Privacy Policy Home Privacy Policy Your privacy is important to First 1 Club. This Privacy Policy explains how First 1 Club Limited (“First 1 Club”, “First1C”, “we”, “us” or “our”) collects, uses, stores and protects your personal data when you use our website and platform. First 1 Club is currently in a promotional and community-building stage. The platform is points-based only. Points, rankings, badges or similar features have no cash value and cannot currently be withdrawn, sold, transferred, exchanged for money, or exchanged for monetary benefit. We do not currently offer cash prizes, monetary prizes, gambling facilities, or rewards that can be exchanged for money. If this changes in the future, we will update this Privacy Policy, our Terms, Cookie Policy and consent controls before introducing any monetised, prize-based, gambling-related or regulated services. 1. Who we are First 1 Club Limited is the controller of the personal data we collect through this website and platform. If you have any questions about this Privacy Policy or how we use your personal data, you can contact us at: [email protected]. 2. Personal data we collect We may collect and use the following types of personal data: Name and contact details, such as your name, email address and contact number. Account details, such as username, login credentials, membership status and account settings. Age and identity verification data, such as date of birth, verification status, identity check results and related audit records. Platform activity, such as points, rankings, predictions, competition entries, preferences and website usage. Technical data, such as IP address, browser type, device information, log data and security information. Communications data, such as messages, support requests, feedback or enquiries you send to us. Marketing and cookie preferences, including your consent choices and communication preferences. 3. How we use your personal data We use your personal data for the following purposes: To create and manage your account. To provide, operate and improve the First 1 Club platform. To record points, rankings, predictions, preferences and platform activity. To carry out age or identity checks where required for safety, platform integrity, fraud prevention or future service readiness. To protect the website, users and platform from misuse, fraud, abuse or unauthorised access. To respond to enquiries, support requests and user communications. To send service messages relating to your account or platform use. To send promotional or marketing communications only where we are permitted to do so and, where required, where you have given consent. To analyse website performance and improve user experience, subject to your cookie preferences where applicable. To comply with legal, regulatory, accounting or security obligations. 4. Lawful basis for using your data We only use your personal data where we have a lawful basis to do so. Depending on the circumstances, we may rely on: Contract — to provide your account and operate the platform you choose to use. Legitimate interests — to improve the platform, protect users, prevent misuse, maintain security and manage our services. Consent — for certain cookies, optional marketing communications or other activities where consent is required. Legal obligation — where we need to keep records or comply with applicable law or regulatory requirements. Where we rely on consent, you can withdraw your consent at any time. 5. Age and identity verification We may ask users to complete age or identity checks to help protect users, prevent misuse, maintain platform integrity and prepare for possible future services. Age or identity verification may involve checking information you provide against trusted verification sources or service providers. We aim to collect only the information needed for the verification purpose. We may keep verification status, audit records and related information for as long as reasonably necessary for security, compliance, fraud prevention and platform integrity. If we introduce any verification process that involves biometric data, special category data or additional regulated checks, we will update this Privacy Policy and our data protection controls before doing so. 6. Cookies and similar technologies We use cookies and similar technologies to help our website work correctly, remember preferences, improve performance and, where you allow it, support analytics or promotional activity. Non-essential cookies are not used unless you choose to allow them through our cookie settings tool. You can change your cookie preferences at any time. For more information, please read our Cookie Policy. 7. Marketing and promotional communications We may send you service messages about your account or use of the platform. We will only send optional promotional or marketing communications where we are permitted to do so and, where required, where you have given consent. You can withdraw marketing consent or update your communication preferences at any time by using the unsubscribe option in our messages or contacting us at [email protected]. 8. Sharing your personal data We do not sell your personal data. We may share personal data with trusted third parties where necessary to operate, secure and improve the platform, including: hosting, website and IT service providers; identity, age verification or fraud prevention providers; payment providers, if paid services are introduced in the future; analytics or cookie providers, subject to your cookie preferences; professional advisers, such as legal, accounting or compliance advisers; law enforcement, regulators or public authorities where required by law. Where we use service providers, we require them to protect personal data and only use it for the purposes we authorise. 9. International transfers Some of our service providers may process personal data outside the United Kingdom or European Economic Area. Where this happens, we will take steps designed to ensure your personal data receives appropriate protection, such as using recognised transfer safeguards where required. 10. How long we keep your data We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy. Retention periods may depend on the type of data, the reason we collected it, account status, legal obligations, security requirements, fraud prevention needs and whether there is an ongoing dispute or investigation. In general: account data is kept while your account remains active and for a reasonable period afterwards; verification and security records may be kept where needed for compliance, fraud prevention and platform integrity; support and communication records may be kept to respond to enquiries and maintain records; cookie consent records are kept in line with our Cookie Policy. 11. Data security We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. No online service can be completely secure, but we work to protect your personal data and keep our security measures under review. 12. Your rights Depending on your location and the circumstances, you may have the right to: request access to your personal data; request correction of inaccurate or incomplete data; request deletion of your personal data; object to certain uses of your data; request restriction of processing; request transfer of your data; withdraw consent where we rely on consent; complain to the UK Information Commissioner’s Office. To exercise your rights, contact us at [email protected]. 13. Children and age restrictions First 1 Club is not intended for children below the minimum age stated in our Terms or registration requirements. We may use age checks to help ensure that users meet our platform requirements and to support user protection, platform integrity and future service readiness. 14. Changes to this Privacy Policy We may update this Privacy Policy from time to time to reflect changes to our platform, legal requirements, services, data practices or future product development. If we make significant changes, we will take appropriate steps to bring them to your attention. 15. Contact us If you have any questions about this Privacy Policy or how we use your personal data, please contact: First 1 Club Limited Email: [email protected]