Privacy

Privacy Policy

How we collect, use, store, and protect your data.

On this page
Introduction

Who we are and how this policy applies.

FirstPass Inc. operates an AI-powered sales training platform. This Privacy Policy describes how we collect, use, store, and protect personal data when you use our platform.

Data controller
Your organization
For enterprise deployments, the customer organization is the data controller: they determine the purposes and means of processing personal data for their employees and users.
Data processor
FirstPass Inc.
FirstPass acts as the data processor, processing personal data on behalf of the customer organization in accordance with their instructions and our service agreement.

This policy applies to all users of the FirstPass platform, including sales representatives, managers and administrators within customer organizations.

Effective date

Version 1.2, effective May 19, 2026, last updated October 10, 2026.

Data we collect

What personal data we collect and where it comes from.

We collect and process several categories of personal data to provide the FirstPass platform. Here's a breakdown of each category.

Account data
Identity & profile
Email address, display name, and profile image sourced from Google OAuth or, where enabled for your organization, SAML SSO. Organization membership, role assignments, and user preferences.
Practice session data
Transcripts & feedback
Conversation transcripts between users and AI-simulated customers. AI-generated performance scorecards with 7-dimension scoring, help requests, and session configuration.
Real call data
Imported transcripts
Transcripts of real sales calls imported from call platforms your organization connects (Gong, Chorus, Zoom, Microsoft Teams) or from a CSV file, and the AI feedback scored on them. Organizations may optionally enable PHI redaction, which detects and redacts protected health information from transcripts before storage and downstream processing.
Coaching data
Notes & assignments
Coaching notes written by managers about specific representatives. Practice assignments created by managers for their team members.
Skill builder data
Scenarios & practice
Manager-authored skill builder scenarios, AI-generated conversation skeletons and persona variations, assignments linking scenarios to representatives, and practice attempt transcripts with AI feedback.
Technical & usage data
Logs & metrics
Audit log entries with timestamps, IP addresses, and user agent strings. AI model usage metrics and authentication events.
LMS integration data
Learner identifiers
When accessed via a Learning Management System: learner identifiers, names, and email addresses provided through SCORM, LTI 1.3, or xAPI protocols.
How we use data

Why we process your data and what we do with it.

We process personal data strictly for the purposes of providing, securing, and improving the FirstPass platform. Your data is never used to train AI models.

No model training on your data

FirstPass does not use your practice sessions, transcripts, or call data to train AI models. The AI customer simulator is prompt-engineered with your product and persona context, not fine-tuned on your team's conversations. Your data is used to serve you, and only you.

Third-party processors

Who processes your data and what they see.

FirstPass uses the following third-party services. FirstPass does not use customer data to train any AI model. Each provider's data processing terms are linked below.

Provider Purpose Data shared Trains on data?
Anthropic Customer simulation, feedback generation, skill builder exercises, help assistant, and deal research including web search Prompts, conversation history, scenario data No
ElevenLabs Text-to-speech for the AI buyer's voice (current provider) The text the AI buyer speaks Per provider agreement
Deepgram Real-time speech-to-text Real-time audio stream No
OpenAI, Hume AI, Cartesia Alternate text-to-speech providers. Only the provider configured for your deployment receives any data. The text the AI buyer speaks Per provider agreement
Anam AI Video-avatar rendering (optional, off unless enabled for your organization) The AI buyer's reply text and audio, for lip-sync Not persisted
Attio, Slack Handling demo requests submitted on our website. Slack also delivers assignment notifications to your own Slack workspace when your organization connects it. Name, email, company and message from the demo form. For assignment notifications: the rep's email (to find their Slack user), assignment type and title, priority and due date No
AWS Infrastructure hosting (database, storage, compute, cache), email delivery (SES), and opt-in PHI redaction (Comprehend Medical) All data categories Per DPA
People Data Labs Professional profile lookups for Research a Deal, an optional feature turned on per organization Names, companies and profile links of the prospects a rep researches; only work details are requested and kept, never emails, phone numbers or addresses Per provider agreement
Sentry Error monitoring Error reports and the technical context around them Not applicable
Integrations you connect Salesforce, HubSpot, Gong, Chorus, Zoom, Microsoft Teams, Slack, and LMS connections via SCORM, xAPI or LTI. Each is turned on by your organization The data needed for the connection your organization turns on Per your agreement with that provider
Data retention

Configurable retention. Two-phase deletion.

