Legal & Help

Privacy policy

Last updated: May 19, 2025

Welcome to Firstline! Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you use the Firstline Platform, including our website, CRM system, mobile application, or other services. By using the Firstline Platform, you consent to the collection, use, disclosure, and storage of your personal data as described in this Policy. If you do not agree with these terms, please discontinue use immediately.

This Privacy Policy complies with international data protection laws, including:

• European Union (GDPR): General Data Protection Regulation.
• United States (CCPA): California Consumer Privacy Act and other state privacy laws.
• United Arab Emirates (PDPL): Federal Decree-Law No. 45 of 2021 on Personal Data Protection.
• Other regional laws: Including laws in Asia-Pacific countries (e.g., DPDPA in India) and Australia.

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1. INFORMATION WE COLLECT

In general, we only collect information that allows us to provide you with our services at the highest level. This includes, in particular, performing simple actions, for example, allowing other users to see your profile: your name, photo, phone number, email that you'll choose to show. It also helps us protect our services from fraudulent activity and spam, and gives us a unique understanding of what additional services may be useful.

Thus, we may collect and process the following types of personal data and restaurant staff data and any customer data that may be transmitted through the platform:

1.1 Information You Provide

• Name, age, email address, phone number.
• Payment details (e.g., bank account or card information).
• Photos and reviews.

1.2 Automatically Collected Information

• Device information (e.g., operating system and model).
• IP address and location data (if permitted).
• Usage data and analytics.

1.3 Information from Third Parties

• Data from social media platforms.
• Information shared by partner businesses (e.g., restaurants).

2. PURPOSES OF DATA PROCESSING

We process your personal data for the following purposes:

• Service Provision: To register accounts, manage profiles, and provide personalized services.
• Payment Processing: To securely process payments via third-party providers.
• Loyalty Program Management: To track and manage Firstline Points.
• Analytics: To improve customer experience through insights.
• Marketing Communications: To send promotional materials (with user consent).
• Fraud Prevention: To monitor suspicious activity and ensure platform security.
• Compliance: To meet legal obligations under applicable laws.

3. DATA RETENTION

We retain your information only as long as necessary to fulfill the purposes outlined in this Policy or comply with legal requirements:

• Personal data is stored securely until it is no longer needed for processing purposes.
• After this period, data will be deleted or anonymized.
• You may request deletion of your data at any time by contacting us at support@firstlinevip.com.

4. REGIONAL FEATURES

4.1 European Union (GDPR)

Residents of the EU have the following rights: Right to Access, Right to Rectification, Right to Erasure ("right to be forgotten"), Right to Restrict Processing, and Right to Data Portability.

4.2 United States (CCPA)

California residents have additional rights: Right to Know, Right to Delete, and Right to Opt-Out (Note: Firstline does not sell personal data).

4.3 United Arab Emirates (PDPL)

Under UAE law, personal data is processed only with explicit consent and cross-border transfers are conducted with adequate safeguards.

4.4 Asia-Pacific Region

Specific requirements include India (DPDPA) regarding sensitive personal data and Australia regarding child safety and automated decision-making.

5. SHARING YOUR INFORMATION

We may share your information with Partner Businesses (for loyalty programs), Service Providers (payment processors, cloud hosting), and Legal Authorities (when required by law).

6. SECURITY MEASURES

We implement robust security measures: Encryption protocols for sensitive data, secure servers, and firewalls. However, users are responsible for safeguarding their login credentials.

7. COOKIE POLICY

We use cookies for Essential functionality, Performance analytics, and Marketing promotions. You can manage preferences through your browser settings.

8. CHILD SAFETY POLICY

Our services are not intended for individuals under 18. We do not knowingly collect information from children and comply with COPPA and GDPR child safety standards.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Policy periodically. Changes will be posted with a revised "Last Updated" date. Users will be notified via email at least 14 days before changes take effect.

10. CONTACT INFORMATION

If you have questions or wish to exercise your rights, please contact us at:

Email: support@firstlinevip.com
Address: SESSSIAWL MARKETING MANAGEMENT L.L.C
Onyx Building G-06-02, Al Khabeesi 60-0
Dubai, UAE

Terms of use for partners

These Terms of Use (hereinafter referred to as the "Rules") are binding on commercial organizations that accept all the terms of the Rules (hereinafter referred to as the "Partner") by using the business version of the Firstline platform from the following link: https://firstlinevip.com.

These Rules have been approved by the Limited Liability Company SESSIA, registered and existing in accordance with the legislation of the USA under File No. 7045651, hereinafter referred to as the "Company", and come into force from the date of acceptance by the Partner of all the conditions established by the Rules and posted at the following address on the Internet: https://firstlinevip.com dated April 03, 2025.

Each of the Parties - the Company and the Partner - may be referred to in this document as a "Party" or collectively as the "Parties". Capitalized terms used in the Rules without definition have the meanings given in section 3 below.

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1. ACCEPTANCE OF THE RULES

When registering on the Firstline platform by clicking the "Continue" button or by any other action expressing explicit consent to use the Firstline platform by integrating it with any existing Partner’s systems, such as reservation systems (e.g., SevenRooms), payment systems, or any other tools that automate the transfer of customer data, the Partner's authorized representative ("Authorized Representative") accepts the Rules on behalf of the Partner, agrees to the Privacy Policy available at https://firstlinevip.com, and confirms that the Authorized Representative:

• (a) is authorized to accept these Rules and the Privacy Policy on behalf of the Partner; and
• (b) has reviewed and understood these Rules.

By accepting these Rules, the Partner agrees to their binding nature as if they were or, when necessary are to be additionally executed in writing and signed by both Parties' Authorized Representatives.

Additionally, the Partner may download the Firstline platform free of charge and configure their loyalty programs within the Firstline application.

2. PARTNER REGISTRATION

The Partner is obliged to provide all the necessary data, including corporate, banking and legal information about their activities. The Partner represents and warrants that the information provided to the Company about the Partner and their activities is true, accurate and complete. In particular:

• Your company name and other corporate organizational information
• Your business email address and the identity of the designated contact person
• Your business address and phone number
• Your registration number and Tax Identification Number
• Your bank account, credit card account, and checking accounts, which will be used to open, fund and maintain your Firstline wallet using the Currency as defined below.

