Copilot
Effective October 25, 2026
This policy explains what Copilot collects, why, where it goes and what you can do about it. Copilot is run by First Class Leaders (13334007 Canada Inc.), based in St. Jacobs, Ontario, Canada. It applies to the app at app.firstclassleaders.com, to the Copilot apps for iPhone and Android, and to the emails and notifications the app sends.
Your account: name, email address and, if you sign in with Google or Apple, the basic profile they share. If you use Sign in with Apple and choose to hide your email, Apple gives us a private address that forwards to you, and that's the one we use. Anything you write in the app: signals you catch, reps, debriefs, wins, moves, your leadership vision, the belief you're working on, conversations with the AI coach, Growth Index answers and reports, feedback you send, and the optional "what I do" line. Settings such as reminder times, your time zone and push notification registrations. Membership and cohort information when you redeem a code or when your membership is synced from our community platform. Basic technical information such as device type and app version, used to keep the app working.
To run the app for you: show your history, keep your streak, send the reminders you turn on, and write your Growth Index report. To improve the program: the Growth Index and activity data of people in our coaching cohorts is used in aggregate to understand whether the program works. Anything we share publicly about results is aggregated and never identifies you. To support you: if you contact us we'll use your account details to help. We don't sell your information and we don't use it for advertising.
We never see or store your card details. On the web, payments are handled by Stripe. If you subscribe inside the Copilot app for iPhone or Android, Apple or Google handles the payment under their own terms, and we use a service called RevenueCat to confirm your subscription. RevenueCat receives your Copilot account ID along with the subscription you chose, its status and its renewal dates, and nothing you've written in the app.
We take this seriously, so here's exactly how it works. Copilot runs on Base44, a platform that's SOC 2 and ISO 27001 certified, meaning an independent auditor has checked its security practices. Your data is encrypted both while it's moving between your device and our servers and while it's sitting in storage. On top of that, every personal entry you make, a rep, a debrief, a coach conversation, your vision, is locked at the database level to your account specifically. That's not just a setting inside the app, it's enforced by the platform itself, so there's no way for another member, or most of our own staff, to open your private entries.
When you use the coach, ask for move suggestions or have a report written, the text involved is sent to Anthropic's Claude to generate the response. When you use voice dictation, the audio is sent to OpenAI to be transcribed and isn't kept afterward. Both are contractually barred from using what you send them to train their own models, and so are we. We've also asked Base44 to confirm that same protection holds at the infrastructure level, and we'll update this page once that's locked down.
Your data is stored on Base44's cloud hosting, which is based in the United States by default and may also be processed in Canada. If you're joining us from the UK or EU, that means your information crosses borders as part of how Copilot runs. Your reps, debriefs, coach conversations and vision are private to you, locked the way described above. First Class Leaders staff can see account, membership and Growth Index information to run the program and can open anything else only if you've asked us for help with it. If you're in a coaching cohort, your coach may see your Growth Index results as part of the program.
The app sends reminders and check in invites by push notification and email when you have them turned on, plus occasional messages about your account. You can turn reminders off in Settings and unsubscribe from emails using the link in any email.
You can delete your account yourself any time from Settings. That removes your account and everything tied to it right away, with no waiting period, and cancels any active web subscription immediately. A subscription you started in the iPhone or Android app is managed by Apple or Google, so you'll need to cancel it in your Apple or Google account settings as well, or it will keep renewing. If you'd rather we do it for you, or you want a copy of what we hold first, email kyle@firstclassleaders.ca. Aggregated program results that no longer identify you may be kept.
Copilot is for adults. We don't knowingly collect information from anyone under 18.
Under Canadian privacy law (PIPEDA) you can ask what we hold about you, ask us to correct it and withdraw consent, subject to legal limits. Write to kyle@firstclassleaders.ca. If you're not satisfied you can contact the Office of the Privacy Commissioner of Canada.
If you're in the UK or EU, GDPR gives you the same core set of rights and a couple more: to access what we hold, correct it, have it deleted, get a copy to take elsewhere, object to how it's used and complain to your own country's data protection authority. The reason we're allowed to process what you write in Copilot is that you've chosen to give it to us, and you can withdraw that at any time simply by deleting your account. This policy is written in plain language rather than legal language, so if you need something more formal for your own purposes, including confirmation of how a cross border transfer is safeguarded, write to kyle@firstclassleaders.ca and we'll sort it out with you directly.
If this policy changes in a way that matters, we'll tell you in the app. This version took effect on October 25, 2026.