Effective Date: September 30, 2025
Last Updated: September 30, 2025

1. INTRODUCTION

Your360 AI, Inc. ("Your360 AI," "we," "us," or "our") provides AI-powered 360-degree feedback services for Professional Development. This Privacy Policy explains how we collect, use, disclose, and protect information when you use our website (your360.ai), platform, and services (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to our collection, use, and disclosure of your information as described herein.

Definition: Throughout this Privacy Policy, "Professional Development" or "Development" means improving your work-related skills and effectiveness through feedback and coaching provided by our Services.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Account Information

• Name, email address, job title, role
• Phone number (optional)
• Company/organization affiliation
• Password and account credentials

Development Information

• Development goals and focus areas
• Optional context documents (resume, performance reviews)
• Selection of feedback providers
• Coaching conversation content

Feedback Provider Information

• Name and email address
• Relationship to feedback recipient
• Feedback content (via voice or text)
• Voice recordings and transcripts

2.2 Information Collected Automatically

Usage Information

• IP address and device information
• Browser type and settings
• Date, time, and duration of visits
• Pages viewed and features used
• Referring and exit pages

Cookies and Analytics

• First-party cookies for session management
• Analytics data (PostHog, Google Analytics)
• Session recordings (with sensitive content obscured)

2.3 Information from Third Parties

We may receive information about you from:

• Your employer (if they sponsor your account)
• Feedback providers you select
• Third-party authentication services
• Business partners and service providers

3. HOW WE USE YOUR INFORMATION

3.1 Primary Uses

We use your information to:

• Provide and operate the Services
• Conduct AI-powered feedback interviews
• Generate 360 feedback reports and Development insights
• Facilitate communication between users and feedback providers
• Process payments and maintain accounts

3.2 Service Improvement

We analyze aggregated, de-identified data to:

• Improve our AI interview techniques
• Enhance feedback synthesis quality
• Develop new features and services
• Conduct research on Professional Development

3.3 AI and Machine Learning

What We Do:

• Use AI to conduct voice interviews
• Analyze feedback patterns and themes
• Generate personalized Development insights
• Improve our interview questions and synthesis

What We Don't Do:

• Train third-party AI models (OpenAI, Anthropic) with your data
• Use your personal feedback for other users
• Create identifiable profiles for non-service purposes

3.4 Communications

We may use your information to:

• Send service-related notifications
• Respond to inquiries and support requests
• Provide updates about new features (with consent)
• Send marketing communications (with opt-out options)

4. HOW WE SHARE INFORMATION

4.1 With Organizations

If your employer sponsors your account, they can see:

• Who was invited to provide feedback
• Who has completed feedback sessions
• Participation and completion rates
• Aggregated, anonymized insights (minimum 5 participants)

They cannot see:

• Individual feedback content
• Your Development report
• Coaching conversations
• Specific feedback from providers

4.2 With Service Providers

We share information with third-party service providers who help us operate our Services:

• Cloud infrastructure providers
• Communication services (email, SMS)
• Payment processors
• Analytics providers
• AI/ML services

All service providers are contractually bound to protect your information and use it only as directed by us.

4.3 With Feedback Recipients

Feedback providers should understand:

• Their feedback contributes to synthesized insights
• Select quotes may be included for authenticity
• Manager feedback is attributed by default
• Other feedback is presented anonymously (solely on a ‘best efforts’ basis; we cannot guarantee complete anonymity)

4.4 Legal Requirements

We may disclose information when required by law or to:

• Comply with legal process
• Protect rights, property, or safety
• Enforce our Terms of Service
• Respond to government requests

4.5 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4.6 With Your Consent

We may share information for any other purpose with your explicit consent.

5. DATA RETENTION

Voice Recordings: Deleted within 90 days of processing. This window allows for issue resolution throughout the entire 360 feedback process, including collection, synthesis, and report delivery.

Transcripts and Reports: Retained while your account is active and for a reasonable period thereafter

Account Information: Retained until you request deletion or account is inactive for 24 months. This retention period enables long-term Development tracking and year-over-year progress comparison.