3. DEFINITIONS

Unless otherwise provided by these Rules, the following terms shall be defined as follows:

• "Applicable Law" means any international, federal, state or local law, regulation or rule that governs or pertains to these Rules or any services or transactions related to these Rules
• "Customer" means any customer, user, buyer, person or entity that uses the Firstline platform to purchase or initiate transactions with a Partner. Furthermore, a Customer may also be any individual who visits a Partner’s business as a result of a post published in the feed of the Firstline application.
• "Firstline Platform" means any of a comprehensive free-to-download and use digital solution (website, CRM. mobile or other application) encompassing programmatic tools designed to streamline business operations for analytics, communication, and operational efficiency that operates loyalty program management, marketing tools, facilitates efficient data handling, customer relationship management, and integration with third-party systems to provide real-time synchronization and automation.
• "Firstline Points" means rewards accrued to a Customer who purchases goods or services from any Partner, invites another user or company to join Firstline, and such invited or interacted user or company purchases goods or services from any Partner through Firstline.
• "Firstline Commission" refers to the charges applied to Partners for using the platform’s services, including transaction processing, Firstline Points distribution, and account maintenance. These fees are deducted from the Partner’s Firstline Wallet or transactions.
• "Friends and Benefits" means users who were engaged to visit a participating Partner and become its Customer by viewing a Customer’s post on the Firstline Social Feed.
• "VIP Credits" means Firstline Points received by Customers after making a purchase.
• "Royalties" means Firstline Points received by users for engaged Friends and Benefits or interacting in promotional activities.
• "Currency" means the local currency of Firstline, equivalent 1:1 to the local currency of the country chosen by the Partner as the main currency in the Firstline account. The application currency is intended for use by the Partner: (i) to pay out Firstline Points to the Customer who buys goods and services using Firstline; (ii) to give out Firstline Commission. The Company reserves the right, at its sole discretion, to use another or additional currency for issuing Firstline Points in order to create additional liquidity for all users.
• "Wallet" means a secure and internal digital wallet on the Firstline platform that allows: (a) Partners to fund their Currency balances, from which Partners can pay Firstline Points in the form of Currency; (b) Customers to accumulate Firstline Points they receive from Partners; and make purchases from other Partners. For the avoidance of any doubt, each Partner or Customer must own and control their own Wallet, and transactions made using the Wallet are the sole responsibility of its owner.

4. INFORMATION AND LICENSES

The Company or its legal and authorized licensors own all names, property rights, and interests, including but not limited to all copyrights, trademarks, and other intellectual property rights on the Firstline platform.

The Company grants the Partner a non-exclusive, non-transferable license to display certain Company logos and trademarks, which the Company may, from time to time, place at the Partner’s locations and on the Partner’s websites for the sole purpose of advising the Partner’s customers at the location and on the Partner’s website(s) about the Partner’s acceptance of Firstline Points transactions.

The Partner acknowledges that they are prohibited from using, reproducing, decompiling, reverse engineering, modifying, or distributing any Firstline platform. The Partner acknowledges that the transactional data processed by the Company is the property of the Company for current and future use.

5. PARTNER'S INTELLECTUAL PROPERTY

The Partner hereby grants the Company a non-exclusive, non-transmissible, non-transferable, royalty-free license to use the Partner’s trademarks, service marks, and logos ("Partner Trademarks") solely for the purposes of marketing and providing services to the Company, the Firstline website, and platform.

Additionally, the Partner grants the Company permission to use and publish any photographs owned by the Partner in the feed of the Firstline application or other promotional materials related to the platform.

6. FIRSTLINE ACCOUNT AND PARTNER ACCOUNT

To ensure uninterrupted reward distribution, the Partner must maintain a minimum balance of 10,000 AED (UAE Dirhams) in their Firstline Wallet at all times. The wallet can be replenished using one of the following methods:

• (i) bank transfer to the Company's account;
• (ii) payment with a corporate credit card; or
• (iii) an electronic wallet connected to Firstline ("Replenishment").

When a Customer pays their bill, Firstline will automatically deduct from the Partner’s wallet the equivalent amount of Firstline Points accrued to the Customer and transfer it to the Customer’s wallet. Additionally, for every 1 unit of Currency (e.g., 1 AED, USD, etc.) in Firstline Points accrued to the Customer, a Firstline Commission of 0.20 units of Currency will be deducted from the Partner’s Wallet and transferred to the Company’s Wallet as a service commission.

The use of Firstline Points by Customers may be subject to restrictions and conditions outlined in Section 11 of these Rules.

Replenishing the Firstline Wallet does not constitute a purchase of any product or service from the Company but merely represents a deposit into the Partner's account. The Partner retains the right to withdraw any remaining funds from their Firstline Wallet, minus applicable fees as determined by relevant payment systems or the Company.

If the balance in the Partner’s Firstline Wallet falls below 10,000 AED or is insufficient to cover the required deductions for Customer Firstline Points and service fees, transactions involving Firstline Points will be rejected until the Partner replenishes their account. This ensures that all reward payouts are processed seamlessly and without interruption.

The Firstline Platform allows a Partner to assign four (4) levels of access and control over a Partner’s Firstline account to Partner employees and representatives as follows:

• "Editor". The Editor can only edit products, text descriptions, and content in the Firstline Platform Partner’s profile. The Editor has no right to accrue Firstline Points to Customers and other users.
• "Cashier". The Cashier has the right to distribute and approve Firstline Points to End Customers and other users.
• "Administrator". The Administrator has the right of an editor and a cashier and can grant access to any employee and representative of the Partner.

The Partner is responsible for providing truthful profiles of all of the Partner’s editors, cashiers, and administrators without omitting or misrepresenting any material information that could compromise the integrity of an employee or representative or their ability to conduct business through Firstline without committing fraud or other illegal activities.

In order to avoid any doubt, the Company does not act as a credit card company, a payment processing agent, or a handling agent between the Partner and the Customer. When the Customer purchases goods or services, the Customer pays the Partner directly to the bank account specified by him using a credit card, debit card in accordance with the Partner's own instructions and policies. The Company is not responsible for and does not participate on behalf of any Partner, business, or other person in the collection of payments for the purchase of any goods or services by any End Customer or other customer.

The Partner is solely responsible for ensuring how they conduct transactions, including the accrual of Firstline Points to Customers, in a Currency that is permitted and not prohibited in the country(s) and jurisdictions in which the Partner operates. The Partner shall be solely responsible for the compensation of damages, defense, and indemnification of the Company, as well as all its beneficiaries and officials, for all claims, actions, or liability arising from any transactions with Currency that violate the law of any state.

