Comprendo Privacy Policy

Privacy is important. We respect yours. Our goal is to do more than we have to by law - we want to earn your trust with your data.

Who we are and what this policy covers

Comprendo is operated by 1074 Ventures LLC, a Washington limited liability company doing business as Comprendo (“Comprendo,” “we,” “us”). This policy explains how we handle information when you visit our websites, contact us, or use our products, software, and services (together, the “Services”).

Some of our products have their own privacy notice that adds detail for that product, including the list of third-party providers that process data for it. For example, ListenTwice has a privacy and provider page. Where a product notice and this policy address the same topic, the product notice controls for that product.

Two ways we handle information

We handle information in two different roles, and your rights and our obligations differ between them.

Website visitors and people who contact us. When you browse comprendo.dev, read our writing, or send us a message, Comprendo decides how that information is used. The sections below on what we collect, cookies, and your rights apply directly.

Client engagements. Organizations such as schools, districts, nonprofits, and companies (“Clients”) hire us to run interviews, analyses, and other services. Information supplied, collected, or generated in those engagements - including interview content, transcripts, prompts, outputs, identifiers, role tags, metadata, and any audio - is “Client Data.” We process Client Data on the Client’s documented instructions under a written agreement with that Client. The Client, participating schools, and other owners keep their rights in Client Data; we do not acquire ownership of it. If you took part in an interview or other activity sponsored by a Client, that Client decides the purpose of the activity and how findings are reported, and the participant notice you saw before taking part describes the specifics. If our written agreement with a Client is stricter than this policy, the agreement controls for that engagement.

What we collect on our websites

We collect information about which Comprendo pages you visit, information about your device (such as device or browser type), referral information, and information you send us (such as the name, email address, organization, and message you enter in our contact form).

When you use our Services, we may collect and store your Internet Protocol address. We use this information to fight abuse and to generate aggregate, non-identifying information about how people use the Services. We may keep aggregated, non-identifiable information without limitation.

What we do not do

  • We do not sell personal information, and we do not “share” it for cross-context behavioral advertising as those terms are defined in California law.
  • We do not use identifiable information for advertising or unrelated profiling.
  • We do not use Client Data to train or fine-tune AI models, ours or anyone else’s, and we use only providers whose terms, as we use them, prohibit training on Client Data.
  • We do not make automated decisions about individuals that have legal or similarly significant effects, such as grading, discipline, eligibility, or clinical decisions. People review outputs, and Clients retain final decision-making authority.
  • We do not re-identify de-identified information or link it back to individuals.

De-identified aggregate information

Subject to our agreements with Clients and applicable law, we may create, keep, and reuse genuinely de-identified aggregate findings and service metrics to evaluate and improve our Services and to describe how well they work, including in general marketing. Aggregates must not identify, or reasonably permit identification of, a participant, Client, school, or confidential program, alone or in combination with reasonably available information. Before releasing an aggregate we review small groups, grade labels, contextual details, and combined releases for identification risk. Removing or replacing names is not enough on its own. This permission covers aggregate findings and metrics, not an archive of raw or merely pseudonymized transcripts, responses, audio, or participant-level records.

Named case studies, Client or school results, logos, and participant quotations are published only with prior written approval from the Client and anyone else whose authorization is required.

Who processes information for us

We rely on third-party providers to run the Services. They process data on our instructions and under their own published data protection terms, and we remain responsible for their performance.

For our websites, these providers currently are:

  • Google Cloud / Firebase - hosting for comprendo.dev and the serverless function that receives contact form submissions (United States).
  • Google Analytics - aggregate website usage analytics (see Cookies below).
  • Slack - contact form submissions are delivered to our internal Slack workspace so we can respond.

For each product that processes Client Data, the product’s privacy and provider page lists every provider that processes that data, the provider’s role, the categories of Client Data it processes, its general processing region, and a link to its published terms. Each page shows a last-updated date. We update the relevant page before a new provider begins processing Client Data, and we do not use providers that are not listed. Clients may object to a provider on reasonable data-protection grounds under their agreement with us.

Authorized Comprendo personnel may analyze Client Data with an AI service listed on the applicable provider page when needed to deliver the Services, minimizing identifying content where practical.

Voice and audio

Some of our Services, such as ListenTwice, use voice. We do not keep a separate audio recording of interviews. Audio is transmitted only to the providers listed on the product’s privacy and provider page for live processing. If an interview is interrupted, session-recovery data, which can include audio, may be held temporarily under the provider’s terms as described on that page, solely to restore the session and never for training or other reuse. The product page describes the specific retention periods involved.

Children and students

Our websites and accounts are intended for adults. We do not knowingly collect personal information from children through comprendo.dev.

Students may take part in interviews and other activities that a school or education organization has sponsored. In those cases the sponsoring Client and participating school document the authorized educational purpose and the lawful authorization route under laws such as FERPA, COPPA, and PPRA, including any required parent or eligible-student notices, permissions, or opt-outs. A student’s own statement that a parent has given permission does not substitute for that authorization. Participation is voluntary, and a student may decline or stop at any time without penalty. Student Data, meaning any Client Data that identifies or can reasonably be linked to a student, is used only for the school-authorized purpose; removing a name alone does not remove that protection. Participation by anyone under 13 requires additional documented review before it begins.