Aggregated Data: May be retained indefinitely in de-identified form

6. DATA SECURITY

We implement administrative, technical, and physical safeguards designed to protect your information, including:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security assessments
• Employee training and confidentiality agreements

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Portability

You may request:

• Access to your personal information
• A copy of your 360 reports and insights
• Export of your Development data

7.2 Correction and Deletion

You may:

• Update your account information
• Request correction of inaccuracies
• Request deletion of your account and data

Note: Some information may be retained for legal or legitimate business purposes.

7.3 Communication Preferences

You may:

• Opt-out of marketing emails
• Adjust notification settings
• Unsubscribe from non-essential communications

7.4 Feedback Provider Rights

Feedback providers may:

• Supplement feedback before report generation
• Create an account to manage multiple feedback requests
• Contact us to request deletion before report finalization (exceptional cases)

8. CALIFORNIA PRIVACY RIGHTS

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know: You may request information about the personal information we collect, use, and disclose.

Right to Delete: You may request deletion of your personal information, subject to certain exceptions.

Right to Opt-Out: You may opt-out of the "sale" of personal information. Note: We do not sell personal information.

Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact privacy@your360.ai or call [phone number].

9. WASHINGTON PRIVACY RIGHTS

Washington residents have rights under the My Health My Data Act. While Your360 AI is not a health service, we acknowledge that feedback may touch on well-being topics. We:

• Do not sell health-related data
• Will delete such information upon request
• Obtain consent for processing any health-related information

10. INTERNATIONAL DATA TRANSFERS

Your360 AI is based in the United States and processes data on US servers. If you use our Services from outside the US, you consent to the transfer of your information to the US. We implement appropriate safeguards for international transfers, including standard contractual clauses where applicable.

11. CHILDREN'S PRIVACY

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected information from a child under 18, we will delete it promptly.

12. SPECIAL INFORMATION REGARDING SENSITIVE DATA

Our AI coach focuses on workplace behaviors and performance. While personal characteristics may naturally arise in conversation, our system is designed to synthesize feedback around professional capabilities and growth areas. We do not intentionally collect special categories of personal information (race or ethnic origin, sex life or sexual orientation, criminal records, religion, political opinions, trade union membership, genetic/biometric data used for identification purposes, health conditions, etc.), and instruct users to focus on professional contexts.

13. DATA OWNERSHIP AND PORTABILITY

Individual Development Data: You retain access to your reports and insights regardless of employment status. Your Development journey belongs to you.

Organization Rights: Organizations may request deletion of data related to their employees but cannot access confidential feedback content.

Data Portability: You may export your Development reports and insights at any time.

14. AUTOMATED DECISION-MAKING

We use AI to analyze feedback and generate insights. These are recommendations for Professional Development, not automated decisions about you. All AI-generated content should be reviewed with human judgment and is not intended as the sole basis for employment decisions.

15. SESSION RECORDING DISCLOSURE

We use analytics tools including session recording to improve our Services and debug issues. Session recordings automatically obscure:

• Feedback content and conversations
• AI coach responses
• Development reports and insights

Recordings are retained for 30 days and accessible only to our technical team.

16. PRIVACY PROTECTION THRESHOLDS

To protect individual privacy:

• Minimum 3 feedback providers required to generate a report
• Minimum 3 responses per category for category-specific insights
• Minimum 5 participants for organizational aggregated insights

17. HOW TO CONTACT US

For privacy-related questions or to exercise your rights:

Email: privacy@your360.ai
Support: support@your360.ai
Mail: Your360 AI, Inc.
[Address]

Response time: We will acknowledge requests within 30 days and respond substantively within 45 days, with possible extension if needed.

18. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on our website
• Sending notice to your registered email
• Displaying a notice in the platform

Your continued use after changes constitutes acceptance of the updated policy.

19. LEGAL BASIS FOR PROCESSING (FOR EEA USERS)

We process personal data based on:

• Consent: For marketing and optional features
• Contract: To provide Services you've requested
• Legitimate Interests: For service improvement and security
• Legal Obligations: When required by law

This Privacy Policy is effective as of September 12, 2025 and supersedes all previous versions.

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