7. CUSTOMER FIRSTLINE ACCRUAL

As far as Firstline integrates with reservation systems like SevenRooms or other similar to enable automated data exchange, when a Customer who is a user of the Firstline Application makes a purchase, the Partner identifies the Customer, locating them by phone number or using their member code, (depending on system applied). Thus, when a Customer completes a purchase, Firstline automatically receives transaction data within 30 minutes, and that transaction is automatically published in the Firstline Social Feed, visible to friends, followers, and other users because while making a reservation through such systems, a phone number linked to a Customer's Firstline account. Only the Customer can further edit the post by adding images or details about the purchase. Friends and followers can interact with the post by liking, commenting, or sharing it on other social networks, generating new customers for the Partner.

Based on transaction data, Firstline points are credited as follows:

• VIP Credits: Automatically credited to the Customer’s account after each purchase. The Partner is responsible for determining the rates of VIP Credits. The percentage must be specified by the Partner in their settings on the Firstline platform.
• Royalties: Automatically credited to the account of the Customer who engaged Friends and Benefits after those individuals make purchases from any Partner. The Partner also determines the rates of Royalties. The percentage must be specified by the Partner in their settings on the Firstline platform.

The Partner may modify the rates of both VIP Credits and Royalties at their discretion. However, any changes to these rates will not affect transactions already completed by Customers. The rates of VIP Credits and Royalties applicable to a specific Customer will be fixed based on the rates in effect on the date their transaction is published in the Firstline Social Feed. For clarity, the date of publication of a Customer's receipt in the Firstline Social Feed will serve as the reference point for determining the applicable VIP Credits for that transaction and Royalties rates for transactions caused by such publications.

The Partner is required to ensure that all changes to VIP Credits and Royalty rates are promptly updated on the Firstline platform and communicated clearly to Customers, where applicable, to maintain transparency and compliance with these Rules.

8. SETTING UP THE FIRSTLINE POINTS AND FIRSTLINE SYSTEM, COMPANY COMMISSIONS

In order to develop the Firstline network, the Partner undertakes to conclude a partnership agreement with the Company (hereinafter referred to as the "Partnership Agreement") in a written form approved by the Company, which will determine the conditions for crediting the initial Currency to the Partner's Wallet, the amount of commission payable to the Company for using Firstline, conditions for the promotion of Partners in the Firstline application.

On the Firstline platform, the Partner will be able to amend by itself or by sending an email to the Company to ask them to set different Firstline Points rates for different types of goods and services (for example, a restaurant can optionally pay higher Firstline Points for alcohol and exotic dishes and lower Firstline Points for main dishes or services). The Partner will be able to change and save their Firstline Points and bonuses on the Firstline platform in real-time in accordance with their changing menus and offers.

The Partner is solely responsible for researching, discovering, becoming aware of, and complying with all Applicable Laws of the country or jurisdiction in connection with the issuance of any Firstline Points through Firstline.

The Company shall display and maintain a rating system for each Partner based on the comments, likes and other feedback on the Firstline Social Network, as further set out in clause 10 below. The Company has the right, at its discretion, to create a system of ratings and methods by which the Company evaluates each Partner in comparison with other Partners on the Firstline platform.

9. FIRSTLINE FEED AND INFORMATION DISCLOSURE

When a Customer makes a purchase (by cheque, bank card, or Currency), the Company in the internal feed of the Firstline Social Network (i) displays a copy of the cheque, debit or credit card receipt; (ii) names the Partner; and (iii) identifies the item, product, or service so that friends, followers and other Firstline users can view, comment, like, and, ultimately, purchase from that Partner, which in turn will result in Firstline Points, issued by the Partner to the Customers and their Friends and Benefits under the Partner’s Firstline Points and loyalty programs.

In order to avoid any doubt, only the End Customer can take a photo of the check and/or receipt of the transaction and allow its publication on the Firstline Social Network, not the Partner.

10. CONTENT OF USERS/PARTNERS ON THE SOCIAL NETWORK, ONLINE STORE AND ON THE FIRSTLINE PLATFORM

The Company hereby prohibits any Partner, user, or Customer from engaging in, writing, entering, displaying, or uploading offensive or profane content, including any language or content that is considered, in the Company's sole discretion, to be obscene, propaganda, or intolerance based on religion, sexual orientation, race, or ethnic origin.

The Company prohibits the marketing, advertising, promotion, and sale of goods, services, products, or other items that promote hatred, violence, racial, sexual, or religious intolerance or promote organizations with such views using Firstline.

The Company has the sole right, in its sole discretion, to remove or modify any objectionable material or material that violates the provisions contained in this clause 10, as well as additionally suspend, cancel, revoke, or terminate the membership of any violator: Partner, Customer, other Firstline users or users associated with them.

Customers and other users warrant that they are at least 16 years of age before creating a Firstline account. Partners are prohibited from engaging in transactions with Customers under the age of 16; in the event that the Partner discovers any person under the age of 16 attempting to use Firstline, the Partner must disclose it to the Company so that the Company can delete and terminate the account of this underage user.

The Partner is solely responsible for indemnifying, protecting, and releasing the Company, as well as all its beneficiaries and officials, from liability for all claims, actions, or liabilities arising from the Partner's violation and/or non-compliance with this clause 10.

11. PARTNER REFUND TERMS

Each Partner is solely responsible for establishing their own refund policy in compliance with applicable laws and regulations governing their operations.

Partners must clearly define the conditions under which refunds are allowed, including but not limited to:

• The eligibility criteria for refunds (e.g., defective goods, canceled services).
• The timeframe within which a refund request can be made (e.g., 14 days or as required by law).
• The method of refund (e.g., to the Customer’s original bank account or payment card).

For Clients of Partners subject to legally mandated refund procedures, Firstline Points accrued from a transaction will only become available for use by the Customer after the expiration of the legally prescribed refund period. During this period, the Firstline Points will remain in a pending state and cannot used by the Customer.

