Firstpeel Privacy Policy

Last Modified: January 3, 2026

Hey everyone, welcome to Firstpeel’s Privacy Policy (“Policy”). Below is a guide on how we collect, use, and share your personal information, as well as some other important information you should know about when you interact with us.

If you reside in Washington or Nevada, our Consumer Health Data Privacy Policy serves as an addendum to this Policy.

1. INTRODUCTION

FIRSTPEEL INC. (“Firstpeel, “we”, “our”, or “us”) respects your privacy and is committed to protecting it through our compliance with this Policy. This Policy describes our practices for collecting, using, maintaining, protecting, and disclosing personal information from our users (“you”, “your”, “User(s)”) on our Firstpeel mobile application (our “App”) and through our events, surveys, products, services, technology platforms and related applications (collectively with the App, the “Service(s)”). Some platforms that we operate on or through our Services may have their own privacy policy, and in that case, that policy will apply instead of this one.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our terms, please do not use our Services. By accessing or using the Services, you agree to this Privacy Policy. This Policy may change from time to time (see Changes to Our Privacy Policy). Your continued access of our Services after we make changes is deemed to be acceptance of those changes, so please check the Last Modified Date at the top of this Policy to ensure that you are viewing the most current version of this Policy.

2. CHILDREN’S PRIVACY

The Service is intended for users 18 and older. We do not permit individuals under the age of 18 on our Services. If you suspect that a User is under the age of 18, please submit a report using the reporting feature available on our Services. Upon becoming aware that someone under the age of 18 has shared Personal Information with us, we will take appropriate steps to delete such information and terminate that individual’s registration, if applicable.

3. THE WHO, WHAT, WHEN, WHERE, AND WHY OF OUR PROCESSING OF YOUR PERSONAL INFORMATION

We collect several types of Personal Information from Users of our Services, such as registration information when you create an account (“Account”) on our Services. “Personal Information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address or email address. Other types of information we collect is information related to how you use our applications, which helps us improve our Services.

Your Personal Information is primarily used to provide you with the Services you request. It may also be used to comply with legal obligations we are subject to or to fulfill our legitimate interests, such as to personalize your experience, develop and improve our Services or to detect illegal activities. Please be aware that if you do not allow us to collect Personal Information from you, we will not be able to provide our Service to you, may not be able to deliver certain experiences, products, and services to you, and/or some of our Services may not be able to take account of your interests and preferences. Please review the table below for more details about our collection and use of your personal information.

PERSONAL INFORMATION PROVIDED BY YOU
Categories of Personal Information Collected	How / When Personal Information is Collected
Account Information, including: First Name Phone Number Email address Geolocation Date of Birth Relationship Preferences (including gender interests and desired relationship type) Photograph(s) Biometric Information (facial data) Government Issued Identification (Driver License) Data	Account Information is required to create an Account on our App and use our Services. For more information on how we use your Account Information, including your Biometric Information, see the Account Verification Processes section below. If you provide us access, we collect the Geolocation (longitude and latitude) of your device, which is important for the core features of our Services. If you decline this access, you may not be able to fully utilize features that rely on your device’s current location.
Profile Information, including: Photograph(s) Video(s) Occupation Religious Beliefs Gender Future Family Plans Other Personal Preferences (including political beliefs, height, and alcohol or smoking consumption)	You may voluntarily choose to provide Profile Information when you complete your profile. Some of this information may be considered sensitive or special in certain jurisdictions, such as details about religious beliefs. If you choose to provide this data, you consent to us using it as laid out in this Policy.
User Content: Any Personal Information you willingly choose to share in your profile or through conversations with other Users. This may include images, videos, text, or other types of content.	You provide this information when you complete your profile. You may voluntarily provide this information through your interactions with Users.
Customer Support & Promotional Content: Any Personal Information you willingly choose to share with our customer support team when you submit reports, complaints, or queries, including communications from other Users that include your Personal Information. Personal Information you provide (including your responses and feedback) if we invite you to participate in surveys, research studies, promotions, marketing campaigns, and events.	You may provide this information when you interact with us or our Services, or contact us.

Account Verification Processes

We use identity verification services to confirm your identity and protect against fraud and abuse. To achieve this, we require all Users to complete a Photo Verification process when creating an Account.

Profile Photo Verification: When you create an Account, you will be asked to upload a profile picture and follow a live process where we collect a photo of yourself (“Verification Selfie”). To authenticate your identity, we will scan your Verification Selfie and profile picture using facial comparison technology provided by our verification service provider (“Verification Provider”) to compare your Verification Selfie to your chosen profile picture. The facial recognition technology processes your Biometric Information by comparing facial feature data to determine the likelihood that the images match. This verification process occurs only once during the signup process, and your Verification Selfie is discarded immediately after the verification process is complete.

