Privacy policy

Effective Date: April 1, 2026
Last Updated: April 1, 2026

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1. Introduction

Welcome to Pivotry the Neuroinclusive Coach, operated by LearningTimes, LLC ("we," "us," or "our"). We are committed to protecting your personal information and being transparent about how we collect, use, and share it.

This Privacy Policy applies to your use of Pivotry the Neuroinclusive Coach service, including our website, Shopify-powered storefront, and AI-powered chat interface (collectively, the "Service"). By using the Service, you agree to the practices described in this policy.

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2. Information We Collect

2.1 Account & Purchase Information (via Shopify)

When you create an account or purchase a subscription, Shopify collects information on our behalf, including your name, email address, billing address, and payment details. Payment card data is handled directly by Shopify's payment processors — we do not store card numbers.

2.2 Conversation Data

When you use Pivotry the Neuroinclusive Coach, we collect the messages you send, the AI-generated responses returned to you, and session metadata (timestamp, session ID, subscription tier).

Free (Explore) tier users: To maintain conversational context, the last 10 messages from your active session are held temporarily in memory. This session memory is cleared when your session ends. No conversation content is retained after a session closes.

Paid (Grow and Lead) tier users: Your conversation history is saved and stored so that you can access it through your account. This history is retained indefinitely until you request deletion. To request deletion of your saved conversation history, contact us at pivotry@learningtimes.com and we will process your request promptly.

Please note that under OpenAI's standard API terms, conversation data transmitted to OpenAI is retained for up to 30 days for abuse monitoring purposes, after which it is deleted. This applies to all users regardless of tier.

2.3 Usage & Technical Data

We may automatically collect browser and device type, IP address, approximate location (country/region), pages visited, features used, session duration, and referring URLs. We use Shopify Analytics to understand how users interact with our Service.

2.4 Information You Voluntarily Provide

You may provide additional information through support requests or feedback forms. We use this only to respond to you or improve the Service.

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3. How We Use Your Information

We use the information we collect to:

- Provide, operate, and personalize the Service
- Process your subscription and manage your account
- Generate AI responses to your messages (see Section 4)
- Send transactional emails, including purchase confirmations, account setup notices, and password resets
- Send marketing communications where you have explicitly opted in
- Monitor and improve Service performance and safety
- Comply with legal obligations and enforce our Terms of Service

We do not sell your personal information to third parties.

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4. How Your Data Is Processed by AI (OpenAI)

Pivotry the Neuroinclusive Coach is powered by OpenAI's GPT-4 Turbo model. When you send a message, the following occurs:

1. Your message, plus the last 10 messages from your current session, are transmitted to OpenAI's API.
2. Relevant management guidance content retrieved from our internal knowledge base is included as additional context in the prompt. This knowledge base contains only generic management guidance content and does not include any personal or user-specific information.
3. OpenAI generates a response and returns it to you.

Your conversation messages are processed on OpenAI's infrastructure under OpenAI's Privacy Policy and API Data Usage Policies. Under OpenAI's standard API terms, data submitted via the API is not used to train OpenAI's models. OpenAI retains API data for up to 30 days for abuse monitoring purposes, after which it is deleted.

We encourage users to avoid entering sensitive personal information about identifiable third parties — such as employees' names or personal circumstances — into the chat, as that content is included in prompts transmitted to OpenAI.

For more information, see OpenAI's Privacy Policy at openai.com/policies/privacy-policy and their API Data Usage Policies at platform.openai.com.

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5. Cookies and Tracking Technologies

We and our service providers use cookies and similar tracking technologies to operate and improve the Service.

| Type | Purpose | Examples |
|---|---|---|
| Essential | Account login, session management | Shopify session cookies |
| Functional | Remembering preferences | Subscription tier, settings |
| Analytics | Understanding usage patterns | Shopify Analytics |
| Marketing | Ad targeting and conversion tracking | Meta Pixel, Reddit Pixel |

Meta Pixel and Reddit Pixel: We use Meta Pixel (Facebook/Instagram) and Reddit Pixel to measure the effectiveness of our advertising campaigns and to serve relevant ads to users who have visited our Service. These tools may collect your IP address, browser information, and pages visited.