If a Customer requests and is granted a refund, the following process applies:

• The equivalent amount of Firstline Points credited to the Customer for the refunded transaction will be deducted from their Wallet within 24 hours of refund confirmation by the Partner. The Firstline system will automatically return the deducted Firstline Points to the Partner’s Wallet.
• The Partner acknowledges that all disputes related to refunds are solely between the Partner and the Customer and that Firstline is not a party to such disputes. The Company does not act as a buyer or seller of goods, services, or products offered by Partners on the Firstline platform and is not responsible for enforcing any refund policies or resolving disputes related thereto.

12. PROHIBITED ITEMS AND GOODS

The following goods, items, services, and other products must not be offered or sold through the Firstline application, website or Firstline platform: pornographic materials and items; animals and wildlife products; funeral accessories; counterfeit currency, stamps or items, credit cards; narcotic substances and preparations, as well as equipment and items for their creation and use; prohibited goods from prohibited countries; firearms, ammunition, copies of weapons; state identity cards and licenses; human remains and body parts; devices for breaking locks; lottery tickets; mailing lists and personal data; seals and stamps; medical equipment; prescription and over-the-counter drugs; satellite and cable television descramblers; shares and other securities; stolen property; surveillance equipment; tobacco and tobacco products (including electronic cigarettes and vapes, cigars and smoking accessories); prohibited plants and seeds. Notwithstanding the foregoing, the purchase of alcohol and tobacco through Firstline is only permitted to the extent that the Customer consumes alcohol or tobacco in a restaurant, bar, café, bistro, diner, cafeteria, or other food service establishment in accordance with the Partner's compliance with Applicable Laws and Regulations in the jurisdictions in which the Partner is located. The Company under no circumstances is engaged in the advertising and promotion of tobacco and alcohol products, and any responsibility for violations of this rule rests with the Partner.

13. TAXES

All Firstline Partners and Customers are solely responsible for reporting, disclosing to government authorities, and paying all applicable taxes on all sales of Value Added Tax (VAT) and other taxes relating to the sale and/or purchase of goods, products, services and other items (''Sales Tax") via Firstline in each applicable jurisdiction. Each Partner is responsible for charging and collecting sales tax directly from the Customer, and the Company is not responsible for its collection and does not refund these taxes.

To the extent that any jurisdiction assesses taxes on refunds and/or kickbacks issued to any Customer or user on the Firstline Platform, the Partner and the Customers are solely responsible for reporting, complying with, and paying the applicable income taxes and all other taxes in connection therewith.

The Company is not responsible for reporting or paying sales tax, income tax, or any other tax on behalf of any Partner, Customer, or other Firstline user. Each Partner and Customer shall be solely responsible for covering damages, defending and indemnifying the Company, as well as all its beneficiaries and officials, for all claims, actions, or liability arising from a violation of the terms of this clause 13.

14. ADDITIONAL WARRANTY

The Partner represents and warrants during the Term that: (a) Partner will at all times comply with all Applicable Laws and will not receive or transfer funds through Firstline or use Firstline for any illegal, fraudulent or misleading activity, including illegal gambling, money laundering or terrorist financing; (b) all information about the Partner and their activities provided by the Partner to the Company is true, accurate and complete; (c) Partner shall refrain from any unfair trading practices as defined in the laws of relevant jurisdictions, including, but not limited to, false or misleading advertising, harassment of other Firstline users, and false and defamatory statements about any competing Partner; (d) promptly respond to questions and comments from Firstline users through the Firstline support service available on the Firstline application; (e) Partner has the necessary rights, powers and opportunities to enter into these Rules and the Partner Agreement and fulfill its obligations.

In addition to the foregoing, the Partner also represents and warrants that:

• The Partner does not conduct business in any country blacklisted by the International Task Force on Financial Action (Money Laundering) (FATF), and also does not have its affiliates and subsidiaries and local bank accounts there;
• The Partner's authorized officials are of legal age to enter into a binding contract and no court has prevented any agreements from being entered into;
• The Partner has not previously been suspended or excluded from Firstline.

The Partner is solely responsible for informing the Company in the event of a change in any of the above warranties and representations as a result of a future event, as well as for covering damages, defending and indemnifying the Company, as well as all its beneficiaries and officials for all claims arising from the foregoing responsibility. The detection by the Company of violations of the warranties or representations of the Partner contained in accordance with this clause 14 will lead to the immediate termination by the Company of these Rules and the Partnership Agreement, as additionally specified in clause 17 of these Rules.

15. TERM OF RULES

The term of these Rules begins on the Effective Date and continues until the earlier of the following events: (i) the Partner's account on Firstline is deleted, either at the initiative of the Partner or the Company, based on the grounds set forth in these Rules and the Partnership Agreement; or (ii) the Partner ceases to use the Firstline platform for any reason. Upon termination of this agreement, all obligations arising under these Rules shall cease, except for those expressly stated to survive termination.

16. TERMINATION

If a Partner violates any of the Partner’s obligations, representations, or warranties, or for reasonable business, security, or fraud prevention purposes, the Company may immediately: (a) suspend or limit the performance of its obligations under these Rules and the Partnership Agreement; (b) suspend, revoke, cancel and/or terminate the Partner's ability to transact on Firstline and otherwise advertise or do business on the Firstline Platform; (c) immediately terminate or suspend these Rules and the Partnership Agreement; or (d) terminate or restrict the Partner’s transactions.

The Company shall not be liable to the Partner as a result of the termination of these Rules or the Partnership Agreement for any reason.

17. CONSEQUENCES OF TERMINATION

Upon termination of these Rules, the Company will: (i) cancel all pending purchase transactions with any Customer and (ii) deliver to the Partner by check or wire transfer any Currency in their Firstline Wallet, minus any fees due to the Company or third parties. Upon termination of these Rules, the Partner will be deleted as a seller on the Firstline platform. Upon termination, the Partner shall, at their own expense, immediately: (a) cease using Firstline and cease further awarding of any Firstline Points through Firstline; (b) stop displaying or using the Firstline Trademarks; (c) cease use and promptly return or, at the request of Firstline, destroy any and all confidential information belonging to the Company; (d) stop using and promptly return to the Company any software received from the Company pursuant to any other agreement between the parties.

18. LINKS TO THIRD PARTY SITES AND SERVICES

The Firstline platform may contain links or connections to third-party websites or services that are not owned or controlled by the Company. When you access third-party websites or use third-party services, you agree that there are risks involved and that the Company shall not be liable for such risks and losses

19. LIMITATION OF LIABILITY

Neither the Company nor its successors, subsidiaries, and affiliates, nor agents or subcontractors shall be liable for any delay or failure to perform its obligations under the Rules in the event that the delay or failure is due to any of the following circumstances:

• (a) failure, interruption, or damage to any hardware, software, or other telecommunications or data transmission systems;
• (b) the Company's belief that the transaction is unauthorized or fraudulent or poses a security risk;
• (c) or circumstances beyond the control of the Company.

