FirstRoles Master Legal Suite

Legal

Terms of Service, Privacy Policy, FERPA institutional compliance, SMS messaging terms, and our cookie policy — all in one place.

1. Master Terms of Service and Terms of Use

Effective Date: August 24, 2026

Important Notice — Arbitration Agreement & Class Action Waiver

These terms contain a mandatory individual arbitration agreement and class action waiver requiring that any disputes between you and First Roles Grads be resolved through binding, individual arbitration rather than in court, jury trials, or class actions.

1.1 Acceptance of Terms & Eligibility

These Master Terms of Service and Terms of Use (these "Terms") constitute a legally binding agreement between you ("User," "you," or "your") and First Roles Grads, LLC d/b/a First Roles Jobs ("Company," "we," "us," or "our"). By accessing or using the website located at firstroles.com, or any affiliated domains, applications, APIs, or notification services (collectively, the "Platform"), you represent and warrant that you are at least sixteen (16) years of age or the age of legal majority in your jurisdiction, have the full legal capacity to enter into these Terms, and agree to be bound by all terms, conditions, policies, and disclaimers set forth herein. If you are accessing the Platform on behalf of an educational institution, career center, or corporate entity, you represent and warrant that you possess the requisite authority to legally bind that entity to these Terms.

1.2 User Accounts and Registration Security

Certain features of the Platform require account creation (such as student profiles, My Tracker, or career center administrative portals). When registering, you agree to provide true, accurate, current, and complete information. You are solely responsible for maintaining the confidentiality of your credentials and passwords and for all activities, actions, and omissions that occur under your account. You agree to notify Company immediately in writing of any unauthorized access, breach of security, or suspected compromise of your account credentials. Company shall not be liable for any losses, claims, or damages arising from your failure to maintain account security.

1.3 Independent Job Aggregator Status & Section 230 Immunity

(a) Informational Aggregation Only: First Roles Jobs is an automated technology platform and indexing search engine designed to discover, aggregate, and surface publicly available job listings and internship opportunities published on third-party employer career feeds and Applicant Tracking Systems ("ATS") including, without limitation, Greenhouse, Lever, Workday, Taleo, and Ashby. Company is not an employer, staffing agency, employment agency, headhunter, labor contractor, or recruiter.

(b) Third-Party Content & Communications Decency Act Immunity: All job listings, descriptions, corporate profiles, qualifications, salary ranges, benefits, and external application links are third-party content. Pursuant to Section 230 of the Communications Decency Act (47 U.S.C. § 230), Company assumes no editorial responsibility, liability, or obligation to monitor, verify, screen, or edit third-party job postings. Company does not guarantee, represent, or warrant: (i) the existence, validity, legitimacy, or active availability of any listed role; (ii) the accuracy or completeness of any job description, requirement, or wage estimate; (iii) that an employer will review, consider, or respond to an application; or (iv) that submitting an application will result in an interview, job offer, or employment.

Direct Third-Party Applications: When you click "Apply Now" or any external link, you are redirected off the Platform to third-party employer websites or ATS endpoints. Your interactions, application submissions, personal data transfers, and correspondence with third-party employers are governed entirely by the terms and privacy policies of those respective third parties. You access external sites and submit job applications entirely at your own risk.

1.4 Intellectual Property & Nominative Fair Use of Trademarks

(a) Company Proprietary Rights: The Platform, including its underlying software, algorithms, scraper engines, visual layout, graphics, user interface, database architecture, design, and trademarks ("First Roles Grads", "First Roles Jobs"), are the exclusive proprietary property of Company and are protected by United States and international copyright, trademark, and trade secret laws.

Nominative Fair Use of Third-Party Marks: All third-party company names, employer trade names, logos, registered trademarks, service marks, and trade dress displayed on the Platform are the exclusive property of their respective trademark owners. Company's display of third-party employer names and logos constitutes non-confusing, nominative fair use pursuant to the Lanham Act (15 U.S.C. § 1125) and common law trademark doctrines, utilized solely to identify the specific corporate entity advertising a job opening. The display of such marks does not indicate, imply, or establish any affiliation, sponsorship, endorsement, joint venture, or official partnership between Company and the trademark owner.