California Residents — Do Not Sell or Share: The use of Meta and Reddit pixels for retargeting constitutes sharing of personal information for cross-context behavioral advertising under California law. California residents have the right to opt out of this sharing. To exercise this right, click the "Do Not Sell or Share My Personal Information" link in the footer of our website. When you opt out, these pixels will no longer fire during your visits.

You may also control cookies through your browser settings, though disabling certain cookies may affect Service functionality.

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6. How We Share Your Information

We share personal information only in the following circumstances:

Service Providers. We work with third-party vendors who process data on our behalf, including:

- Shopify — account management, payments, storefront, and transactional emails (Shopify Privacy Policy: shopify.com/legal/privacy)
- OpenAI — AI response generation (OpenAI Privacy Policy: openai.com/policies/privacy-policy)
- Replit — application hosting, infrastructure, and conversation data storage
- Notion — internal knowledge base content used to inform AI responses (contains no personal user data)
- Klaviyo — marketing and drip email communications to opted-in users only

Business Transfers. If we are involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction. We will provide advance notice by email or a prominent notice within the Service.

Legal Requirements. We may disclose information when required by law, subpoena, or court order, or to protect the rights and safety of our users or the public.

We do not share your personal information with advertisers for their own independent use.

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7. Your Privacy Rights (California Residents — CCPA/CPRA)

If you are a California resident, you have the following rights:

- Right to Know — Request the categories and specific pieces of personal information we have collected about you.
- Right to Delete — Request deletion of your personal information, subject to certain legal exceptions.
- Right to Correct — Request correction of inaccurate personal information we hold about you.
- Right to Opt-Out — Opt out of the sharing of your personal information for cross-context behavioral advertising via the "Do Not Sell or Share My Personal Information" link in our website footer.
- Right to Non-Discrimination — We will not penalize you for exercising your privacy rights.

To submit a rights request, contact us at pivotry@learningtimes.com. We will respond to verified requests within 45 days, extendable by an additional 45 days with prior notice when reasonably necessary.

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8. Data Retention

| Data Type | Retention Period |
|---|---|
| Account & billing data | Duration of account + 7 years |
| Conversation session memory (free users) | Cleared at session end |
| Saved conversation history (paid users) | Indefinitely until deletion requested |
| Usage & analytics data | 24 months |
| Marketing consent records (Klaviyo) | Duration of consent + 3 years |

To request deletion of your saved conversation history, contact us at pivotry@learningtimes.com.

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9. Data Security

We implement commercially reasonable technical and organizational safeguards to protect your personal information, including:

- Encrypted data transmission (TLS/HTTPS)
- Access controls on our Replit-hosted application
- Secure storage of API credentials
- Reliance on Shopify's PCI-compliant payment infrastructure
- Application logs designed to exclude personally identifiable information such as user IDs, email addresses, and conversation content

No method of internet transmission is 100% secure. We encourage users to choose strong, unique passwords and to avoid entering sensitive personal information about identifiable third parties into the chat.

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10. Children's Privacy

The Service is designed for managers and working professionals and is not intended for anyone under the age of 18. We do not knowingly collect personal information from minors. If we become aware that a minor has provided personal information through the Service, we will delete it promptly. To report a concern, contact us at pivotry@learningtimes.com.

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11. Third-Party Links

The Service may contain links to third-party websites or resources not governed by this policy. We encourage you to review the privacy policies of any third-party services you access independently.

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12. Changes to This Policy

We may update this Privacy Policy periodically. When we make material changes, we will update the "Last Updated" date at the top of this policy and notify you by email or through a prominent notice within the Service where appropriate. Your continued use of the Service after changes take effect constitutes your acceptance of the revised policy.

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13. Contact Us

If you have questions, concerns, or privacy rights requests, please contact us at:

Email: pivotry@learningtimes.com
Mailing Address:
LearningTimes, LLC
118 West 18th Street Floor 6
New York, NY 10011

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This policy is effective as of the date listed above and applies to all users of Pivotry the Neuroinclusive Coach.