NOTWITHSTANDING THE FOREGOING, IN NO EVENT WILL THE COMPANY BE LIABLE TO A CUSTOMER OR PARTNER FOR ANY CLAIMS OR LIABILITIES RELATED TO THESE RULES. THE COMPANY, ITS AFFILIATES, SUBSIDIARIES, AGENTS, OR SUB-CONTRACTORS SHALL NOT BE LIABLE TO THE USER OR PARTNER OR THIRD PARTY FOR ANY DAMAGES.

20. DAMAGES COMPENSATION

The Partner undertakes to indemnify the Company and its branches, subsidiaries and affiliates, agents, and subcontractors from any and all claims, losses, suits, liabilities, expenses, fines, and costs (including legal costs) arising from the fact that the Partner (any): (a) accepted the services of the Company; (b) violated the provisions of these Rules, (c) committed a negligent or wrongful act or omission, (d) failed to fulfill any obligation under the Rules, (e) failed to comply with any condition or warranty under the Rules, (f) sold goods or services to Customers; or (g) if a third party claims that the Partner's use of the Firstline platform, Firstline application or other services in violation of these Rules infringes or misappropriates such third party's intellectual property rights or violates Applicable Law.

21. DISCLAIMER OF WARRANTY

EXCEPT FOR ANY EXPRESS WARRANTIES SET FORTH IN THESE TERMS AND CONDITIONS, THE COMPANY PROVIDES THE FIRSTLINE SITE, THE FIRSTLINE PLATFORM, THE FIRSTLINE APP, AND THE OTHER SERVICES ON AN "AS IS" AND "AS AVAILABLE" BASIS, AND MAKES NO WARRANTY OF ANY KIND, WHATSOEVER WITH THE FIRSTLINE WEBSITE, FIRSTLINE PLATFORM, FIRSTLINE APP AND OTHER SERVICES, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES, ANY GUARANTEES RESULTING FROM USE OR CONSUMPTION, ANY GUARANTEES ARE CLEARLY OR INDIRECTLY MENTIONED. THERE IS NO WARRANTIES DISCLAIMER FOR A VIOLATION OF APPLICABLE LAW.

THE COMPANY DOES NOT WARRANT THAT THE FIRSTLINE SITE, THE FIRSTLINE PLATFORM OR THE FIRSTLINE APPLICATION WILL BE ERROR-FREE, AVAILABLE, OR MEET THE REQUIREMENTS AND ALL EXPECTATIONS OF THE PARTNER. THE COMPANY'S LIABILITY FOR ANY ERRORS, ACTIONS OR OMISSIONS ARISING FROM THE PROVISION OF THE FIRSTLINE SITE, THE FIRSTLINE PLATFORM, THE FIRSTLINE APPLICATION AND OTHER SERVICES SHALL BE LIMITED TO THE RE-PROVISION OF THE ABOVE SERVICES FREE OF CHARGE TO THE PARTNER. EXCEPT IN THIS EVENT, THE COMPANY SHALL NOT BE LIABLE FOR ANY CLAIM, LOSS, OR DAMAGE ARISING OUT OF OR REPRESENTED AS A RESULT OF THE USE OF THE FIRSTLINE PLATFORM, THE FIRSTLINE APPLICATION, THE FIRSTLINE WEBSITE, OR OTHER SERVICES, IN NO EVENT SHALL THE COMPANY BE LIABLE FOR ANY REFUSAL OR DELAY IN THE PROVISION OF THE FIRSTLINE SITE, THE FIRSTLINE PLATFORM, THE FIRSTLINE APP AND OTHER SERVICES OF THE COMPANY ARISING OUT OF FORCE MAJEURE.

22. GENERAL PROVISIONS

Address for suggestions and complaints Email: support@firstlinevip.com.

• Applicable law and jurisdiction. Any contradictions, disputes, demands, claims, or grounds for action (including the interpretation and scope of this clause) are considered by the Dubai International Arbitration Center and based on the current legislation of the United Arab Emirates.
• Changes. Unless otherwise provided in these Rules, the Company has the right to change any of the provisions of the Rules by publishing the changes on its information resources https://firstlinevip.com.
• Assignment. The Company has the right to transfer its rights and obligations in accordance with the Rules to a third party. The Partner may not assign, transfer, or sublicense, including by operation of law, any of its rights, obligations, or obligations to, in whole or in part, any person or entity without the prior written consent of the Company.
• If certain provisions of these Rules are wholly or partly invalidated, the validity of the remaining provisions shall remain in force. A provision that has become invalid is considered to be replaced by another one that is closest in meaning and purpose. The same applies to possible omitted provisions of these Rules.
• Applicable law. These Rules shall be governed by and construed in all respects in accordance with the laws of the United Arab Emirates.

Terms of use for users

These Terms of Use (hereinafter referred to as the "Rules") are binding for all individuals (hereinafter referred to as the "Users") who use the Firstline Application available at the following link: https://firstlinevip.com. By using the Application, Users confirm their full agreement with these Rules.

These Rules have been approved by the Limited Liability Company SESSIA, registered and existing in accordance with the legislation of the USA under File No. 7045651, hereinafter referred to as the "Company", and come into force from the date of acceptance by the Users of all the conditions established by the Rules and posted at the following address on the Internet: https://firstlinevip.com dated April 22, 2025.

Each of the Parties - the Company and the User - may be referred to in this document as a "Party" or collectively as the "Parties". Capitalized terms used in the Rules without definition have the meanings given in section 3 below.

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1. ACCEPTANCE OF THE RULES

When registering on the Firstline Application by clicking “Continue” or any other action expressing explicit consent to use the Firstline Application, accepts the Terms on behalf of the User, agrees to the Privacy Policy available at: https://firstlinevip.com, and confirms that:

• (a) accepts these Rules and the Privacy Policy on behalf of; and
• (b) has read and understood these Rules.

By accepting these Terms, User agrees to be bound by them as if they were additionally in writing and signed by Authorized Representatives of both Parties.