1.5 Prohibited Activities & Anti-Scraping Restrictions

You agree not to engage in any of the following prohibited behaviors: (a) Using any robot, spider, scraper, crawler, deep-link, or automated data extraction tool to access, index, extract, or copy data from the Platform without prior written consent from Company; (b) Attempting to probe, scan, or test the vulnerability of the Platform, bypass authentication measures, or breach security architectures; (c) Decompiling, reverse engineering, disassembling, or deriving the source code of the Platform; (d) Introducing viruses, worms, trojan horses, malware, or malicious code designed to disrupt, damage, or limit the functionality of the Platform; (e) Using the Platform for any unlawful purpose, discriminatory recruitment practice, or in violation of federal, state, or local employment regulations.

1.6 Disclaimer of Warranties

TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, THE PLATFORM, ITS CONTENT, NOTIFICATION FEEDS, AND ALL ASSOCIATED SERVICES ARE PROVIDED STRICTLY ON AN "AS IS," "AS AVAILABLE," AND "WITH ALL FAULTS" BASIS. COMPANY, ITS FOUNDER, OFFICERS, DIRECTORS, EMPLOYEES, AFFILIATES, AGENTS, AND LICENSORS (COLLECTIVELY, THE "COMPANY PARTIES") EXPRESSLY DISCLAIM ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, AND FREEDOM FROM COMPUTER VIRUSES OR HARMFUL COMPONENTS.

WITHOUT LIMITING THE FOREGOING, THE COMPANY PARTIES MAKE NO REPRESENTATION OR WARRANTY THAT: (I) THE PLATFORM WILL MEET YOUR CAREER REQUIREMENTS OR EMPLOYMENT GOALS; (II) THE PLATFORM WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE; (III) JOB POSTINGS ARE ACTIVE, AUTHORIZED, OR ACCURATELY CATEGORIZED; OR (IV) DEFECTS WILL BE DETECTED OR CORRECTED.

1.7 Comprehensive Limitation of Liability

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL THE COMPANY PARTIES BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES WHATSOEVER, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF PROFITS, LOSS OF REVENUE, LOSS OF EMPLOYMENT OPPORTUNITIES, LOSS OF REPUTATION, LOSS OF DATA, WORK STOPPAGE, SYSTEM FAILURE, OR BUSINESS INTERRUPTION, ARISING OUT OF OR IN CONNECTION WITH THESE TERMS, THE PLATFORM, THE USE OR INABILITY TO USE THE PLATFORM, OR RELIANCE ON ANY THIRD-PARTY JOB LISTING, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, STATUTORY, OR OTHERWISE), EVEN IF THE COMPANY PARTIES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

TO THE FULLEST EXTENT PERMISSIBLE BY APPLICABLE LAW, IN NO EVENT SHALL THE TOTAL AGGREGATE CUMULATIVE LIABILITY OF THE COMPANY PARTIES FOR ALL CLAIMS, DISPUTES, INJURIES, OR LOSSES ARISING OUT OF OR RELATED TO THESE TERMS OR THE PLATFORM EXCEED THE GREATER OF: (A) THE TOTAL FEES ACTUALLY PAID BY YOU TO COMPANY IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO LIABILITY; OR (B) ONE HUNDRED UNITED STATES DOLLARS ($100.00 USD). THE EXISTENCE OF MULTIPLE CLAIMS OR PROCEEDINGS SHALL NOT ENLARGE OR EXTEND THIS LIMIT. THE LIMITATIONS OF DAMAGES AND REMEDIES SET FORTH HEREIN ARE FUNDAMENTAL ELEMENTS OF THE BASIS OF THE BARGAIN BETWEEN COMPANY AND YOU.