Adding or Updating Profile Photo: When you upload or replace your profile picture, we will scan your profile picture using facial detection and/or comparison technology provided by our Verification Provider to ensure (a) your profile photo contains a face, and (b) any future profile photos you upload still represent you. The technology processes your Biometric Information by (a) detecting the presence and general attributes of a face, and (b) comparing facial feature data to determine the likelihood that the profile images match.

Biometric Information Processing Purpose: We and our Verification Provider only process Biometric Information for verification purposes as described above.

Biometric Information Disclosure and Retention: Our Verification Provider processes your Biometric Information until the verification process has been completed, at which point the information is permanently deleted by the Verification Provider. Neither the App nor any of our third-party service providers (including our Verification Provider) stores or retains your Biometric Information.

Government Issued Identity Verification: To verify that users meet the age requirements to use our app, we require all users to scan the barcode on the back of their government-issued ID (Driver License). During this process, only the date of birth is temporarily processed to confirm eligibility. This information is not stored nor retained.

PERSONAL INFORMATION COLLECTED AUTOMATICALLY

Categories of Personal Information Collected

How / When Personal Information is Collected

Technical information:

Details of your visits to our Services (e.g. location data, logs, and other similar communication data and statistics about your interactions).

This information is automatically collected or generated when you visit our Services.

Device information:

Information about your computer and internet connection, including your Internet Protocol address and device ID.

This information is automatically collected when you visit our Services.

PERSONAL INFORMATION COLLECTED BY US OR ON YOUR BEHALF

Categories of Personal Information Collected

How / When Personal Information is Collected

Moderation information:

Personal Information collected as part of any moderation or investigation process.
Personal Information collected from Third-Party sources about potentially harmful Users, as permitted by law.

This information is collected as part of any automatic or manual moderation efforts.

4. HOW WE USE YOUR INFORMATION

We generally use your Personal Information described above to provide you with our Services, to communicate with you, and to ensure that all Users enjoy a safe and personalized experience. Specifically, we may use your Personal Information to:

To provide the Services requested by you.
To provide you with an Account on our Services.
To personalize the content on our Services; to recommend other Users to you.
To verify your identity (including via SMS or email).
To send you information about our Services.
To provide customer support and communicate with you.
To improve the Services and to offer you new features or products.
To analyze how you use the Services.
To prevent, investigate, or combat fraud, misconduct or any violation of our Terms and Conditions or the law.
To administer surveys, research studies, promotions, marketing campaigns, and events.
To maintain the safety and security of our Users.
To monitor User interactions and protect the Firstpeel community.
To resolve disputes, address technical issues, and safeguard our legal rights.
To enforce our Terms and Conditions.

5. HOW WE DISCLOSE AND SHARE YOUR INFORMATION

We don't share Personal Information with third parties, except as described below. When we disclose Personal Information, the recipient is required to keep that Personal Information confidential, secure and process the Personal Information only for the specific purpose for which they are engaged.

Other Users: You share Personal Information with other Users when you voluntarily disclose information on the Services for others to see, such as your Account Information, Profile Information and User Content. This information also may be shared with non-Users of the Services, such as in cases where a User shares Personal Information from your profile with third parties outside the Services. In addition, if a User files a report about another User, we may inform the reporter of any actions we have taken, if applicable, due to the report.

Service Providers: We engage third party companies and individuals to provide Services on our behalf or to help improve and operate our Services. This includes service-related operations such as database management, analytics, customer service, communications, and tools or integrations (e.g., Third-Party Software Development Kits) that enable or enhance features within our Services. These Service Providers may access all or some of your Personal Information, depending on the service provided by the third party.

Corporate Transactions: We may sell, transfer, or otherwise share some or all our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

If Required by Law: Firstpeel will share Personal Information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also may share Personal Information to ensure the safety and security of individuals or assist in the prevention or investigation of criminal activity, and to establish, enforce, or defend against legal claims.

6. YOUR CHOICES REGARDING YOUR INFORMATION

You have several ways to exercise control over your information:

Account settings: Registered Users may update their choices regarding the types of Personal Information processed by us and the communications you receive from us through your Account settings or by updating your profile.