2. USER’S REGISTRATION

2.1 All Users are obliged to provide all necessary data, including personal information required for registration and use of the application. The User hereby represents and warrants that the information provided about him/her is true, accurate and complete. In particular:

• Your personal information (first name, last name, sex (gender), date of birth),
• Your photo as a profile avatar (optional),
• Your email address,
• Contact phone number (currently not widely available),
• Your bank account, credit card account and checking accounts to be used to open, fund and maintain a Firstline Wallet using Currency as defined below.

3. DEFINITIONS

Unless otherwise provided by these Rules, the following terms shall be defined as follows:

• "Applicable Law" means any international, federal, state or local law, regulation or rule that governs or pertains to these Rules or any services or transactions related to these Rules.
• "Customer" means any customer, user, buyer, person or entity that uses the Firstline platform to purchase or initiate transactions with a Partner. Furthermore, a Customer may also be any individual who visits a Partner’s business as a result of a post published in the feed of the Firstline application.
• "Partner" means a business (for example, a restaurant, store, or other commercial organization) that participates in the Firstline program, downloads the business version of the application (Firstline Platform), agrees to the terms of the platform, and uses it to attract customers, pay bonuses (Firstline Points), and interact with users through Firstline's social functionality.
• "Firstline Application" means mobile application of a comprehensive free-to-download and use digital solution encompassing programmatic tools designed to streamline business operations for analytics, communication, and operational efficiency that operates loyalty program management, marketing tools, facilitates efficient data handling, customer relationship management, and integration with third-party systems to provide real-time synchronization and automation.
• "Firstline Points" means rewards accrued to a Customer who purchases goods or services from any Partner, invites another user or company to join Firstline, and such invited or interacted user or company purchases goods or services from any Partner through Firstline.
• "Firstline Commission" refers to the charges applied to Partners for using the Application’s services, including transaction processing, Firstline Points distribution, and account maintenance. These fees are deducted from the Partner’s Firstline Wallet or transactions.
• "Friends and Benefits" means users who were engaged to visit a participating Partner and become its Customer by viewing a Customer’s post on the Firstline Social Feed.
• "VIP Credits" means Firstline Points received by Customers after making a purchase.
• "Royalties" means Firstline Points received by users for engaged Friends and Benefits or interacting in promotional activities.
• "Currency" means the local currency of Firstline, equivalent 1:1 to the local currency of the country chosen by the Partner as the main currency in the Firstline account. The application currency is intended for use by the Partner: (i) to pay out Firstline Points to the Customer who buys goods and services using Firstline; (ii) to give out Firstline Commission. The Company reserves the right, at its sole discretion, to use another or additional currency for issuing Firstline Points in order to create additional liquidity for all users.
• "Wallet" means a secure and internal digital wallet on the Firstline Application that allows: (a) Partners to fund their Currency balances, from which Partners can pay Firstline Points in the form of Currency; (b) Customers to accumulate Firstline Points they receive from Partners; and make purchases from other Partners. For the avoidance of any doubt, each Partner or Customer must own and control their own Wallet, and transactions made using the Wallet are the sole responsibility of its owner.

4. USER'S INTELLECTUAL PROPERTY

Users retain all ownership rights to the content they create and share through the Application, including but not limited to text, photos, images, videos, reviews, comments, and other materials (hereinafter referred to as “User Content”).

By posting User Content in the Application, the user grants the Company a non-exclusive, fully paid and royalty-free, transferable, sub-licensable, worldwide license to use their content. This license is granted for the purpose of operating, developing, promoting, and improving the Application and related services, as well as for the creation of new products and services by the Company.

The user represents and warrants that they have all necessary rights to the posted User Content and that granting such rights to the Company does not infringe or violate the rights of any third party, including copyright, related rights, proprietary rights, or personal non-property rights.

User hereby acknowledges that they are prohibited from using, reproducing, decompiling, reverse engineering, modifying, or distributing any Firstline Application or performing any other actions that violate copyright and intellectual property rights. The User also acknowledges that the transactional data processed by the Company is the property of the Company for current and future use.

5. FIRSTLINE ACCOUNT

When a Customer pays their bill, Firstline will automatically deduct from the Partner’s wallet the equivalent amount of Firstline Points accrued to the User and transfer it to the User’s wallet. Additionally, for every 1 unit of Currency (e.g., 1 AED, USD, etc.) in Firstline Points accrued to the User, a Firstline Commission of 0.20 units of Currency will be deducted from the Partner’s Wallet and transferred to the Company’s Wallet as a service commission. The use of Firstline Points by User may be subject to restrictions and conditions outlined in Section 11 of these Rules.

In order to avoid any doubt, the Company does not act as a credit card company, a payment processing agent, or a handling agent between the Partner and the User. When the Customer purchases goods or services, the Customer pays the Partner directly to the bank account specified by him using a credit card, debit card in accordance with the Partner's own instructions and policies. The Company is not responsible for and does not participate on behalf of any Partner, business, or other person in the collection of payments for the purchase of any goods or services by any End Customer or other customer.

6. USER FIRSTLINE ACCRUAL

As far as Firstline integrates with reservation systems like SevenRooms or other similar to enable automated data exchange, when a Customer who is a user of the Firstline Application makes a purchase, the Partner identifies the Customer, locating them by phone number or using their member code, (depending on system applied). Thus, when a Customer completes a purchase, Firstline automatically receives transaction data within 30 minutes, and that transaction is automatically published in the Firstline Social Feed, visible to friends, followers, and other users because while making a reservation through such systems, a phone number linked to a Customer's Firstline account. Only the Customer can further edit the post by adding images or details about the purchase. Friends and followers can interact with the post by liking, commenting, or sharing it on other social networks, generating new customers for the Partner.

Based on transaction data, Firstline points are credited as follows:

• VIP Credits: Automatically credited to the Customer’s account after each purchase. The Partner is responsible for determining the rates of VIP Credits. The percentage must be specified by the Partner in their settings on the Firstline Application.
• Royalties: Automatically credited to the account of the Customer who engaged Friends and Benefits after those individuals make purchases from any Partner. The Partner also determines the rates of Royalties. The percentage must be specified by the Partner in their settings on the Firstline Application.

