PRIVACY POLICY

LAST REVISED ON: July 21, 2026

“This Privacy Policy (”Privacy Policy“) describes the data protection practices of FirstThen, Inc., a Texas corporation, and its affiliates (collectively, “Company,” “FirstThen,“ “we,” “our,” or “us”)”, including when you visit any FirstThen website that links to this Privacy Policy (including firstthen.com), use the Application or any affiliated mobile or web applications that link to or contain this Privacy Policy, or otherwise provide data to FirstThen. We refer to the websites, mobile applications, and all other services provided directly by FirstThen, including the Application (as defined in our Terms of Use, which can be found at firstthen.com/terms-of-use), together in this Privacy Policy as the “Services.” The Services consist of a self-guided application featuring training modules, practice tools, tracking tools, and digital coaching, each of which is science-informed and grounded in research-based protocols, and all of which are designed to support parents and caregivers of children with behavioral disorders.

This Privacy Policy is incorporated into our Terms of Use, which can be found at firstthen.com/terms-of-use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE THE SERVICES.

We use your personal data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time (see “Revisions to Our Privacy Policy” below). Any changes to this Privacy Policy will be effective immediately upon posting the updated Privacy Policy unless otherwise stated or as required by applicable law (for example, notice and opt-in or opt-out consent may be required). Your continued use of the Services after we make changes is deemed to be acceptance of those changes to the fullest extent permitted by applicable law, so please check the Privacy Policy periodically for updates.

For purposes of this Privacy Policy, FirstThen is responsible for deciding how and why your Personal Information (as defined below) is collected, used, and disclosed in connection with the “Services”. If you have questions about this Privacy Policy, or wish to exercise any privacy rights described here, please see the “Contacting Us” section below.

The Services are not intended for persons under the age of 18 “(“Minors” or “Children”). Minors are not authorized to use the Services or to provide any information through the Services. We do not solicit or knowingly collect information from Minors, and if we become aware of any such information being collected, we will take immediate action to delete it. We do not knowingly “sell” or “share” personal information of consumers under 18 years of age, as those terms are defined under applicable state privacy laws. Should you become aware that we have collected personal information from a Minor, please see the “Contacting Us” section below.

SCOPE OF FIRSTTHEN PRIVACY POLICY

This Privacy Policy applies to all aspects of our Services as well as to information we may collect offline, or through any other means in connection with your use of our Services. The Services may link to or incorporate websites or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, which are each governed by the privacy policy and business practices of the third party. You understand and agree that FirstThen is not responsible for the security, privacy, or business practices of any third party.

We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

This Privacy Policy applies to Personal Information (as defined below) that we collect when you: access or use the Services; interact with us via email, text, or other electronic messages; participate in our marketing, surveys, events, or promotions; interact with our advertising and applications on third-party websites and services that link to this Privacy Policy; or otherwise provide data to FirstThen.

This Privacy Policy does not apply to: information collected by us offline or through any other websites or services that do not link to this Privacy Policy; or information collected by any unaffiliated third party, including through applications or content that may link to or be accessible through the Services.

YOUR INFORMATION

The Information We Collect and the Sources of Such Information. We collect several types of information from and about users of the Services (collectively, “Personal Information”). The specific types of Personal Information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. Personal Information includes but is not limited to the following categories described below:

Identifiers, such as name, date of birth, address, postcode, email address, and telephone number; Billing information, such as shipping address, credit or debit card number, verification number, and expiration date, collected by our payment processors on our behalf; Commercial information, such as information about purchases or other transactions with us, including information about your providers, if applicable; Customer service information, such as information about your customer service and maintenance interactions with us; Demographic information such as your gender, age, marital status, and similar information in connection with the Services; Information you provide in connection with Services, such as audio recordings, videos (and in some cases the recordings of such videos), lab results, photos, and signatures, including contents of communications made via the Services; General geolocation information, such as city, state, or zip code; Information about others, such as if you provide a family or friend's email address or contact information to allow access to your information or name them as an emergency contact; User-generated content you post in public online forums on our Services or disclose to other users; Internet or other electronic network activity information, including IP addresses, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, cookie identifiers, and any other identifier by which you may be contacted online or offline; Sensitive Personal Information that you may voluntarily provide about yourself or your family members in connection with your use of the Application’s self-guided training modules, which FirstThen handles in accordance with applicable law; Information about your internet connection, the equipment you use to access the Services, and usage details; and/or any other information you choose to directly provide to us in connection with your use of the Services.

We collect this information: directly from you when you provide it to us. automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. from third parties, for example, or business partners.

