Privacy Policy

1) Information We Collect

• Account and Contact Information: Names, organizational affiliations, email addresses, and contact details of users and administrators.
• Usage Data: Application activity, log data, IP addresses, browser type, and performance metrics.
• Training and Input Data: Information you or your authorized users upload for training, such as student profiles, assignments, and performance records.
• Service Data: Automatically generated operational data, analytics, and technical logs related to service stability and improvement.

During pilot or evaluation phases, we may use aggregated, non-identifiable data to test and improve performance, functionality, and user experience.

2) How We Use Information

• To operate, maintain, and improve the Application.
• To provide technical support and respond to inquiries.
• To analyze usage for product enhancement and performance.
• To communicate important notices, updates, or security alerts.
• To comply with applicable legal obligations.

3) Legal Basis for Processing

We process information as necessary to perform our contractual obligations with our clients, to comply with legal requirements, and to pursue legitimate business interests such as maintaining security, improving functionality, and preventing misuse.

4) Data Retention

We retain information only as long as needed to fulfill the purposes outlined in this Policy, comply with legal requirements, or maintain business continuity. Training data from pilot or production environments may be deleted or de-identified upon request or within 30 days of termination, with system backups retained up to 90 days.

5) Disclosure of Information

We do not sell or rent personal information. We may disclose limited data only to:

• Service providers (e.g., Supabase) assisting in hosting and infrastructure.
• Law enforcement or government entities when required by law or subpoena.
• Authorized business transfers such as mergers or acquisitions, provided protections remain in place.

6) Data Security

We implement administrative, technical, and physical safeguards designed to protect data integrity and confidentiality, including encryption in transit (TLS) and at rest (via Supabase). Despite these measures, no platform can guarantee absolute security. Users should promptly notify us of any suspected unauthorized access.

7) Your Rights

Depending on your relationship with us and your location, you may have the right to:

• Access, correct, or delete personal data.
• Request restriction of processing or object to certain processing activities.
• Request data portability where applicable.
• Withdraw consent for communications or optional processing at any time.

Requests should be submitted to cbuer@hotmail.com. We may require verification before fulfilling certain requests.

8) Washington State Privacy Compliance

We comply with applicable Washington State privacy and consumer protection laws, including the Washington Consumer Protection Act (RCW 19.86) and, where applicable, the My Health My Data Act (RCW 19.373). In the event of a data breach involving personal information of Washington residents, we will notify affected parties and relevant authorities in accordance with RCW 19.255.010.

9) Data Processing Role

Tempered Training Solutions LLC acts primarily as a data processor or service provider for its client organizations. We process personal and training data only under the instructions of our clients and do not independently determine the purposes or means of processing.

10) Children’s Privacy

The Application is designed for professional and institutional training purposes and is not directed to children under 13. We do not knowingly collect personal data from minors. If we learn we have done so, we will promptly delete such data.

11) Governing Law

This Privacy Policy is governed by the laws of the State of Washington. Any disputes arising under this Policy shall be resolved exclusively in the state or federal courts of Clark County, Washington.

12) Changes to This Policy

We may update this Privacy Policy periodically to reflect operational, legal, or regulatory changes. Material updates will be posted in the Application or communicated directly. Continued use after changes become effective constitutes acceptance.

13) Contact

• Privacy Officer: Tempered Training Solutions LLC (d/b/a Kyln)
• Location: Vancouver, WA 98682
• Email: cbuer@hotmail.com

14) Future Name Changes

If the DBA name changes (e.g., “Kyln” → “Forge”), update only the “Doing Business As” references and public-facing branding. The underlying legal entity, Tempered Training Solutions LLC, remains responsible for privacy and data protection obligations.