1. Your Agreement with First Steps

1.1. Your use of the First Steps service is governed by this agreement and referenced Policies (the "Terms"). First Steps is provided as a First4Adoption project associated with Coram, Adoption UK and Coram Children’s Legal Centre, with a registered office address at 49 Mecklenburgh Square, London WC1N 2QA. The “Service” means making available the website known as https://firststeps.first4adoption.org.uk/ (the “Site”) and the information and content on the Site.

1.2. In order to use the Service, you must first agree to the Terms. You can agree to the Terms by actually using the Service. You understand and agree that First Steps will treat your use of the Service as acceptance of the Terms from that point onwards.

1.3. You may not use the Service if you are a person barred from receiving the Service under the laws of the United Kingdom or other countries, including the country in which you are resident or from which you use the Service. You affirm that you are over the age of 18, as the Service is not intended for children under 18.

1.4. As a consumer, you have legal rights in relation to the Services. Advice about your legal rights is available from your local Citizens’ Advice Bureau or Trading Standards office. Nothing in these Terms will affect these legal rights.

2. Your Account and Use of the Service

2.1. You must provide accurate and complete registration information any time you register to use the Service. You are responsible for the security of your passwords. If you become aware of any unauthorised use of your or any User’s password, you agree to notify First Steps immediately.

2.2. Your use of the Service must comply with all applicable laws, regulations and ordinances, including any laws regarding the export of data or software.

2.3. You agree not to (a) access (or attempt to access) the administrative interface of the Service by any means other than through the interface that is provided by the Site in connection with the Service, unless you have been specifically allowed to do so in a separate agreement with First Steps, or (b) engage in any activity that interferes with or disrupts the Service (or the servers and networks which are connected to the Service).

2.4. You must not misuse the Service. This includes attempting to gain unauthorised access, introducing malicious code, interfering with the Service, impersonating another person, or using the Service in a way that is unlawful, harmful, abusive, or inconsistent with its purpose as a learning service.

3. Service Policies and Privacy

3.1. You agree to comply with these Terms and with any reasonable instructions shown in the Service that are needed to keep First Steps secure and working properly.

3.2. The Service shall be subject to the First Steps Privacy Policy (“Privacy Policy”) for the Service. You agree to the use of your data in accordance with the First Steps Privacy Policy, which may be updated from time to time.

3.3. First Steps asks for personal information only where it is needed to provide and protect the Service. This includes account details, course progress, quiz results and any notes you choose to save. Please do not add information to your notes that you would not want the First Steps administrators to be able to review for support and safeguarding of the Service.

3.4. If you delete your account, First Steps may retain anonymised course progress and quiz score information for service statistics, as described in the Privacy Policy.

4. Proprietary Rights

4.1. You acknowledge and agree that First Steps (or First Steps licensors) own all legal right, title and interest in and to the Service, including any intellectual property rights which subsist in the Service (whether those rights happen to be registered or not, and wherever in the world those rights may exist).

4.2. Except as provided in Section 8, First Steps acknowledges and agrees that it obtains no right, title or interest from you (or your licensors) under these Terms in or to any Content or the Application that you create, submit, post, transmit or display on, or through, the Service, including any intellectual property rights which subsist in that Content and the Application (whether those rights happen to be registered or not, and wherever in the world those rights may exist). Unless you have agreed otherwise in writing with First Steps, you agree that you are responsible for protecting and enforcing those rights and that First Steps has no obligation to do so on your behalf.

5. License from First Steps and Restrictions

5.1. First Steps gives you a personal, worldwide, royalty-free, non-assignable and non-exclusive license to access the Site. This license is for the sole purpose of enabling you to use and enjoy the benefit of the Service as provided by First Steps, in the manner permitted by the Terms.

5.2. You may not (and you may not permit anyone else to): (a) copy, modify, create a derivative work of, reverse engineer, decompile or otherwise attempt to extract the source code of the Service or any part thereof, unless this is expressly permitted or required by law, or unless you have been specifically told that you may do so by First Steps, in writing (e.g., through an open source software license); or (b) attempt to disable or circumvent any security mechanisms used by the Service or any Application.

6. Modification and Termination of the Service

6.1. First Steps is constantly innovating in order to provide the best possible experience for its users. You acknowledge and agree that the form and nature of the Service which First Steps provides may change from time to time without prior notice to you. Changes to the form and nature of the Service will be effective with respect to all versions of the Service; examples of changes to the form and nature of the Service include without limitation changes to the Privacy Policy, security patches, added functionality, modified appearance and other enhancements.