Providing Consent: You consent to our processing of your Personal Information based on explicit, affirmative consent by voluntarily providing such information (e.g., when you provide sensitive Personal Information when filling out your profile). In instances where we ask for consent, you may withdraw your consent at any time by accessing your Account settings, updating your profile, removing device permissions in your device settings, or contacting us at privacy@firstpeel.com. Note: Certain Personal Information is required to provide our Services. If you withdraw consent for the processing of this Personal Information, we may no longer be able to provide you with access to our Services, and your Account may be terminated.

Contact Us: You may contact us at privacy@firstpeel.com to learn more about your rights and choices regarding your Personal Information.

We do not currently respond to web browser 'Do Not Track' (DNT) signals or other mechanisms that indicate a request to disable online tracking of users who use our Services.

7. YOUR RIGHTS REGARDING YOUR INFORMATION

You have the following rights regarding your Personal Information. To exercise any of these rights, you can contact us at privacy@firstpeel.com or by following the relevant instructions below (if applicable). Upon request, Firstpeel will provide you with information about whether we hold any of your Personal Information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information.

Right to be informed of the Personal Information we process about you.

This information is provided to you in this Privacy Policy. Please see the above section within this Policy titled THE WHO, WHAT, WHEN, WHERE, AND WHY OF OUR PROCESSING OF YOUR PERSONAL INFORMATION to see the full list of categories and sources of Personal Information we have collected and we process.

Right to access Personal Information.

If you request to access all Personal Information you’ve submitted, we will respond to your request to access within the time period required by applicable law.

Right to rectify or update your Personal Information where it’s inaccurate or incomplete.

You can rectify or update your Personal Information through your Account profile.

Right to delete your Personal Information.

You can delete some of your Personal Information through your Account profile.
We will use commercially reasonable efforts to honor your requests for deletion; however, certain residual information may actively persist on the Service even if you close your account. Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, in accordance with our Personal Information Retention policies and to the extent permitted by law. For more information, see the PERSONAL INFORMATION RETENTION section of this Policy.

Right to withdraw consent you’ve given us to process your Personal Information for a specific purpose.

You can directly withdraw consent you’ve given us either by updating your Account settings or your profile, or removing device permissions you’ve agreed to in your device settings (e.g., access to specific types of device data such as pictures, location services or consent to receive push notifications). When you withdraw consent, certain services may lose functionality.

The right to be free from discrimination related to the exercise of any of your privacy rights.

The right to opt out of the sale of your Personal Information, and to request information about whether we have sold your Personal Information in the past 12 months.

We have not sold Personal Information in the past 12 months.

The right to limit the use and disclosure of your sensitive Personal Information.

Please note that we may require you to verify your credentials, by matching your e-mail address or other account information to the information in our systems, before you can submit a request to exercise any of these rights.

8. INTERNATIONAL JURISDICTIONS

Our Services are hosted and offered in the United States of America (US), and are subject to US federal, state, and local law. If you are accessing the Services from another country, please be advised that you may be transferring your Personal Information to us in the US, and you consent to that transfer, processing and storage of your Personal Information in accordance with this Privacy Policy. You also agree to abide by the applicable laws of applicable US federal, state, and local laws concerning your use of the Services and your agreements with us. Any persons accessing our Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of Personal Information, different from those of the jurisdictions mentioned above may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you may not use our Services.

9. SECURITY

We use physical, technical and organizational measures designed to protect your information against unauthorized access, theft and loss. We restrict access to your Personal Information to those employees who need to know that information to service your Account or perform their job functions. Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your Personal Information is at your own risk, and we expect that you will use appropriate security measures to protect your Personal Information.

10. PERSONAL INFORMATION RETENTION

For information on Biometric Information retention, see the Account Verification Processes section in this Policy.

We will retain your Personal Information only as long as necessary for legitimate business purposes and as permitted by applicable law. If you delete your Account, it will no longer be visible on the Services. After a 30-day period following Account termination, we will delete your Personal Information, except in the following circumstances:

We retain limited information to support our legitimate business interests, such as customer support records, traffic logs, and data necessary to prevent banned Users from creating a new Account. These interests include allowing us to protect our rights in the event of a claim, preventing fraud, and keeping Users safe.
We keep relevant information if there is an unresolved issue, claim, or dispute that requires us to keep the data until the matter is resolved.

11. CHANGES TO THIS POLICY

Firstpeel may update this Privacy Policy at any time. Any changes will be effective upon posting, and we will update the Last Modified date at the top of this Policy. If there are material changes to the way we treat your Personal Information, we will notify you in advance by email and/or through an in-App notification before the changes take effect.

12. HOW TO CONTACT FIRSTPEEL

If you have any questions about this Privacy Policy, please contact us at: privacy@firstpeel.com.