Privacy Notice

FirstPass is operated by Home Caption Marketing LLC ("FirstPass", "we", "us"). We are the data controller for personal data processed through this service.

• Account data: email address and login credentials.
• Profile data: display name (optional).
• Submitted content: the text you submit for coverage and the resulting reports.
• Usage and telemetry: pages viewed, features used, error logs.
• Device data: IP address, browser type, device identifiers.
• Support messages: anything you send us through support channels.

Payment and billing information (card details, billing address, tax data) is collected directly by Paddle, our Merchant of Record, and is not stored by us.

• To provide the service: account creation, generating coverage reports, storing your report history (legal basis: contract performance).
• Security and fraud prevention: detect abuse, prevent unauthorised access (legitimate interests).
• Product improvement: aggregated usage analytics to improve the service (legitimate interests).
• Customer support: respond to your questions (contract performance).
• Legal compliance: tax, accounting, responding to lawful requests (legal obligation).

We do not sell your data, and we do not use your submitted text to train AI models.

• Hosting and infrastructure: our cloud hosting and database providers.
• AI processing: AI model providers that generate coverage reports from your submissions. Submissions are sent for processing only and are not retained by these providers for training.
• Payments and tax (Paddle): Paddle.com, our Merchant of Record, handles all payment processing, subscription management, tax compliance, and invoicing.
• Professional advisers: legal and accounting advisers, where required.
• Authorities: where required by law or to protect rights.

Some of our service providers (including Paddle and AI model providers) are located outside your country of residence. Where data is transferred internationally, we rely on appropriate safeguards such as Standard Contractual Clauses or adequacy decisions.

Account data and reports are retained for as long as your account is active. If you delete a report, it is removed immediately. If you delete your account, all associated data is deleted within 30 days, except where we are required to retain limited records for legal or tax purposes.

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data
• Restrict or object to certain processing
• Receive your data in a portable format
• Withdraw consent at any time (where processing is based on consent)
• Lodge a complaint with a supervisory authority

To exercise any of these rights, contact us through your account page. We respond within 30 days.

We use appropriate technical and organisational measures to protect your data, including encryption in transit, encrypted storage, access controls, and Row-Level Security on our database. No system is perfectly secure, but we work to minimise risk.

We use only essential cookies required to keep you signed in and to operate the service. We do not use advertising or third-party tracking cookies.

We may update this Privacy Notice from time to time. Material changes will be communicated via email or in-app notice at least 14 days before taking effect.

Privacy questions or requests: reach out through the support link in your account page.