6.2. You agree that First Steps, in its sole discretion and for any or no reason, may terminate the Service or any part thereof. With the exception of misuse of the Service or breach of these Terms, which may result in termination of the Service and your account without prior notice, First Steps will serve notice of at least 30 days for any other termination of the Service. You agree that First Steps will not be liable to you or any third party for such termination.

6.3. Upon any termination of the Service or your account these Terms will also terminate, but Sections 5.1, 7, 10, and 12 shall continue to be effective after these Terms are terminated.

7. Liability

7.1. If we fail to comply with these Terms, we are responsible for loss or damage you suffer that is a foreseeable result of our breach of these Terms or our negligence, but we are not responsible for any loss or damage that is not foreseeable. Loss or damage is foreseeable if they were an obvious consequence of our breach or if they were contemplated by you and us at the time we entered into the Contract.

7.2. We only supply the Services for domestic and private use. You agree not to use the product for any commercial, business or re-sale purposes, and we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity.

8. Other Content

8.1. The Service may include links to other websites, content, or resources. First Steps does not control those external websites or resources.

8.2. First Steps is not responsible for the availability, content, privacy practices, or security of external websites or resources.

8.3. A link from First Steps does not mean that First Steps endorses that external website or resource.

9. Changes to the Terms

9.1. First Steps may make changes to the Terms from time to time. If we change the Terms in any substantive way, we will give you at least twenty eight (28) days notice before the changes take effect, during which period of time you may reject the changes by terminating your account.

9.2. You understand and agree that if you use the Service after the date on which the Terms have changed, First Steps will treat your use as acceptance of the updated Terms.

10. General Legal Terms

10.1. The Terms constitute the whole legal agreement between you and First Steps and govern your use of the Service (but excluding any services which First Steps may provide to you under a separate written agreement), and completely replace any prior agreements between you and First Steps in relation to the Service.

10.2. There are no third party beneficiaries to these Terms. The parties are independent contractors, and nothing in these Terms creates an agency, partnership or joint venture.

10.3. First Steps may provide notices, including notices about changes to the Terms, by email or by posting a notice on the Service.

10.4. You agree that if First Steps does not exercise or enforce any legal right or remedy which is contained in the Terms (or which First Steps has the benefit of under any applicable law), this will not be taken to be a formal waiver of First Steps's rights and that those rights or remedies will still be available to First Steps.

10.5. First Steps shall not be liable for failing or delaying performance of its obligations resulting from any condition beyond its reasonable control, including but not limited to, governmental action, acts of terrorism, earthquake, fire, flood or other acts of God, labour conditions, power failures, and Internet disturbances.

10.6. The Terms, and your relationship with First Steps under the Terms, shall be governed by and construed in accordance with the law of England and Wales, without regard to its conflict of laws provisions. You and First Steps agree to submit to the exclusive jurisdiction of the courts located within England and Wales to resolve any legal matter arising from the Terms.

10.7. Notwithstanding this, you agree that First Steps shall still be allowed to apply for injunctive remedies (or an equivalent type of urgent legal relief) in any jurisdiction.

Privacy Policy

11. Who is responsible for your personal information?

First Steps is provided by First4Adoption, operated by Coram. First4Adoption is the data controller for personal information collected through First Steps.

If you have a privacy question or want to exercise your data protection rights, please contact us using the privacy contact form. [Privacy contact form to be added.]

12. Information we collect

When you register for First Steps, we collect information such as your name, email address, county or region, password, learner type, account status, and preferences. We also record your course progress, quiz results, and any information you choose to put into the Notes section.

Please do not add sensitive personal information about yourself or other people into Notes unless it is necessary for your own learning. First Steps does not ask you to enter information about children, birth relatives, adopters, applicants, social workers, health, ethnicity, religion, criminal records, or other sensitive matters into Notes.

If you contact us, we may keep your message, email address, and our response. When you use the site, our systems may also process technical information such as your IP address, browser type, device information, requested pages, dates and times of access, error logs, and security logs. This helps us operate, secure, diagnose, and improve the Service. We do not use Google Analytics or marketing tracking software.

13. Why we use your information

We use your information to create and manage your account, let you sign in, provide the course, save your progress and notes, send account and password emails, respond to support requests, protect the security of the Service, and meet our legal and governance responsibilities.

We may invite users to receive newsletters or surveys in the future. These will be optional. We will only send newsletters or surveys where you have chosen to opt in, and you will be able to withdraw that choice later.

14. Lawful basis

For core account and course functions, we rely on processing being necessary to provide the Service you ask to use. We also rely on legitimate interests where we need to secure, support, maintain, and improve First Steps, provided those interests are not overridden by your rights and freedoms.

For optional newsletters and surveys, we rely on your consent. You can withdraw consent at any time.