Information you provide. The information we collect on or through our Services may include: information that you provide by filling in forms provided through our Services. This includes information provided at the time of registering to use or creating an account on our website, purchasing our products, subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Services; details of transactions you carry out through our Services, including your purchase of or subscription to the Application, in which case you may be required to provide financial information. records and copies of your correspondence or communication (including email addresses) that you submit to us via forms or email; your participation in research, surveys, contests, and sweepstakes; requests for customer support and technical assistance, including through any online chat functions, uploads or posts to the Services; where explicit consent has been provided, information about your physical or mental health or condition (where necessary and appropriate); and any other information you choose to directly provide to us in connection with your use of the Services. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the website, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we take measures to ensure the security of our Services, and any information we collect, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies. When you use our Services and websites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, and other information about your equipment, browsing actions, and patterns, including: details of your visits to our websites, including traffic data, general geolocation information (such as city, state, or zip code), logs, and other communication data and the resources that you access and use via our Services. information about your device and internet connection, including your IP address, operating system, and browser type. data collected through our Services by third party analytics and advertising companies.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). In some instances, such information may be considered sensitive Personal Information, in which case we will only collect/process it in accordance with applicable legal requirements depending on your state of residence.

The information we collect automatically may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to: estimate our Services usage statistics and usage patterns. store information about your preferences, allowing us to customize our Services according to your individual interests. improve the Services we provide to our users. recognize you when you return to engage with our Services.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on your device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.

Web Beacons. Pages of the website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We collect certain information automatically when you use our Services, including usage information and device information as described in this Privacy Policy. We may tie this information to Personal Information about you that we collect from other sources or you provide to us.

When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media platforms, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media platforms.

If you access the Services through a third-party connection or log-in (e.g., through a social network or third-party authentication tool), you may allow us to have access to and store certain information from such third parties depending on your settings on such services. If you do not wish to have this information disclosed, do not use these connections to access the Services. For a description of how these third parties handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.

Similarly, if you choose to connect our Services to third-party platforms or tools, or with other apps on your device (e.g., health or fitness monitoring platforms or tools, or your contacts, photos, or calendar), such third parties and tools may allow us to have access to and store additional information as it relates to your use of the Services (e.g., to integrate your fitness data within the Services or access your calendar to help you schedule an appointment). If you do not wish to have this information disclosed, do not initiate these connections.

Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on our website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact us at support@firstthen.com. For information about how you can opt out of receiving targeted advertising, see Choices About How We Use and Disclose Your Information.

Healthcare Information. FirstThen is not a healthcare provider, covered entity, or business associate under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). The Application is designed solely for educational and wellness purposes and does not involve the provision of clinical services. Any general wellness or behavioral information that you voluntarily provide through the Application is not treated as protected health information (“PHI”) under HIPAA. FirstThen handles all personal information you provide in accordance with this Privacy Policy and applicable law.

HOW WE USE YOUR INFORMATION

We collect and use information that you provide to us directly, that we collect automatically through your use of the Services, and that we receive from other sources. This includes Personal Information, sensitive Personal Information (including health information), and usage information, for the following purposes:

Provide the Services. To operate, maintain, and provide the Services, including account and product registration; administration of your account; delivering behavioral technique training modules, tools, and digital coaching; and processing your subscription or purchase transactions.

Account Administration and Customer Support. To create and manage your account, communicate with you about your account and the Services, respond to your questions, communications, or feedback submitted via forms or email, provide customer support and technical assistance (including through online chat functionalities), and respond to your inquiries and requests.

Improve and Develop the Services. To analyze usage and performance, develop new features or products, improve the user experience, and enhance our Services through the use of artificial intelligence technologies to analyze patterns and trends.

Marketing and Communications. To send you newsletters, offers, surveys, and other marketing communications, to personalize the content and ads you see (where permitted by law and your preferences), and to use artificial intelligence technologies to personalize content and recommendations.

Security and Fraud Prevention. To protect the Services, our company, and others, including detecting, preventing, and responding to security incidents, abuse, and fraud.

Legal and Compliance. To comply with legal obligations, enforce our terms and policies, and protect our rights, privacy, safety, and property, and/or that of you or others.

Application Support and Development. To operate and improve the Application, including sharing information with vendors, agents, or subcontractors with whom FirstThen has contracted to assist in providing and improving the Application and its educational content.

With Your Consent. For any other purpose that you consent to at the time of collection or in any other way we may describe when you provide the information.

Identity Verification. To verify your identity and administer your account, including processing your payments, fulfilling your orders, and verifying the authenticity of your government-issued identification photo.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at support@firstthen.com. For more information, see “Choices About How We Use and Disclose Your Information” below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Some of our disclosures of Personal Information to third parties for advertising, analytics, or similar purposes may be considered “sales” or “sharing” of Personal Information under certain state privacy laws. You may have the right to opt out of such activities, as described in the “State Privacy Rights” section below.

