communications
If you consent to receive direct marketing, we will send out direct marketing to you from time-to-time. You will always have the option to unsubscribe from marketing by interacting with the ‘unsubscribe’ feature in any marketing communication.
We may send you communications such as those which relate to any service updates or provide customer satisfaction surveys. These are not direct marketing.
Who else might we share your personal data with
We will share your personal data with those operators whom you navigate to from the Website. It is always important to make sure you also read their privacy notice to understand how they will process your personal data.
We may share your personal data with third parties (known as processors) who assist us with administering the provision of the Website.
Finally, in limited circumstances we may share your personal data with the following:
- Professional advisors – where we require advice.
- Law enforcement – where we consider it necessary and proportionate to share information upon request or where we are obliged to do so via an order.
- Investors or purchases – in respect of any corporate activity or restructuring.
- Group companies – for support in respect of the purposes set out in this privacy notice.
We may also share your personal data where we are required to do so by law.
We may also pass Aggregated Data on the usage of the Website (e.g. we might disclose the numbers of visitors to the Website that come from different geographic areas) to third parties, but this will not include information that can be used to identify you personally.
Transferring your personal data
The information that we processed may be stored at, and (if applicable) transferred to, a destination outside of the United Kingdom and the European Economic Area (EEA). When we transfer your personal data outside of the United Kingdom and EEA we will ensure that it is adequately protected by using appropriate safeguards, such as standard contractual clauses (or equivalent).
How long we keep your personal data for
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data are as follows:
- whether we maintain an ongoing relationship with you;
- whether we have a lawful purpose to process your personal data (e.g. any laws requiring us to keep transaction records for a certain time period before deleting them); and
- what the limitation period is under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal data, or to which your personal data may be relevant).
We may retain personal data about you for statistical purposes. Where data is retained for statistical purposes, it will always be anonymised, meaning that you will not be identifiable from that data.
Your rights
You have the following rights in relation to your personal data:
- to request confirmation as to whether we process your personal data and obtain a copy of such personal data;
- to request that we update any of your personal data if it is inaccurate or out of date;
- to request that we erase the personal data we hold about you;
- to request that we restrict the way in which we process your personal data;
- to object to our processing which is carried out on the basis of legitimate interests;
- to withdraw your consent where we rely on your consent for processing; and
- ‘port’ your personal data to a third party.
For more information on your rights and how to use them, or if you would like to make any of the requests set out above, please contact us at [email protected].
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Your rights are not absolute and there may be situations in which we are unable to comply with a rights request. For example, your right to object to processing carried out on the basis of legitimate interests is qualified where we believe that our interests are so compelling so as to override your interests and right to object.
Cookies
The Website uses cookies. These are small text files that are stored on your device.
You can learn more about cookies and how to disable them here.
Save in respect of cookies which are strictly necessary in order to provide our service to you, cookies will only be used where you have given your consent for these via our Consent Management Platform which pops up when you visit the Website.
We use the GA4 cookie and you can read more about this here.
More Information
If you have any questions or concerns about how we handle your personal data, you can contact us at [email protected].
If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to make a complaint to the data protection regulator. The Information Commissioner’s Office is the authority in England and Wales which is tasked with the protection of personal data and privacy. However, we ask that you always contact us in the first instance.
Last updated: [November 2024]