15. Who we share information with

First-party user data will only be shared, where required, with Coram and those responsible for operating First4Adoption and First Steps. We do not sell your personal information.

We use trusted service providers to run First Steps. Hetzner hosts and runs the website infrastructure. Brevo helps us send transactional emails, such as registration, verification, and password reset messages. In this context, processing means collecting, storing, using, transmitting, securing, deleting, or otherwise handling personal information for the purposes of providing the Service.

Hetzner and Brevo publish GDPR/data-protection information and offer data processing terms for customers. They process personal information for First Steps only as needed to provide hosting and email services, subject to their contractual and data protection obligations.

16. How long we keep information

We keep account details, course progress, quiz results, and notes while your account is active. Inactive accounts which have not been signed into for a period of three years, will be notified of their deletion. The user can sign-in again to extend the life of their account should they require longer to complete or review their progress. User deletion will delete the users details, effectively anonymising personal information unless there is a clear reason to keep it for longer.

Routine technical logs should normally be kept only for as long as needed for security, diagnosis, and service operation. We recommend keeping routine server and application logs for up to 90 days unless a longer period is needed to investigate abuse, security incidents, errors, or legal claims.

Support, privacy, and complaint correspondence may be kept for up to 6 years where needed for accountability, legal, or governance purposes. Newsletter and survey preferences are kept until you withdraw consent, your account is deleted, or they are no longer needed.

17. Where information is stored

First Steps is hosted with Hetzner. Email delivery is supported by Brevo. These providers may process information in the UK, European Economic Area, or other locations where they operate under appropriate data protection safeguards. We aim to use providers and settings that support UK GDPR and EU GDPR-style governance.

18. How we protect your information

We use technical and organisational safeguards designed to protect personal information. These include secure HTTPS connections, password protection, secure cookies, restricted administrator access, server firewalls, backups, and access controls. No online service can be guaranteed completely secure, so you are responsible for keeping your password and account details confidential.

19. Your rights

You have rights under data protection law. These may include the right to ask for a copy of your personal information, ask us to correct inaccurate information, ask us to delete information, object to certain uses, restrict certain processing, withdraw consent where we rely on consent, and complain to the Information Commissioner’s Office.

You can delete your own account from your account details page. When an account is deleted, we will remove or blank personal identifiers such as the user’s name, email address, region, and saved Notes. We may retain course progress and quiz scores after account deletion, but only without the user’s name, email address, region, or Notes, so that First Steps can understand overall course completion, learning progress, and service statistics.

We normally respond to valid data protection requests free of charge. We may need to verify your identity before acting on a request.

Cookie Policy

This Cookie Policy explains how First Steps uses cookies on this website. First Steps uses cookies that are needed to keep the site secure, let you sign in, and save your course progress. We do not use marketing or analytics cookies to track you.

20. What are cookies?

Cookies are small text files that websites save on your device. They help a website remember information about your visit, such as whether you are signed in or whether you have already seen a notice.

The same rules can also apply to similar technologies that store information on your device or access information from it. First Steps uses these technologies only where they are needed to provide the service you ask to use.

21. What types of cookie does First Steps use?

First Steps uses essential cookies. These are needed for the website to work properly and to provide the service you ask for. We use both session cookies and persistent cookies:

• Session cookies are temporary. They usually last until you close your browser.
• Persistent cookies remain on your device for a set period of time, unless you delete them sooner.

22. Cookies we use

• _firststeps_session keeps your session secure, lets you sign in, and supports the normal operation of the site. When you are signed in, this cookie may be linked to your account so the site can save progress and show the right information to you. This is a session cookie.
• cp-continue remembers that you have acknowledged the cookie notice, so we do not keep showing it on every page. This cookie lasts for up to 1 year.
• last-subject remembers the last course subject you viewed, so the course page can reopen in the right place. This is a session cookie.

23. What’s the law?

UK cookie rules say that websites must tell people what cookies they use and explain what those cookies do. Websites usually need consent before setting non-essential cookies. Cookies that are strictly necessary to provide a service requested by the user, such as security and sign-in cookies, do not usually need consent. You can read more in the ICO guidance on cookies and similar technologies.

24. How does First Steps use cookies?

First Steps uses cookies to keep the site secure, remember your session, let you sign in, save course progress, remember where you were in the course, and support forms and other features you choose to use.

We do not use Google Analytics, advertising cookies, marketing cookies, or tracking pixels on First Steps.

25. How do I turn cookies off?

Most browsers accept cookies automatically, but you can change your browser settings to delete cookies or block them. Visit the options, settings, or preferences area of your browser to change how cookies are handled.

First Steps needs some cookies to work. If you block these cookies, you may not be able to sign in, save progress, use forms, or use some features of the website.