RETENTION AND TRANSFER OF INFORMATION

Retention of Your Personal Information and Data

We retain Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy, including to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria we use to determine retention periods include: the nature of the information, the purpose for which it is processed, applicable legal requirements, and our legitimate business needs.

The Company will also retain your usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our platform, or we are legally obligated to retain this data for longer time periods.

Transfer of your Personal Data

Your Personal Information and data is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your Personal Information and data is treated securely and in accordance with this privacy policy and no transfer of your Personal Information and data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Information.

SECURITY OF YOUR PERSONAL DATA

The security of your Personal Information and data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information and data, we cannot guarantee its absolute security. We also use third-party service providers, including providers of artificial intelligence technologies, to process Personal Information on our behalf, subject to contractual obligations that require them to implement appropriate security measures and only process Personal Information in accordance with our instructions. Any natural or legal person who processes the data on behalf of the Company may have access to your Personal Information or data. These third-party vendors collect, store, use, process and transfer information about your activity on our Platform and in connection with virtual and in-person Services in accordance with their privacy policies and our contractual requirements.

DISCLOSURE OF YOUR INFORMATION

Information We May Disclose. Some content or applications, including advertisements and AI-powered features, on our website may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Policy: to our subsidiaries and affiliates. to contractors and other third parties we use to support our business (including providers of artificial intelligence technologies) and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our users is among the assets transferred. to third parties to market their products or services to you if you have consented to these disclosures or if you have not opted out of these disclosures, where permitted by law. For more information, see Choices About How We Use and Disclose Your Information. to fulfill the purpose for which you provide it. for any other purpose disclosed by us when you provide the information. with your consent. To service providers who assist in collecting usage information through automated means, including providers of analytics services, advertising services, artificial intelligence services, and technology services who may use cookies and similar technologies to collect information such as IP addresses, browser types, operating system, device IDs, and other technical information about your use of the Services, subject to appropriate data protection standards and vendor management processes.

We may also disclose your Personal Information or PHI: to comply with any court order, law, or legal process, including to respond to any government or regulatory request. to enforce or apply our Terms of Use which can be found at firstthen.com/terms-of-use and other agreements, including for billing and collection purposes. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FirstThen, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Other uses and disclosures of your Personal Information will be made only with your written authorization, as otherwise described in this Privacy Policy, or as permitted or required by applicable law. If you give FirstThen written authorization to use or disclose your Personal Information for a purpose that is not described in this Privacy Policy, then you may revoke it in writing at any time unless FirstThen has taken action in reliance on your authorization. FirstThen may use de-identified and aggregated information derived from your use of the Application (which does not identify any individual) for any lawful purpose in its sole discretion, including to improve the Application, develop educational content, and conduct research and analytics.

Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information: Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

“Do Not Track” Signals. Some browsers transmit “Do Not Track” (“DNT”) signals. Because there is not yet a common understanding of how to interpret DNT signals, our Services do not currently respond to DNT signals. We will revise this Privacy Policy if that changes in the future.

We and our third-party partners may use cookies and similar technologies to collect information about your activities over time and across different websites, applications, and services for advertising and analytics purposes, including targeted advertising. You may have the right to opt out of our sale or sharing of your Personal Information or our use of your Personal Information for targeted advertising, as described in the “State Privacy Rights” section below.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have certain rights in relation to the Personal Information we collect from you. However, these rights are not absolute, and we may decline your request as permitted by law. These rights include the right: to know whether or not we are processing your personal data; to access your personal data; to correct inaccuracies in your personal data; to request the deletion of your personal data; to obtain a copy of the personal data you previously shared with us; to non-discrimination for exercising your rights; and to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

If you are a resident of one of the states listed above, you may exercise your applicable privacy rights by contacting us at: support@firstthen.com. When you submit a request, we may need to verify your identity to protect your security and privacy. This may include asking you to provide certain information that we already have on file (such as your email address or a recent transaction) so we can match it to our records. We will respond to your request within the timeframe required by applicable law and will let you know if we need additional information. You may also designate an authorized agent to submit certain requests on your behalf, subject to our verification of the agent’s authority, as permitted by law. If we deny your request (in whole or in part), you may have the right to appeal our decision. If applicable, instructions for submitting an appeal will be included in our response.