The Partner may modify the rates of both VIP Credits and Royalties at their discretion. However, any changes to these rates will not affect transactions already completed by Customers. The rates of VIP Credits and Royalties applicable to a specific Customer will be fixed based on the rates in effect on the date their transaction is published in the Firstline Social Feed. For clarity, the date of publication of a Customer's receipt in the Firstline Social Feed will serve as the reference point for determining the applicable VIP Credits for that transaction and Royalties rates for transactions caused by such publications.

The Partner is obliged to ensure that all changes to VIP Credits and Royalty rates are promptly updated on the Firstline Application and communicated clearly to Customers, where applicable, to maintain transparency and compliance with these Rules.

7. USE OF FIRSTLINE POINTS AND USER’S PARTICIPATION IN THE FIRSTLINE SYSTEM

To participate in the Firstline system and receive Firstline Points, the User agrees to use the Firstline application in accordance with these Terms and all instructions provided by the Company.

Users can earn Firstline Points by making purchases from Partners registered on the Firstline Application. The amount of Firstline Points credited may vary depending on the type of goods or services purchased, as determined by the Partner. Partners may set different Firstline Points rates for various categories of products (e.g., higher rates for premium items and lower rates for standard items), and these rates may change in real-time depending on the Partner’s current offers.

Users acknowledge that the accrual and value of Firstline Points and Royalties depend on the specific terms set by each Partner and may vary across the Application. Users are encouraged to review each Partner’s current offers and settings in the Firstline Application.

The Company may display a rating or activity score for each User based on their engagement in the Firstline Social Network, including but not limited to comments, likes, and other feedback. The Company reserves the right to implement and update its rating system at its sole discretion.

8. FIRSTLINE FEED AND INFORMATION DISCLOSURE

When a User (Customer) makes a purchase through a Partner on the Firstline Application (using a receipt, bank card, or in-app Currency), the Firstline system may, with the User’s consent, display information about the transaction in the internal Firstline Social Network feed. This may include:

• a) a photo or digital copy of the receipt (uploaded by the User only);
• b) the name of the Partner where the purchase was made;
• c) a description of the purchased goods, services, or items.

This information may be visible to the User’s friends, followers, and other Users of the Firstline Application, who may interact with the post (like, comment, share), and may be encouraged to make similar purchases from that Partner, thus earning Firstline Points and Royalties through the Partner’s programs available.

Users can adjust privacy settings in the Application to control who sees their activity feed (e.g., limiting visibility to specific groups). However, restricting access entirely may affect the platform’s ability to verify engagement, potentially impacting the accrual of Firstline Points tied to social interactions (e.g., Friends and Benefits rewards).

Only the User has the right to upload or allow the publication of a receipt or any transaction-related information. Partners are not entitled to do so and violation of this clause will be considered and subject to penalties as for disclosure of the User's personal data.

The Company processes transaction-related data and displays it on the Application only to the extent permitted by applicable law and solely for the purposes described in these Terms. The Company will never publish or share any sensitive personal information (bank account or card numbers, social security numbers, home addresses). Such personal data of Users will not appear in the Firstline Social Network or on any other section of the Application unless strictly required by law.

By uploading transaction data (e.g. a receipt or review), the User acknowledges that such information may become publicly visible within the Firstline network, subject to the User’s privacy settings.

9. CONTENT OF USERS/PARTNERS ON THE SOCIAL NETWORK, ONLINE STORE AND ON THE FIRSTLINE APPLICATION

The Company strictly prohibits Users from posting, sharing, or displaying any content that is offensive, profane, or otherwise inappropriate, including, but not limited to, content that promotes or displays obscenity, hate speech, or intolerance based on religion, sexual orientation, race, or ethnic background.

Users are also prohibited from promoting, advertising, or selling products, services, or goods that incite hatred, violence, or discrimination of any kind, or support organizations that hold such views.

The Company reserves the right, at its sole discretion, to remove or modify any content that violates these terms. Additionally, the Company may suspend, terminate, or revoke the account of any User who engages in such behavior, including Partners, Customers, and other individuals associated with the violator.

By using the Firstline Application, Users certify that they are of age of majority (as defined by the age of majority in their jurisdiction of use of the Application). Underage Users are prohibited from using Firstline. If the Client becomes aware that the Application is being used by an underage User, they must report it to the Company for account deletion and termination.

Users agree to indemnify and hold harmless the Company, its affiliates, and officers from any claims, actions, or liabilities resulting from violations of these terms by the User.

10. PARTNER REFUND TERMS

Each Partner on the Firstline Application sets their own refund policy in accordance with applicable law. Users must review and accept these terms before making a purchase.

Refund policies typically define:

• When refunds are allowed (e.g. defective goods, canceled services);
• Time limits for refund requests (e.g. 14 days or as per law);
• How refunds are processed (e.g. to the original payment method).

Firstline Points and Refunds:

• Firstline Points from a transaction remain pending until the refund period expires.
• If a refund is approved, the earned Points will be deducted from the User’s Wallet and returned to the Partner.
• How refunds are processed (e.g. to the original payment method).

Refunds and related disputes are resolved directly between Users and Partners. The Company is not a party to such transactions and does not enforce refund terms.

These Rules take effect from the moment the User accepts them and remain in force until the earliest of the following: (i) the User’s account is deleted by the User or by the Company on the grounds provided by these Rules; or (ii) the User ceases to use the Firstline Application. Upon termination, all obligations under these Rules cease, except for those that, by their nature or terms, are intended to survive termination.

11. TERM OF RULES

These Rules take effect from the moment the User accepts them and remain in force until the earliest of the following: (i) the User’s account is deleted by the User or by the Company on the grounds provided by these Rules; or (ii) the User ceases to use the Firstline Application. Upon termination, all obligations under these Rules cease, except for those that, by their nature or terms, are intended to survive termination.

12. TERMINATION

The Company may, at its sole discretion, suspend or terminate the User’s access to Firstline, including the ability to earn or use Firstline Points, if the User: (a) violates any terms of these Rules or applicable law; (b) engages in fraudulent or abusive behavior; (c) creates a security or reputational risk for the Application or other users. The Company is not liable to the User for any losses or damages resulting from such termination or suspension.

13. CONSEQUENCES OF TERMINATION

Upon termination of a User account: (i) all pending transactions will be canceled; (ii) any remaining Firstline Points in the User’s Wallet that are not eligible for use (e.g., under a refund period or otherwise restricted) will be forfeited; (iii) the User will lose access to their profile, transaction history, and any other Application features.

