Privacy Policy

The First Click ("we", "us", "our") publishes curated news and insights at www.the-first-click.com. We believe a publication built for the age of AI has a heightened duty of transparency about data. This policy explains what personal information we collect, why we collect it, how we use and protect it, and the choices you have.

We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where they apply to readers outside Canada, the EU/UK General Data Protection Regulation (GDPR) and comparable laws.

1. Information we collect

Information you give us directly

• Account and subscription details — your name, email address, password, and the tier you hold (Free, Ad-Free, Premium, or Black).
• Waitlist and newsletter sign-ups — your email address and communication preferences.
• Referral activity — if you participate in our referral programme (which can earn Ad-Free access), we record the referrals attributed to you and the email addresses of people who sign up through your link. We never let you enter someone else's email on their behalf; invitees always opt in themselves.
• LinkedIn connection — if you claim the free year of Premium by connecting a LinkedIn profile, LinkedIn passes us the profile identifier it issues when you approve the connection (an opaque ID), together with your name and the email address on your LinkedIn account. The identifier is the thing your free year is attached to. The name and email are written into our record of the connection and used for nothing else: we never change the email address you sign in with, we do not post anything to LinkedIn on your behalf, and we do not read your connections. Connecting LinkedIn does not change how you sign in here.
• Payments — if you purchase a Premium or Black subscription, payment is processed by our payment provider. We receive confirmation of payment, the last four digits of your card, and billing country — never your full card number.
• Correspondence — anything you send to us by email or through forms on the site.

Information collected automatically

• Usage data — pages viewed, links clicked, newsletter opens and clicks, approximate location derived from IP address, device and browser type.
• Cookies and similar technologies — used for sign-in sessions, remembering preferences, measuring readership, and (on the ad-supported tiers) serving advertising. See section 6.

What we do not collect. We do not knowingly collect sensitive personal information (health, financial account details beyond payment processing, government identifiers) and we do not buy personal data about our readers from data brokers.

2. Why we collect it

We collect and use personal information to:

• deliver the publication, newsletters, and subscription tiers you have chosen;
• administer accounts, referrals, billing, and refunds;
• understand what our readers find valuable, so our editors can improve coverage;
• serve and measure advertising on the ad-supported tiers, which are Free and Premium (Black members, and anyone holding earned Ad-Free status, are not shown ads);
• secure the platform, prevent fraud and referral abuse, and meet legal obligations.

We rely on your consent, the performance of our contract with you, and our legitimate interests in operating a sustainable publication, as applicable. Where consent is the basis, you may withdraw it at any time.

3. AI and your data

Our editorial pipeline uses AI systems to help aggregate and organise the news (see our AI Use Declaration). Your personal information is not used to train AI models, and reader data is not fed into third-party model training. AI-assisted personalisation, where offered, operates on your reading activity within our platform only, and always under human-defined editorial rules.

4. Sharing and disclosure

We do not sell personal information. We share it only with:

• Service providers who process data on our behalf — hosting, email delivery, payment processing, and analytics — under contracts that limit their use of your data to our instructions;
• Advertising partners, only in respect of readers on the ad-supported tiers and only in aggregate or pseudonymous form for ad delivery and measurement — editorial data and member lists are never given to advertisers (see our Advertising Policy);
• Legal authorities, where required by law or to protect our rights, readers, or staff;
• A successor organisation, if The First Click or Agency of Strategy Inc. is involved in a merger, acquisition, or asset sale — with notice to you.

Some service providers are located outside Canada (for example, in the United States or the European Union). Where personal information is processed abroad, it remains subject to the laws of those jurisdictions; we use contractual safeguards to require an equivalent standard of protection.

5. Retention

We keep personal information only as long as needed for the purposes above: account data for the life of your account plus a short administrative period; billing records as required by tax law (generally seven years); analytics in aggregated or pseudonymised form. When you delete your account, we remove or anonymise your personal information within 30 days, except records we must keep by law.

One anti-abuse exception, stated plainly because it outlives your account: if you connected a LinkedIn profile to claim the free year of Premium, we replace that profile identifier with a one-way hash of it when you close the account and keep the hash. It cannot be turned back into your LinkedIn profile and it is used for exactly one thing — recognising that the offer has already been claimed once, so closing an account and opening a new one cannot claim it again.

6. Cookies and choices

We use strictly necessary cookies (sign-in, security), preference cookies, analytics cookies, and — on the ad-supported tiers only — advertising cookies.

If you are reading from the UK, the European Economic Area or Switzerland, analytics and advertising cookies are switched off until you allow them: our measurement and advertising tags start in a restricted mode that sets no such cookies and does not personalise advertising. Elsewhere they are on by default. You can also block or delete cookies at any time in your browser settings.

Refusing advertising cookies does not remove ads on the ad-supported tiers, but the ads shown will not be personalised.

7. Your rights

Subject to applicable law, you may:

• access the personal information we hold about you and ask how it has been used and disclosed;
• correct inaccurate or incomplete information;
• withdraw consent to uses that rely on it (for example, unsubscribe from any newsletter with one click);
• delete your account and associated personal information;
• complain — first to us, and if unresolved, to the Office of the Privacy Commissioner of Canada (priv.gc.ca). Readers in the EEA/UK may contact their local supervisory authority.

To exercise any right, email support@the-first-click.com. We respond within 30 days.

8. Security

We protect personal information with encryption in transit, access controls, audit logging, and the principle of least privilege across our systems. No method is perfectly secure; if a breach creates a real risk of significant harm to you, we will notify you and the Privacy Commissioner as PIPEDA requires.

9. Children

The First Click is not directed at children under 16, and we do not knowingly collect their personal information. If you believe a child has provided us data, contact support@the-first-click.com and we will delete it.

10. Changes to this policy

We will post any changes here and update the date above. For material changes, we will notify members by email before the changes take effect.

11. Contact

Privacy Officer, The First Click
Agency of Strategy Inc.
Email: support@the-first-click.com