Depending on where you live, you may have the right to opt out of (i) the “sale” of your Personal Information, (ii) the “sharing” of your Personal Information for cross-context behavioral or targeted advertising, and (iii) our processing of your Personal Information for targeted advertising, as those terms are defined under applicable state law. To opt out of “sales” or “sharing” of Personal Information for targeted advertising under applicable state law, you may submit a request using the contact information above and indicate “Do Not Sell or Share My Personal Information” in your request.

YOUR RIGHTS

Right to Receive Confidential Communications. You have the right to request that FirstThen communicate your Personal Information to you through alternate means (e.g., alternate address or mode of communication). FirstThen will accommodate reasonable requests from you to receive communications of Personal Information from FirstThen by alternative means or at alternative locations. Electronic communications such as e-mail and facsimile are not completely secure. FirstThen is not responsible for incorrect e-mail addresses or facsimile numbers.

Right to Access Your Personal Information. You generally have the right of access to inspect and obtain a copy of your Personal Information which FirstThen collects or maintains in its files. If the request is granted, FirstThen will provide the access requested, including inspection or obtaining a copy of your Personal Information. FirstThen will provide you with access to your Personal Information in the form or format requested if feasible, in a readable hardcopy form, or another form as agreed by FirstThen and you. FirstThen may provide you with a summary of your Personal Information in lieu of providing access to your Personal Information or may provide an explanation of your Personal Information if you agree in advance to such summary or explanation and you agree in advance to the fees imposed, if any, by FirstThen for such summary or explanation. FirstThen will provide you with access to your Personal Information within the timeframe required by applicable law. FirstThen will arrange with you a convenient time and place to inspect or obtain a copy or otherwise mail you a copy of your Personal Information at your request. FirstThen may charge you for the cost of copying the materials and any postage involving your requested Personal Information. FirstThen may discuss with you the scope, format, and other aspects of your request as necessary to process your request. FirstThen will not provide you access, however, to certain Personal Information, namely, information compiled for use in civil, criminal, or administrative proceedings, and information that is subject to legal privilege or other legal restrictions.

Right to Correct Personal Information. You have the right to request that FirstThen correct inaccuracies in your Personal Information or a record about you that FirstThen maintains. Any request must be made in writing and you must provide a reason to support a requested correction. FirstThen will act on your request within the timeframe required by applicable law. If FirstThen cannot comply with the request within the initial timeframe, then it may extend the time as permitted by applicable law, provided that FirstThen has informed you in writing of the reasons for the delay and the date by which FirstThen will act on your request. FirstThen may grant or deny your request to correct your Personal Information. If FirstThen grants your request to correct your Personal Information, then it will make the appropriate correction to your Personal Information or record that is the subject of the request. FirstThen may also inform relevant third parties to whom the Personal Information was disclosed, as required or permitted by applicable law. If FirstThen denies your request to correct your Personal Information, then the denial will be written in plain language and contain the basis for the denial, as required by applicable law. Where required by applicable law, the denial will include a description of your right to appeal the denial and how you may submit an appeal.

USE OF ARTIFICIAL INTELLIGENCE TECHNOLOGIES.

FirstThen may incorporate artificial intelligence and machine learning features into the Application to personalize educational content, recommend training modules, provide coaching, and improve user experience (“AI Features”). AI Features are designed to support the educational and wellness purposes of the Application only. We do not use AI Features to provide clinical advice, diagnosis, or treatment recommendations. Before any user content is leveraged for AI Features, FirstThen strips personally identifiable information from the data to the extent practicable. De-identified user content generated through the Application may be used to train proprietary FirstThen algorithms and AI models; user content is not used to train general-purpose AI models. Users may contact us at support@firstthen.com with questions about AI Features at any time.

DATA SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Services. In the event we become aware of a data security incident that compromises the confidentiality or integrity of your Personal Information, we will investigate and take reasonable steps to mitigate the incident, and where required by law, notify you and/or relevant authorities.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the website home page at firstthen.com. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the website home page at firstthen.com. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

RELATIONSHIP TO TERMS OF USE

Your use of the Website and Services is subject to our Terms of Use and any applicable consent forms, including their provisions on limitations of liability, dispute resolution, and governing law. If there is any conflict between this Privacy Policy and the Terms of Use, the Terms of Use will control to the extent of the conflict, unless otherwise required by applicable law.

THIRD PARTIES

This Privacy Policy does not create rights enforceable by third parties, nor does it require us to take any actions beyond those required by applicable law.

COMPLAINTS AND ADDITIONAL INFORMATION

If you believe your privacy rights have been violated by FirstThen or if you wish to file a complaint or to ask questions or comment about this privacy policy and our privacy practices, contact us at: support@firstthen.com. You will not be retaliated against for exercising any of your privacy rights or for choosing to file a complaint with FirstThen.