1.8 Indemnification

You agree to defend, indemnify, and hold harmless the Company Parties from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, and fees (including reasonable attorneys' fees and court costs) arising out of or relating to: (a) your violation or alleged breach of these Terms; (b) your use or misuse of the Platform; (c) your violation of any third-party right, including intellectual property, privacy, or contractual rights; (d) any information or data you upload or submit to the Platform; or (e) your interaction with, application to, or dispute with any third-party employer.

1.9 Mandatory Binding Individual Arbitration & Class Action Waiver

(a) Informal Dispute Resolution: Prior to initiating any formal legal proceeding, you and Company agree to attempt in good faith to resolve any dispute, claim, or controversy informally. Either party must send a written Notice of Dispute describing the claim and desired relief. If the dispute is not resolved within thirty (30) days of receipt of such notice, either party may proceed to binding arbitration.

(b) Binding Individual Arbitration: Any dispute, claim, or controversy arising out of or relating to these Terms, the breach thereof, or the Platform shall be resolved exclusively through final and binding individual arbitration administered by the American Arbitration Association ("AAA") under its Consumer Arbitration Rules (or Commercial Rules, as applicable), and judgment on the award rendered by the arbitrator may be entered in any court having jurisdiction thereof. The arbitration shall take place in Washington, District of Columbia, or virtually via secure videoconference.

(c) CLASS ACTION WAIVER: YOU AND COMPANY EXPRESSLY AGREE THAT ALL CLAIMS AND DISPUTES MUST BE BROUGHT SOLELY IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF, CLASS REPRESENTATIVE, OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE INDIVIDUAL'S CLAIMS AND MAY NOT PRESIDE OVER ANY FORM OF CLASS OR REPRESENTATIVE PROCEEDING.

(d) WAIVER OF JURY TRIAL: YOU AND COMPANY VOLUNTARILY, KNOWINGLY, AND IRREVOCABLY WAIVE ANY CONSTITUTIONAL AND STATUTORY RIGHT TO A TRIAL BY JURY IN ANY ACTION OR PROCEEDING ARISING OUT OF OR RELATED TO THESE TERMS OR THE PLATFORM.

(e) Statute of Limitations: You agree that any claim or cause of action arising out of or related to these Terms or the Platform must be filed within one (1) calendar year after such claim or cause of action arose; otherwise, such claim or cause of action is permanently barred.

1.10 Governing Law, Venue & General Provisions

These Terms shall be governed by, construed, and enforced in accordance with the laws of the District of Columbia, without giving effect to any principles of conflicts of law. If any provision of these Terms is adjudicated by an arbitrator or court of competent jurisdiction to be invalid, illegal, or unenforceable, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall remain in full force and effect. Company's failure to enforce any right or provision shall not constitute a waiver of future enforcement.

2. Master Privacy Policy

Effective Date: August 24, 2026

2.1 Information We Collect

We collect the following categories of information to operate, personalize, and improve our services:

(a) Identifiers & Contact Information: Full name, email address (including university .edu email), mobile phone number (for SMS alerts), and account authentication credentials.

(b) Academic & Student Profile Data: Enrolled institution, college major, graduation year, class standing, and any user-provided resume documents or career interests.

(c) Job Search & Interaction Telemetry: Bookmarked jobs, explored listings, application timestamps recorded in "My Tracker," reported interview milestones, offer statuses, and notification cadence preferences.

(d) Automated Device & Technical Telemetry: Internet Protocol (IP) address, browser type, operating system, device identifiers, referring URLs, access timestamps, and session logs.

2.2 How We Use Your Information

Company utilizes collected information for legitimate business and operational purposes, including: (a) Delivering real-time job discovery feeds, personalized search matching, and drop alerts (scheduled at 12:00 PM ET and 6:00 PM ET); (b) Facilitating institutional analytics, student progress tracking, and intervention reporting for authorized University Career Centers; (c) Authenticating accounts, processing password resets, and ensuring platform security; (d) Detecting, preventing, and investigating fraud, security incidents, scraping, or violations of these Terms.