Only the data categories agreed with the Client, and other minimum information necessary for the approved purpose, are requested. Before participation we display the notice agreed with the Client and record its version, a timestamp, and the acknowledgment or consent method against a session identifier that is not a name.

Cookies and analytics

We use cookies and similar technologies such as local storage to recognize you when you return to our Services, for example to keep you signed in or remember your preferences.

Some third-party services that we use, such as Google Analytics, may place their own cookies in your browser. This policy covers use of cookies by Comprendo only and not the use of cookies by third parties. You can block or delete cookies through your browser settings.

Data security

We maintain administrative, technical, and physical safeguards proportionate to the sensitivity of the data we hold. These include:

  • encryption in transit (HTTPS/TLS) and at rest;
  • access limited to authorized personnel who are bound by confidentiality obligations;
  • multifactor authentication for privileged access;
  • content-bearing debug and error logging disabled or redacted, and any necessary security records containing Client Data minimized;
  • providers vetted for terms consistent with this policy.

No data transmission over the Internet is 100% secure, so we cannot guarantee security. You are responsible for taking reasonable measures to secure any account you hold with us, like using a strong password.

Retention and deletion

We keep different types of information for different periods, depending on why we process it and on legal requirements.

Website and contact information. We keep contact form submissions and correspondence as long as needed to respond to you and maintain our business records.

Client Data. We retain Client Data only while necessary for an authorized purpose under our agreement with the Client. After an engagement is completed or terminated, we may keep necessary data for a restricted transition period of up to 90 days solely for Client export, handoff, and orderly deletion, unless the Client extends it in writing for a stated purpose and fixed end date. We delete earlier when the purpose ends, when a valid deletion request requires it, or when law or school data terms require it. The de-identified aggregates described above do not extend retention of the source data.

Backups and residual copies. Residual backup, provider cache, or soft-delete copies are isolated from ordinary use, access-restricted, and subject to finite expiry periods. If a backup is restored, we reapply deletions. On request we will confirm deletion in writing, distinguishing completed active deletion from any remaining protected copies and when they expire. Archiving is not deletion.

Legal holds. Where law requires us to keep information, we keep only the data and for only the duration required, protect it from other use, and end retention when the legal duty ends.

Security incidents

If we discover unauthorized access to, use of, disclosure of, or other compromise of Client Data, we notify the affected Client without undue delay and within 48 hours of discovery, or sooner where law requires. An initial notice may be preliminary. We then contain and investigate the incident, preserve relevant evidence, cooperate with affected parties, provide material updates, and remediate the causes. The Client, or the party legally responsible, notifies affected individuals and regulators; we coordinate where lawful. Report a suspected security issue to the incident contact listed below.

Your rights and choices

Wherever you live, you can ask us to access, correct, or delete personal information we hold about you, or ask questions about how we handle it, by contacting us. We respond to requests promptly and within any deadline that applies.

If your information was collected in a Client engagement, we will route your request through the Client or participating school where that is required by our agreement with them or by law, because they decide the purpose of processing. Telling us the project name or interview link is enough to help us find your data.

California residents

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), gives you the right to know what personal information we collect, use, and disclose; to correct inaccurate personal information; to delete personal information; to limit the use of sensitive personal information; to opt out of the sale or sharing of personal information; and not to be discriminated against for exercising these rights. We do not sell or share personal information as defined in the CPRA. To make a request, contact us. You may also use an authorized agent.

Verifying requests

To protect your information, we may need to verify that you are who you say you are before acting on a request, and we may ask questions to understand the scope of what you are asking for. We will not disclose personal information about other people in responding to your request.

Disclosure of your information

We do not share your personal information outside the company except as described in this policy. We may share personal information: (1) with your consent; (2) with the providers described above that help us run the Services; (3) with the Client that sponsored an engagement you took part in, as described in the participant notice; and (4) when we have a good-faith belief it is required by law, such as pursuant to a subpoena or other legal process.

If we are going to share your information in response to legal process, we will limit the disclosure to what is required and give you or the affected Client advance notice so you can challenge it, unless we are prohibited from doing so by law or court order. We will object to requests for information that we believe to be improper.

Email from Comprendo

Sometimes we will send administrative emails about account or service changes, or new policies. You cannot opt out of those. Where we send marketing or newsletter email, you can unsubscribe at any time.

We will never email you to ask for your password or other account credentials. If you receive such an email, send it to us so we can investigate.

Changes to this policy

We may update this policy from time to time. The current version will always be at this address with the date it was last modified. We will notify you about significant changes, and prior versions are available on request.

Privacy and incident contacts

Questions, concerns, requests, and feedback about this policy: contact us or email hello@comprendo.dev.

To report a suspected security incident, email hello@comprendo.dev with “Security” in the subject line.

Last Modified: October 8, 2026