14. LINKS TO THIRD PARTY SITES AND SERVICES

The Firstline Application may contain links or connections to third-party websites or services that are not owned or controlled by the Company. When you access third-party websites or use third-party services, you agree that there are risks involved and that the Company shall not be liable for such risks and losses.

15. LIMITATION OF LIABILITY

Neither the Company nor its successors, subsidiaries, and affiliates, nor agents or subcontractors shall be liable for any delay or failure to perform its obligations under the Rules in the event that the delay or failure is due to any of the following circumstances:

• (a) failure, interruption, or damage to any hardware, software, or other telecommunications or data transmission systems;
• (b) the Company's belief that the transaction is unauthorized or fraudulent or poses a security risk;
• (c) or circumstances beyond the control of the Company.

NOTWITHSTANDING THE FOREGOING, IN NO EVENT WILL THE COMPANY BE LIABLE TO A CUSTOMER OR PARTNER FOR ANY CLAIMS OR LIABILITIES RELATED TO THESE RULES. THE COMPANY, ITS AFFILIATES, SUBSIDIARIES, AGENTS, OR SUB-CONTRACTORS SHALL NOT BE LIABLE TO THE USER OR PARTNER OR THIRD PARTY FOR ANY DAMAGES.

16. DAMAGES COMPENSATION

The User undertakes to indemnify the Company and its branches, subsidiaries and affiliates, agents, and subcontractors from any and all claims, losses, suits, liabilities, expenses, fines, and costs (including legal costs) arising from the fact that the Partner (any): (a) the User’s misuse of the Firstline Application or services;(b) violation of these Rules;(c) negligent or unlawful acts or omissions; (d) breach of any obligation, representation, or warranty under these Rules; or(e) any third-party claim that the User’s conduct violates applicable law or infringes third-party rights.

17. DISCLAIMER OF WARRANTY

EXCEPT FOR ANY EXPRESS WARRANTIES SET FORTH IN THESE TERMS AND CONDITIONS, THE COMPANY PROVIDES THE FIRSTLINE SITE, THE FIRSTLINE APPLICATION, THE FIRSTLINE APP, AND THE OTHER SERVICES ON AN "AS IS" AND "AS AVAILABLE" BASIS, AND MAKES NO WARRANTY OF ANY KIND, WHATSOEVER WITH THE FIRSTLINE WEBSITE, FIRSTLINE APPLICATION, FIRSTLINE APP AND OTHER SERVICES, INCLUDING, BUT NOT LIMITED TO, ANY IMPLIED WARRANTIES, ANY GUARANTEES RESULTING FROM USE OR CONSUMPTION, ANY GUARANTEES ARE CLEARLY OR INDIRECTLY MENTIONED. THERE IS NO WARRANTIES DISCLAIMER FOR A VIOLATION OF APPLICABLE LAW.

THE COMPANY DOES NOT WARRANT THAT THE FIRSTLINE SITE, THE FIRSTLINE APPLICATION OR THE FIRSTLINE APPLICATION WILL BE ERROR-FREE, AVAILABLE, OR MEET THE REQUIREMENTS AND ALL EXPECTATIONS OF THE PARTNER. THE COMPANY'S LIABILITY FOR ANY ERRORS, ACTIONS OR OMISSIONS ARISING FROM THE PROVISION OF THE FIRSTLINE SITE, THE FIRSTLINE APPLICATION, THE FIRSTLINE APPLICATION AND OTHER SERVICES SHALL BE LIMITED TO THE RE-PROVISION OF THE ABOVE SERVICES FREE OF CHARGE TO THE PARTNER. EXCEPT IN THIS EVENT, THE COMPANY SHALL NOT BE LIABLE FOR ANY CLAIM, LOSS, OR DAMAGE ARISING OUT OF OR REPRESENTED AS A RESULT OF THE USE OF THE FIRSTLINE APPLICATION, THE FIRSTLINE APPLICATION, THE FIRSTLINE WEBSITE, OR OTHER SERVICES, IN NO EVENT SHALL THE COMPANY BE LIABLE FOR ANY REFUSAL OR DELAY IN THE PROVISION OF THE FIRSTLINE SITE, THE FIRSTLINE APPLICATION, THE FIRSTLINE APP AND OTHER SERVICES OF THE COMPANY ARISING OUT OF FORCE MAJEURE.

18. GENERAL PROVISIONS

Address for suggestions and complaints Email: support@firstlinevip.com.

Applicable law and jurisdiction. Any contradictions, disputes, demands, claims, or grounds for action (including the interpretation and scope of this clause) are considered by the Dubai International Arbitration Center and based on the current legislation of the United Arab Emirates.

Changes. Unless otherwise provided in these Rules, the Company has the right to change any of the provisions of the Rules by publishing the changes on its information resources https://firstlinevip.com.

Assignment. The Company has the right to transfer its rights and obligations in accordance with the Rules to a third party. The Partner may not assign, transfer, or sublicense, including by operation of law, any of its rights, obligations, or obligations to, in whole or in part, any person or entity without the prior written consent of the Company.

If certain provisions of these Rules are wholly or partly invalidated, the validity of the remaining provisions shall remain in force. A provision that has become invalid is considered to be replaced by another one that is closest in meaning and purpose. The same applies to possible omitted provisions of these Rules.

Applicable law. These Rules shall be governed by and construed in all respects in accordance with the laws of the United Arab Emirates.

Delete Your Firstline Account

If you no longer wish to use Firstline — VIP Royalties, you can request deletion of your account and personal data at any time.

Email Request

To delete your account, send an email to our support team:
support@firstlinevip.com

Please include the following information in your email (in order of importance):

• Phone number associated with your account
• First and last name
• Email address or nickname (if available)

We will confirm your request by email.

What Happens Next?

After we receive your request, we will review it and delete your account and personal data within 30 days.
We may contact you if we need additional information to process your request.

What Data Is Deleted?

We delete all personal data associated with your account. However, we may retain certain records (such as orders, rewards, and financial data) for auditing, analysis, and legal compliance.

Questions?

If you have any questions, feel free to contact us at:
support@firstlinevip.com

How to delete an account within the app

Step 1

Open the side menu and go to settings

Step 2

In the “About the app” section, click on “Remove account”

Step 3

After this, a modal window for confirmation will open. Once you click on the “Delete” button confirmation, the user’s account will be deleted (all personal data will be deleted).