2.3 Information Sharing & Disclosure

Company does not sell, rent, or trade your personal information to third-party data brokers. We share information only under the following circumstances:

(a) University Career Centers: If your account is associated with a participating partner institution, your application activity, job search metrics, and enrollment details are shared with authorized career advisors to facilitate student career counseling.

(b) Service Providers & Subprocessors: We engage trusted technical vendors who provide cloud hosting, database management (Supabase), transactional email delivery (connected Gmail API / SendGrid), SMS gateway transmission (Twilio), and platform monitoring. These vendors are bound by strict confidentiality and data protection obligations.

(c) Legal & Regulatory Obligations: We may disclose personal data if required to comply with a valid subpoena, court order, regulatory inquiry, or to protect the vital rights, property, and physical safety of Company, users, or the public.

(d) Corporate Transactions: In the event of a merger, acquisition, corporate reorganization, or sale of assets, user data may be transferred as a business asset subject to standard confidentiality protections.

2.4 Data Security & Encryption

Company implements administrative, physical, and technical safeguards designed to protect personal data against accidental loss, unauthorized access, destruction, or alteration. All data transmissions are encrypted using Transport Layer Security (TLS 1.3), and stored data is encrypted at rest using AES-256 bit encryption within United States-based cloud data centers.

2.5 State Privacy Rights (CCPA / CPRA & State Laws)

Depending on your state of residence (including California, Virginia, Colorado, Connecticut, and Utah), you may possess specific statutory rights regarding your personal information, including:

(a) Right to Know and Access: The right to request disclosure of the categories and specific pieces of personal data collected, sources, and third parties with whom data is shared.

(b) Right to Rectification: The right to correct inaccurate personal data.

(c) Right to Deletion: The right to request the permanent erasure of your personal information, subject to statutory retention exceptions.

(d) Right to Non-Discrimination: Company will never deny services, charge different prices, or provide a lower quality of service for exercising your privacy rights. To exercise any privacy rights, contact privacy@firstroles.com.

2.6 Children's Online Privacy Protection Act (COPPA)

The Platform is strictly intended for post-secondary college students and adults. We do not knowingly collect or solicit personal information from children under the age of thirteen (13). If we discover that personal data from a child under 13 has been collected, we will take prompt steps to delete such data immediately.

3. Data Usage & FERPA Institutional Compliance Addendum

Applicable to University, College, and Career Center Partners

3.1 Statutory Framework & Scope

This Data Usage and FERPA Institutional Compliance Addendum (this "Addendum") is entered into between First Roles Grads ("Vendor") and the participating post-secondary educational institution ("Institution"). This Addendum governs the transmission, handling, and security of student education records and institutional data subject to the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 C.F.R. Part 99, "FERPA").

3.2 School Official Designation

(a) Legitimate Educational Interest: Pursuant to 34 C.F.R. § 99.31(a)(1)(i)(B), Institution hereby designates Vendor as an authorized "School Official" with a legitimate educational interest in accessing student education records (including student rosters, names, .edu email addresses, majors, and career placement metrics).

(b) Direct Control: Vendor acknowledges and agrees that with respect to all Institution-provided educational records, Vendor shall operate under the direct control and supervision of the Institution regarding the handling, maintenance, and processing of student education records.

3.3 Data Ownership

Institution retains full, exclusive, and unencumbered ownership of all student roster files, CSV uploads, student directory records, and institutional data transmitted to Vendor. Vendor acquires no proprietary ownership rights, title, or intellectual property interest in Institution-provided education records.

3.4 Permissible Processing & Operational Use

Vendor is authorized to process Institution-provided student data solely for the following educational purposes: (a) Creating and provisioning student account invitations; (b) Delivering personalized job and internship drop notifications; (c) Generating real-time career analytics, engagement statistics, and intervention flags (such as resume review and interview coaching alerts) within the Career Center administrative dashboard; (d) Maintaining the operational stability, diagnostic performance, and security of the Platform.

