Reviews & loyaltyFirstPromoter and the GDPR: agreement, role and data location.
FirstPromoter is a reviews & loyalty tool. Most customers use it as a processor, it explains how to get its data processing agreement, and the data location depends on your account. Below: what to check and how to declare it.
Prefilled for you · Free to set up · No credit card
In short
- Category
- Reviews & loyalty
- Usual role
- Usually a processor
- Data location
- Set per account or project
- Agreement
- Obtained through the vendor
What does FirstPromoter do with personal data?
Collect customer reviews, run loyalty, referral or affiliate programs and send related messages. That is how Privacyboard describes a typical use of FirstPromoter, as a starting point you can edit.
The data usually involved: customer names, email addresses, order details, reviews, points or rewards, referral and engagement data.
Is FirstPromoter a processor or a controller?
Most customers use FirstPromoter as a processor: it handles personal data on their instructions, for the purposes they set. That is the common reading for reviews & loyalty tools and it is what Privacyboard suggests.
As a processor, it needs a written agreement with you under Article 28, and you should know which subprocessors it uses. Confirm the role against your own agreement, because the way you use a tool can change it.
Where does FirstPromoter store personal data?
FirstPromoter does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable.
How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Even when the main location is in the EU, ask whether subprocessors or support access involve a transfer outside the EEA, and record it if so.
Which legal basis usually applies to FirstPromoter?
For the usual use of FirstPromoter, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest.
The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Publishing a review with the author’s name needs their agreement, and review requests must be easy to refuse. The balancing test is yours to do: the interest must be real, the processing necessary for it, and people’s rights must not outweigh it.
This is a starting point, not legal advice: the basis belongs to your activity, and you confirm it in your register.
Sources: GDPR Article 6, lawfulness of processing, EDPB Guidelines 1/2024 on legitimate interest
Does FirstPromoter have a data processing agreement?
Checked on 5 November 2026. Vendors change their pages, so check the date.
FirstPromoter does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy.
What we noted when we opened the page: GDPR page: paid customers request the DPA through the in-app Intercom chat. No contracting entity, hosting location or transfer tool stated.
A page that exists does not mean you are covered. Whether the agreement applies to you depends on your plan and on what you accepted, so record the decision yourself in your vendor list.
Open the FirstPromoter reference pageHow to declare FirstPromoter
- 1
In your privacy policy
Name FirstPromoter as a recipient, say what it is used for (collect customer reviews, run loyalty, referral or affiliate programs and send related messages) and mention any transfer outside the EEA. Articles 13 and 14 ask you to tell people who receives their data.
- 2
In your vendor list
Add FirstPromoter with its purpose, the data involved, its role, its region and a link to the agreement. Privacyboard prefills all of this, you confirm or correct it.
- 3
In your processing register
Link FirstPromoter to the activities that use it, so each record shows its recipients. Article 30 asks the register to list the categories of recipients.
What to check before relying on FirstPromoter
- Check which emails the tool sends and that each one offers an easy way to stop them.
- Decide how reviews are published: first name only, initials, or full name with agreement.
- Check how long points, reviews and referral data are kept.
- Record the region and any transfer outside the EEA.
Go online for free. Grow when you need to.
Free puts you online. Pro adds requests, domains and your team; Business, your brand only.
Free
$0 forever
No card, no time limit
For getting compliant and going online on your own.
Start for freeKey features:
- Privacy and cookie policies
- Vendor and processing registers
- Requests and breaches tracked
- Impact assessment screening
- Privacy center on privacyboard.io
- Cookie banner on 1 domain
- 1 person
No card needed
ProRecommended
$32 per month
Billed $384 a year Save $84
For taking requests, covering all your sites and working as a team.
Start with ProEverything in Free, plus:
- DPA for your clients
- PDF and Excel exports
- Email reminders
- Request form and replies
- Your own domain
- Banner on 3 domains, every choice logged
- Weekly site scan
- Complete DPIAs and TIAs
- AI assistant connector
- Up to 5 people, with roles
Cancel any time
Business
$109 per month
Billed $1,308 a year Save $240
For proving it to customers and auditors, under your brand only.
Start with BusinessEverything in Pro, plus:
- No Privacyboard mention
- Security section and vendor alerts
- Evidence pack in one click
- Banner on 10 domains, daily scan
- Up to 50 people
- Two-step verification required
- Activity log kept 3 years
Bank transfer on request
Questions, answered.
Is FirstPromoter GDPR compliant?
Privacyboard does not certify vendors. Compliance depends on how FirstPromoter is configured and used, on the agreement you have with it and on your own practices. What can be checked is documented here: it explains how to get a data processing agreement, the usual role and the data location. Read the agreement itself before relying on it.
Does FirstPromoter have a DPA?
FirstPromoter does not publish the full text of its data processing agreement on a public page. The reference page explains how a customer gets or signs it, usually from inside the account. Article 28 of the GDPR still requires a written contract, so get it and keep a copy. The reference page is https://www.firstpromoter.com/gdpr.
Is FirstPromoter a data processor?
Usually, yes. Most customers use FirstPromoter as a processor that acts on their instructions. Check your own agreement and how you use the tool, because the role can differ.
Which legal basis applies when I use FirstPromoter?
For the usual use of FirstPromoter, companies most often rely on performance of a contract and legitimate interests (GDPR Article 6(1)). A loyalty program the customer joined is a contract; a review request after a purchase usually rests on a legitimate interest. The interest you would state: “Asking customers for a review of their purchase and rewarding loyal customers.” The GDPR asks you to say which interest you pursue (Article 13(1)(d)).
Where does FirstPromoter store data?
FirstPromoter does not have one fixed location for every customer. The location depends on the plan, the account and the services you enable. How to find yours: Check your account settings, the address you log in to, or the provider’s data processing terms. Support can tell you if you cannot find it.
Do I need to mention FirstPromoter in my privacy policy?
Yes, if FirstPromoter handles personal data for you. The GDPR asks you to tell people who receives their data (Articles 13 and 14). Name the vendor or its category, say what it is used for and mention any transfer outside the EEA.
How do I add FirstPromoter to my vendor list?
In Privacyboard, pick FirstPromoter from the catalog. The purpose, the data, the suggested role and a link to its agreement are prefilled, and you confirm each one. Creating a workspace is free.
Similar tools
Compare all reviews & loyalty tools
Privacyboard is not affiliated with FirstPromoter. Names and logos belong to their owners and are used only to identify the tool. This page summarises public documents as checked on 1 November 2026; it is guidance, not legal advice, and it does not certify any vendor.