1st90 LLC (“1st90,” “us,” "we," or “our”) is committed to protecting and respecting your privacy in connection with your use of our applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of 1st90). This privacy policy (“Privacy Policy”) and any other documents referred to herein set forth the basis on which any personal information we collect from you, or that you provide to us, in connection with the Products will be processed by us. Please read the following carefully to understand our practices regarding your personal information and how we will collect, use and disclose your personal information.
This Privacy Policy applies to learners and other end users of the Kyper Shift app and related 1st90 learning Products. If you use Kyper Studio, the Kyper Dashboard, or the Kyper AI connector, the Kyper Studio Privacy Policy applies to that use.
1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you:
- Your name, company e-mail address, and information about your usage of the Products and information collected by tracking technologies as further described below that may identify you as an individual or allow online contact with you as an individual.
- Device Information such as operating system version, device type, and system performance information to help the users experience.
- Content you create in the Products, such as reflections, responses to prompts and surveys, habit and action tracking, and an optional profile image.
- Your interactions with the in-app AI coach (Kyper Coach), such as the questions you ask and the coaching responses and personalized micro-actions you receive.
- If you choose to use voice practice, the audio of your practice session, its transcript, and the feedback, delivery metrics, and scores generated from it. Voice practice starts only when you begin a session and grant microphone access. We do not use your voice for biometric identification.
2. CONFIDENTIALITY AND SECURITY
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at hello@1st90.com. Except as described under the “Disclosure of Your Information” section below, we do not provide your personal information to any third party without your specific consent, as defined by applicable law.
3. ELECTRONIC COMMUNICATIONS
If you sign up to receive daily reminders via email we will use the information you give us to provide the communications you have requested.
If you inform us that you wish to cancel email notification by selecting “unsubscribe” at the bottom of such communication or by emailing us at hello@1st90.com, we will remove you from our list. If you no longer wish to receive push notifications, you may turn them off at the device level.
4. TRACKING TECHNOLOGIES
1st90 use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don't have to provide the same information several times during one task, recognize that you may have already given a username and password so you don't need to do it for every web page requested, and to measure how people are using the Products.
5. WHERE WE STORE YOUR PERSONAL INFORMATION
All information you provide to us through the Products is stored on secure AWS servers located in the United States. If you access the Products from outside the United States, your information will be transferred to and processed in the United States. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that you change your password frequently.
6. ACCESS TO AND DELETION OF PERSONAL INFORMATION
Upon request, 1st90 will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email hello@1st90.com.
You can delete your account at any time from the profile page in the app, and we complete account deletion within 24 hours. Within the app, you can also delete individual discussion posts from your social feed, individual reflections from your library, and individual AI chat conversations and voice practice sessions from your Conversation History. To ask us to correct or delete your personal information, email hello@1st90.com. Because your access is usually provided by your organization, we may coordinate your request with your organization where our agreement with it requires.
7. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other device.
- To provide AI-powered features you choose to use, such as coaching responses, personalized micro-actions, and voice practice feedback.
- To provide you with customer service communications.
- To notify you about changes to the Products.
- To inform your company about your registration and use of the Products
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
If you are an existing user, we will only contact you by electronic means (e-mail or in-Product communication)
We may allow a third party platform to access to your company email address you provide in order to perform the verification.
We do not use your personal information to train AI models, and the AI providers we use are not permitted to use it to train their models.
8. DISCLOSURE OF YOUR INFORMATION
We share your personal information only as described in this section. We do not sell your personal information.
Your organization. If your access to the Products is provided by your employer or another organization, we share information about your registration, participation, and progress with that organization's authorized administrators and program staff. Most reporting is aggregated. Individual-level data is available only to administrators your organization has authorized to see it.
Service providers. We use service providers that process information on our behalf to operate the Products, such as cloud hosting (Amazon Web Services), email and push-notification delivery, product analytics, and AI model providers that power AI features (for example, OpenAI). They may use your information only to provide services to us and are bound by confidentiality and security obligations. We access AI models only through enterprise services whose terms do not permit the provider to use your information to train its models.
Third-party AI integrations. Your organization's authorized administrators may connect 1st90 reporting tools to a third-party AI assistant, including but not limited to Anthropic (Claude) and OpenAI (ChatGPT and Codex), to review program data. When they run an action through that integration, the data returned by the action is transmitted to the provider operating that assistant to deliver the feature they invoked. That data is usually aggregated. Where an administrator is authorized to view individual-level data, it may include your progress and activity records and, where the administrator's permissions allow, your name and work email. The provider's handling of that data is governed by its own terms and privacy policy and by your organization's agreement with that provider.
Legal requirements and safety. We may disclose information where required by law, regulation, or legal process, or where needed to protect the rights, property, or safety of 1st90, our users, or others.
Business transfers. If 1st90 is involved in a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction, subject to this Privacy Policy.
With your consent. We may share your information for other purposes with your consent.
9. INFORMATION POSTED ON FORUMS
1st90 users may have the ability to post content to one or more 1st90 forums. All such users may request and obtain removal of such posted content by contacting 1st90 at hello@1st90.com and specifically identifying the content to be removed.
10. DATA RETENTION
We retain your personal information for as long as your account is active or as needed to provide the Products, and thereafter only as required to comply with our legal obligations, resolve disputes, and enforce our agreements. Our standard retention periods are:
- Account information, such as your name, work email, and profile image, is kept while your account is active and for up to 12 months after it becomes inactive, unless you or your organization ask us to delete it sooner.
- Content you create, AI coach conversations, and voice practice records are kept for the duration of your organization's program with 1st90, unless you delete them sooner. Short-term AI coach conversation context expires after 24 hours.
- When you delete your account, we complete deletion within 24 hours. Residual copies in our encrypted backups are removed on our normal backup rotation.
- Operational logs are kept for at least 90 days, and security and audit logs for at least 12 months, then deleted on a rolling basis.
- We may keep aggregated or de-identified information that can no longer be used to identify you.
If your organization's agreement with 1st90 sets a different retention period, that agreement controls.
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and notify you through the Products or by email.
12. CONTACT US
If you have questions about this Privacy Policy or want to exercise your privacy rights, contact our Privacy Officer at hello@1st90.com or write to 1st90 LLC, 3961 Ronda Road, Pebble Beach, CA 93952.