3.5 Security Standards & Incident Response

(a) Security Controls: Vendor maintains industry-standard technical, physical, and organizational safeguards, including AES-256 encryption at rest, TLS 1.3 encryption in transit, and role-based access controls restricting data access strictly to authorized personnel with a need-to-know.

(b) Breach Notification: In the event Vendor confirms an unauthorized breach or security incident resulting in unlawful access to or disclosure of Institution PII, Vendor shall notify Institution's designated Career Center administrator in writing without unreasonable delay, and in no event later than forty-eight (48) hours following confirmed verification of the incident.

3.6 Data Return & Certified Destruction

Upon termination or expiration of the partnership agreement between Institution and Vendor, or upon written demand from Institution, Vendor shall within thirty (30) calendar days securely delete and purge all Institution-provided student education records and CSV roster files from Vendor's active servers, providing written certification of destruction upon request. This provision does not restrict or prohibit Vendor from retaining anonymized, aggregated statistical data that contains no personally identifiable student information.

4. SMS / Text Messaging Terms and Conditions

Compliance with TCPA, CTIA Messaging Principles, and 10DLC Standards

4.1 Program Description & Express Written Consent

By checking the SMS alert checkbox, providing your mobile telephone number on the Platform, and submitting your registration, you provide your prior express written consent to enroll in the First Roles Grads Job Drop Alerts notification program. You acknowledge and agree that your consent is voluntary and is not a condition of purchasing any property, goods, or services.

4.2 Message Frequency & Delivery

(a) Frequency: Subscribers will receive recurring automated text messages. Standard messaging frequency is up to two (2) SMS notifications per calendar day, dispatched immediately following our scheduled job drop cycles at 12:00 PM ET and 6:00 PM ET, containing summary metrics of newly published internships and recent graduate roles with direct access links.

(b) Carriers & Delivery: T-Mobile, AT&T, Verizon, Sprint, and other mobile carriers are not liable for delayed or undelivered messages.

4.3 Cost Disclosures

Message and data rates may apply for any SMS messages sent to you from Company or sent to Company from you, according to the terms of your individual mobile service contract. Company is not responsible for any mobile carrier fees or data charges incurred.

4.4 Opt-Out & Customer Support

(a) Opt-Out Instructions: You may revoke your consent and terminate SMS communications at any time. To cancel, text STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any message received. You will receive one final confirmation SMS confirming that your number has been unsubscribed, after which no further SMS messages will be sent to your mobile device.

(b) Support & Help: For assistance or technical support, text HELP to any message received, or contact Company directly at support@firstroles.com.

4.5 Mobile Subscriber Privacy

Company values your privacy. Mobile telephone numbers and text messaging consent records collected for SMS drop alerts will strictly not be sold, rented, leased, or shared with third parties or affiliates for third-party marketing or promotional purposes. Information is transmitted solely through our contracted SMS telecommunications gateway provider (Twilio) to facilitate message delivery.

5. Website Cookie & Tracking Policy

5.1 Use of Cookies & Local Storage

The Platform utilizes browser cookies, web beacons, and HTML5 local storage to ensure platform functionality, maintain authentication sessions, and record job search activity.

Essential & Security — HTTP Session Cookies: Authenticates logged-in users, prevents cross-site request forgery (CSRF), and preserves session integrity.

Functional & Preferences — Local Storage: Stores user UI preferences, dark/light theme, and active filter states across browsing sessions.

Job Tracking & Telemetry — Session & Local Storage: Powers "My Tracker" functionality (recording explored jobs, bookmarks, and applied listings).

Performance & Diagnostics — First-Party Analytics: Measures page load speeds, scraper ingestion performance, and platform error rates.

5.2 Managing Cookies

Most web browsers automatically accept cookies by default. You can adjust your browser settings to decline or delete cookies. Please note that disabling essential cookies may render core platform features (such as user authentication and tracker saving) inaccessible.

Legal Notice: These documents constitute the full legal and data architecture for First Roles Grads / First Roles Jobs. For legal inquiries, official notices, or FERPA institutional agreements, contact legal@firstroles.com.