The full text of our Privacy Policy follows below, the above is a summary and not legally binding.
Last updated: April 21, 2024
The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why; how your data is handled; and your rights with respect to your data. We promise we never sell your data: never have, never will.
This policy applies to all our Services and products.
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with FirstLook). We refer collectively to these categories of individuals as “you” throughout this policy.
However, this policy does not cover information about a customer’s end users that FirstLook receives from a customer, or otherwise processes on a customer’s behalf, in connection with the services provided by FirstLook to the customer pursuant to an applicable services agreement (including the content of messages of customer end users (“End User Communications”)). FirstLook processes End User Communications under the instructions of the relevant customer, which is the “data controller” or “business” (or occupies a similar role as defined in applicable privacy laws), as described in the applicable services agreement between such customer and FirstLook. FirstLook’s obligations as a “data processor” or “service provider” with respect to such information are defined in such services agreement and applicable data protection addendum and are not made part of this policy.
If you are a customer’s end user and you have questions about how your information is collected and processed through the services, please contact the organization who has provided your information to us for more information.
Our guiding principle is to collect only what we need. Here’s what that means in practice:
When you sign up for FirstLook, we ask for identifying information such as your name, email address, and your Studio/organization name. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. With your consent, we will send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.
We’ll never sell your personal information to third parties, and we won’t use your name or company in marketing statements without your permission either.
If you sign up for a paid FirstLook plan, you will be asked to provide your payment information and billing address. Credit card information is submitted directly to our payment processor and doesn’t hit FirstLook’s servers. We store a record of the payment transaction, including the last 4 digits of the credit card number, for purposes of account history, invoicing, and billing support. We store your billing address so we can charge you for service, calculate any sales tax due, send you invoices, and detect fraudulent credit card transactions. We occasionally use aggregate billing information to guide our marketing efforts.
We store on our servers the content and Player Data that you upload or receive or maintain in your FirstLook accounts. This is so you can use our product as intended, for example, to create a waitlist page, or guide players to access your playtest. We keep this content as long as your account is active. If you delete your account, we’ll delete the content within 60 days.
We log the full IP address used to sign up for an account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.
We collect information about your browsing activity for analytics and statistical purposes such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, which web pages you visited and how long they took to load, and which website referred you to us. We do not store your IP Address for analytics purposes. If you have an account and are signed in, these web analytics may be tied to your user account until your account is no longer active.
When you email FirstLook with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, for example, written responses to surveys. If you agree to a customer interview, we may ask for your permission to record the conversation for future reference or use. We will only do so with your express consent.
When you explicitly share confidential information with us, such as your business plan, game design, or other proprietary information, we will protect it as we would our own. We will not share this information with third parties.
To provide products or services you’ve requested. We use some third-party subprocessors to help run our applications and provide the Services to you. You can view the third-party subprocessors we use at firstlook.gg/legal/subprocessors. We also use third-party processors for other business functions such as customer support, email marketing, and analytics, listed separately in our Subprocessors page.
We may disclose your information at your direction if you integrate a third-party service into your use of our products. For example, if you choose to connect your FirstLook account to a third-party application, we may share your information with that third-party to enable the integration.
No FirstLook human looks at your Player Data except for limited purposes with your express permission, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases, and when they happen, we look for root cause solutions as much as possible to avoid them recurring. We may also access your data if required in order to respond to legal process (see “When required under applicable law” below).
To help you troubleshoot or squash a software bug, with your permission. If at any point we need to access your content to help you with a support case, we will ask for your consent before proceeding, unless consent is implied by the nature of the support request.
To investigate, prevent, or take action regarding abuse. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We want to protect the privacy and safety of both our customers and the people reporting issues to us, and we do our best to balance those responsibilities throughout the process. If we discover you are using our products for a restricted purpose, we will take action as necessary, including notifying appropriate authorities where warranted.
Aggregated and de-identified data. We may aggregate and/or de-identify information collected through the services. We may use de-identified or aggregated data for any purpose, including marketing or analytics.
When required under applicable law. FirstLook is a Dutch company, and we comply with the General Data Protection Regulation (GDPR) and other applicable data protection laws. If we receive a request for data from a law enforcement agency, we will inform you of the request where we are legally permitted to do so. We will also do our best to challenge requests we believe are improper. We will only comply with requests we are legally required to meet. Additionally, we may be required to retain your data for legal or regulatory reasons.
Finally, if FirstLook is acquired by or merges with another company — we don’t plan on that, but if it happens — we’ll notify you well before any of your personal information is transferred or becomes subject to a different privacy policy.
At FirstLook we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at privacy@firstlook.gg.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted. In addition, we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review our Security Policy. Most data are not encrypted while they live in our database (since they need to be ready to send to you when you need them).
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.
Our products and other web properties are operated in the Netherlands. If you are located in the United States, UK, or elsewhere outside of the European Union, please be aware that any information you provide to us will be transferred to and stored in the European Union. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data that is transferred out of the UK. Accordingly, FirstLook has adopted a data processing addendum with Standard Contractual Clauses to help ensure this protection. our DPA is available at firstlook.gg/legal/dpa.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will refresh the date at the top of this page and take any other appropriate steps to notify users.
Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at privacy@firstlook.gg and we’ll be happy to try to answer them!