Data retention is configurable per organization. Administrators can set retention periods for practice sessions and audit logs, from 1 day to 10 years. The help assistant and Research a Deal periods below are fixed.

Practice sessions
1 to 3,650 days
Practice session transcripts and feedback scorecards. Retention period is configurable by the organization administrator, or set to unlimited.
Imported calls
On request
Imported call transcripts and their AI feedback. Deleted on request; automatic expiry of imported calls is not yet enforced.
Help assistant
180 days
Questions asked of the in-app help assistant and its answers. Removed automatically after 180 days, whatever the organization's retention settings.
Research a Deal
7, 30 and 90 days
Cached lookups expire after 7 days. Raw research evidence (page text, search findings and company data) is removed after 30 days, and what was learned about people after 90 days. A person can be erased sooner on request.
Audit logs
1 to 3,650 days
All audit log entries including user actions, timestamps, and IP addresses. Default is indefinite retention.
Deletion process
Two-phase
Expired practice sessions are hidden first and permanently deleted 30 days later. Hidden sessions can't be restored from the app. Audit log entries past their limit are deleted with no grace period. Automated daily purge runs at 03:00 UTC. Product-analytics events are kept for 180 days and system logs for 30 days by default.
Your rights

Access, export, delete, and correct your data.

We support data subject rights on request. Email data@myfirstpass.com and we will act on your request.

Right of access
Data export
Request an export of all your personal data. Includes user profile, practice sessions with conversation history, scoring feedback, and coaching notes.
Right to erasure
Account anonymization
Request account anonymization: email is replaced with an anonymized address, display name set to "Deleted User", sessions soft-deleted, coaching notes permanently removed.
Right to rectification
Profile updates
Update your profile information directly. Organization administrators can modify user role assignments.
Right to portability
Machine-readable JSON
Data exports are provided in a structured, machine-readable JSON format suitable for transfer to another service.
How to exercise these rights

On request: Data export and account deletion are available on request to data@myfirstpass.com.

Security measures

Technical and organizational measures that protect your data.

We implement comprehensive security measures across encryption, access control, monitoring, and infrastructure. For full details, see our Security page.

AES-256
Field-level encryption (GCM)
TLS 1.2+
Connections in transit
4 roles
43 granular permissions
HSTS
1-year max-age enforced
Cookies

One session cookie. First-party. No tracking.

FirstPass uses a single authentication cookie managed by NextAuth.js to maintain user sessions. While an administrator connects an integration, a short-lived security cookie (10 minutes) protects the sign-in handoff. We do not use any analytics, advertising, or social media tracking cookies.

Type
Strictly necessary
These cookies are required for platform functionality (authentication). They cannot be opted out of because the platform cannot work without them.
Scope
First-party only
No third-party cookies are set. Neither cookie is used for tracking, analytics, or advertising of any kind.
International transfers

Where your data lives and how cross-border transfers are protected.

FirstPass infrastructure is hosted on Amazon Web Services in the US-East-1 (N. Virginia) region. FirstPass stores personal data in this region.

For customers in the European Economic Area (EEA) or United Kingdom, data transfers to the United States are governed by appropriate safeguards including Standard Contractual Clauses (SCCs) as required by applicable data protection law.

AI and data providers (Anthropic, Deepgram, the configured speech provider and People Data Labs) process data in the United States. Other processors in the table above process data under their own terms, and integrations you connect process data under your agreement with that provider. Data transmitted to these providers is protected by TLS encryption in transit and is subject to each provider's data processing terms.

Contact

Questions about privacy? Get in touch.

For questions about how your organization uses FirstPass, contact your organization's administrator or data protection officer. For questions about FirstPass's data processing practices, reach out to us directly.

Privacy inquiries
data@myfirstpass.com
For data processing questions, data subject requests, or any privacy-related concerns.
Policy updates
Notified via email
When we make material changes, the "Last Updated" date is revised and customer organization administrators are notified via email.
Children's data

FirstPass is a business-to-business enterprise tool designed for professionals within customer organizations. The platform is not directed at individuals under the age of 18. We do not knowingly collect personal data from children.

Questions about privacy or data protection?

Book a call. We'll walk through your data processing requirements, discuss compliance, and answer whatever your team needs to know.

Talk to us →