Privacy Policy

Effective Date: September 22,2025

OUR COMMITMENT

FirstDate.com (“First Date”), which is operated by Reflex Media, Inc. (“Reflex”) respects your privacy. We are committed to protecting the privacy of our users and we want to provide a safe and secure user experience. We will use our best efforts to ensure that the information you submit to us remains private and is used only for the purposes set forth herein. This policy details how data about you is collected, used, and shared when you access our website or interact with us.

APPLICABILITY OF PRIVACY POLICY

This privacy policy applies to all information we collect through the First Date website (the “Website”). When you are no longer a visitor or user of the Website, we continue to share your information as described in this policy. This policy only applies to the Website and does not apply to the practices of any other Reflex website or service. This policy also covers our treatment of any personally identifiable information that our business partners share with us.

REFLEX MEDIA AFFILIATES

Reflex is affiliated with various entities. These entities are as follows:

• Clover8 Investments Pte Ltd.
• W8 Tech Limited (Hong Kong)
• W8 Tech Limited (Cyprus)
• W8 Tech Limited, Inc. (USA)

INFORMATION COLLECTED

Reflex collects data to operate effectively and provide better quality experiences. If you do not agree to our collection of information, you may be limited or restricted in the content available to you.

HOW REFLEX USES PERSONAL DATA:

First Date uses this information to:

• Provide, maintain, and improve the Website;
• Inform you of updates to our services, security alerts, and other support and administrative messages;
• Communicate with you about products, services, offers, promotions, and events, and provide other news and information we think will be of interest to you; and
• Monitor and analyze trends, usage, and activities in connection with the Website.

WEBSITE VISITORS

We gather information about all users collectively, such as what areas users visit most frequently and what services users access the most. We only use such data anonymously. This information helps us determine what is the most beneficial for our users and how we can continually create a better overall user experience. We may share anonymized information with our partners so that they may also understand how visitors use our Website. We may use data stitching, which is the process of combining your datasets from multiple sources, to better track website use. Our Website uses Google Analytics. To learn more about how Google Analytics collects and uses data, or to opt out, click HERE.

INFORMATION FROM MINORS

We do not knowingly solicit, collect, or share information from any individuals under the age of 18.

DEVICE FINGERPRINTING

We collect certain software and hardware information from the devices you use to access our Website. This information is used to help identify you, for analytics purposes, and to detect suspicious activity.

COOKIES

When you utilize the Website, we—along with certain business partners and vendors—may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies as outlined in the “How Your Information Is Used Section.” Certain aspects and features of the Website may only be available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Website may be limited.

DO NOT TRACK

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not respond to DNT signals.

SHARING INFORMATION

When you use the Website, certain information may be shared. For example:

• We will not share, sell, or give away any of our users’ personal information to third parties, unless one of the following circumstances applies:
• We may share information with vendors, consultants, and other service providers who need access to such information to carry out work for us. A complete list of the types of these third parties is at Appendix I at the end of this Policy. These companies may have access to your personal information as necessary to perform their functions, and they are contractually obligated to maintain the confidentiality of any personal information in which they come in contact as part of their services to First Date.
• If you participate in promotions, special offers, or other events or activities in connection with the Website, we may share information with entities that partner with us to provide these offerings;
• We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to meeting national security or law enforcement requirements;
• We may share information in response to an emergency if we believe it is necessary to prevent imminent and serious bodily harm to a person;
• We may share aggregated or anonymized information, which cannot reasonably be used to identify you;
• We may share information between and among First Date, and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• We may share information with your consent or at your direction.

DOMESTIC DATA

First Date is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information to us, You consent to the processing, transfer, and storage of information in and to the U.S.

California

Pursuant to the California Consumer Privacy Act (the “CCPA”), we are required to disclose the categories of Personal Data we collect from You and how we use it, as well as the third parties with whom we share it, which we have explained above and in Appendix I.

The CCPA provides California consumers, defined as “natural persons who are California residents,” with certain rights under the CCPA.  These rights are as follows:

• You have the right to know and request information regarding the categories of Personal Data:
  • We collect, use, or share;
  • The purposes for which these categories are collected or used by us;
  • The sources from which we collect Personal Data; and
  • The specific Personal Data we have collected about you.
• You have the right to equal service.  Reflex and will not discriminate against You for exercising your privacy rights under California law.
• You have to right to request deletion of your Personal Data.

To request access to or deletion of your Personal Data, please contact Reflex at the following email: [email protected] or via our toll-free telephone number: 1-888-928-3887.  Any requests are subject to identity verification.

Reflex does not sell the Personal Data of our users.

Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah & Virginia

Under Colorado’s Consumer Privacy Act (the “CPA”), Connecticut’s Data Privacy Act (the “CTDPA”), Delaware’s Personal Data Privacy Act (the “DPDPA”), Iowa’s Consumer Data Protection Act (the “ICDPA”), Montana’s Consumer Data Privacy Act (the “MTCDPA”), Nebraska’s Data Privacy Act (the “NDPA”), New Hampshire’s Privacy Act (the “NHPA”), New Jersey’s Data Privacy Law (the “NJDPL”), Oregon’s Consumer Privacy Act (the “OCPA”), Texas’ Data Privacy and Security Act (the “TXDPSA”), Utah’s Consumer Privacy Act (the “UCPA”), and Virginia’s Consumer Data Protection Act (the “VCDPA”), residents of these states have certain rights around collection, use, and sharing of their Personal Data. These rights are as follows:

• You have the right to confirm processing and to know and request information regarding the categories of Personal Data:
  • We collect, use, or share;
  • The purposes for which these categories are collected or used by us;
  • The sources from which we collect Personal Data; and
  • The specific Personal Data we have collected about you.
• You have the right to equal service.  Reflex and will not discriminate against You for exercising your privacy rights under Colorado or Connecticut law.
• You have the right to request deletion of your Personal Data.
• You have the right to correct your Personal Data.

Reflex does not sell the Personal Data of our users and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law. Similarly, Reflex does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. Reflex may engage in “targeted advertising” as that term is defined in the CPA, CTDPA, MTCDPA, OCPA, TXDPSA, and the VCDPA. You have the right to opt-out of targeted advertising here.

Any requests are subject to identity verification.

Nevada

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operator may collect about them.  Reflex does not sell the Personal Data of our users and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.

INTERNATIONAL DATA

First Date is a worldwide service. We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law.

European Union; European Economic Area; Switzerland

In connection with First Date’s processing of personal data received from the European Union and Switzerland, we adhere to the E.U. General Data Protection Regulation (the “GDPR”) and the Swiss Federal Act on Data Protection (the “SFADP”) and comply with their frameworks and principles.  Please direct any inquiries or complaints regarding our compliance with GDPR or SFADP to the email listed in the “Data Protection Officer” section below. If we do not resolve your complaint, you may submit your complaint free of charge to the International Centre For Dispute Resolution-American Arbitration Association (ICDR-AAA) based in the United States. Under certain conditions, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the E.U. and Switzerland. If we share E.U. or Swiss data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of E.U. or Swiss data in violation of the GDPR or SFADP, unless we can prove that we are not responsible for the event giving rise to the damage.

United Kingdom

In connection with First Date’s processing of personal data received from the United Kingdom (the “U.K.”), we adhere to the U.K. GDPR/2018 Data Protection Act (the “U.K. GDPR”) and comply with its frameworks and principles.  Please direct any inquiries or complaints regarding our compliance with U.K. GDPR to the email listed in the “Data Protection Officer” section below. If we do not resolve your complaint, you may submit your complaint free of charge to the International Centre For Dispute Resolution-American Arbitration Association (ICDR-AAA) based in the United States. Under certain conditions, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.K. If we share U.K. data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of U.K. data in violation of the U.K. GDPR, unless we can prove that we are not responsible for the event giving rise to the damage.

Brazil

In connection with First Date’s processing of personal data received from Brazil, we adhere to the Brazilian General Data Protection Law (Lei Geral de Protecao de Dados Pessoais) (the “LGDP”) and comply with its frameworks and principles.  Please direct any inquiries or complaints regarding our compliance with LGPD to the email listed in the “Data Protection Officer” section below.

New Zealand

In connection with First Date’s processing of personal data, we adhere to the New Zealand Privacy Act.  Please note that while First Date strives to ensure the privacy of your personal data, by using the Services your personal data may not be given the same protection as provided by the New Zealand Privacy Act.

PROTECTION & STORAGE OF PERSONAL INFORMATION

Your personal information is protected by physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. We also use computer safeguards such as firewalls and data encryption. In addition, we enforce physical access controls to our offices and files, and we authorize access to users’ personal information only for personnel who require it to fulfill their job responsibilities. We strive to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial, and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well. First Date may post a notice on the Website if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us of your request here.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. We will place any updates to this policy on our Website. You may also request a paper copy of the Privacy Policy by contacting us at the email or address noted below. You are bound by any changes to the Privacy Policy by using the Website after such changes have been posted to the Website.

DATA PROTECTION OFFICER

To communicate with our Data Protection Officer, please email [email protected].

CONTACT US

If you have any questions, You can contact Reflex at the following email [email protected] or at the following addresses Reflex Media, 3250 Pepper Ln, Las Vegas, NV 89120. 

You can also contact our Data Protection Officer at the e-mail noted above, or our Data Protection Representative located in the EU, EEA, or Switzerland at www.datarep.com/reflex or, or our Data Protection Representative located in the U.K. at www.datarep.uk/reflex, or write to:

• DataRep, 72 rue de Lessard, Rouen, 76100, France
• DataRep, Leutschenbachstrasse 95, Zurich, 8050, Switzerland
• DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom

APPENDIX I

Types of Reflex Vendor Third Parties

• Web server hosting
• Data analysis
• Marketing services
• Security services
• Card and payment processors

To receive a copy of the complete list of third parties, please contact [email protected] and use the subject line “Third Party Request”.  The list is proprietary and confidential and may not be used for any other purpose or distributed in any form; violation of this requirement is a violation of the Terms of Use governing this site, and its use and is subject to the Commercial Use provisions in the Terms of Use.