First Step is a gift-based digital contribution platform designed to allow individuals to celebrate the arrival of a newborn by sending personal messages and monetary gifts. The platform does not offer gambling, betting, or lottery services, and any symbolic selections (e.g. selecting a “date”) serve purely ceremonial or decorative functions with no effect on the receipt, value, or outcome of contributions.

First Step does not include elements of chance, prize allocation, or competitive selection that would categorize it as a game of skill or game of chance under applicable law, including:

• The U.S. Unlawful Internet Gambling Enforcement Act (UIGEA)
• The Canadian Criminal Code (Sections 197–206)

Users do not receive rewards or financial incentives based on participation, date selection, or contribution behavior. No part of the platform constitutes a sweepstake, contest, or wager.

All contributions made through First Step are voluntary, irrevocable gifts to the child designated by the account holder. By making a contribution, users acknowledge that:

• No service or product is purchased in exchange.
• Contributions are non-refundable, unless required by law.
• They have no claim or expectation of financial return, shareholding, or compensation.

Contributed funds are transferred to an investment or custodial account managed by the child’s parents or legal guardians. First Step:

• Does not hold, manage, or invest the funds directly.
• Does not act as a fiduciary, financial advisor, or trustee.
• Makes no guarantees or representations about financial performance, investment outcomes, or tax consequences.

It is the sole responsibility of the child’s guardian(s) to determine how funds are managed after receipt. We recommend that all contributors and parents seek independent financial and tax advice.

To use First Step, users must:

• Be at least 18 years old or the age of majority in their jurisdiction.
• Use the platform in compliance with all applicable laws and financial regulations.
• Not be located in a jurisdiction where gift-based financial transfers are prohibited or restricted.

First Step reserves the right to refuse service, block transactions, or deactivate accounts in cases of suspected fraud, misuse, or regulatory risk.

We take the security of user data seriously. All personal and financial information is processed in accordance with:

• The General Data Protection Regulation (GDPR) (for EU-based users)
• The California Consumer Privacy Act (CCPA) (for California residents)
• PIPEDA (for Canadian residents)

First Step is hosted on Amazon Web Services (AWS) and maintains a secure, containerized environment using Docker and Terraform-based Infrastructure as Code (IaC). We operate separate development and production environments, and enforce best practices in secure deployment.

Transactional emails (e.g., confirmation receipts, welcome emails) are handled via a secure third-party provider.

We reserve the right to modify these Terms at any time. Any material changes will be communicated via email or posted on our platform. Continued use of the service constitutes acceptance of the updated Terms.