Privacy Policy

Effective date: October 12, 2026 Applies to: FluentOrg, The AI-Enabled Organization: the program at fluentorg.com, the learner portal at portal.fluentorg.com, and the prd-writer skill (together, the "Service").

FluentOrg is the product. Caldermont Management LLC ("we," "us," "our") is the company behind it, and the name that appears on your card statement and on your invoice.

The short version

• We collect what it takes to sell you seats and let the right people into the program: name, work email, company, billing address, and what you bought.
• We record how far each learner has got: modules marked complete, exam attempts and scores. Whoever bought the seat can see that. That is the point of the product, and Section 5 says exactly who sees what.
• If you sit a proctored exam under artificial intelligence (AI) proctoring, it is recorded, and your face is matched to your identity document. That happens only with your written consent, given on the check-in screen. Section 2 says exactly what is collected, and Section 8 how long it is kept.
• We never see your card number. Stripe handles payment; we keep the receipt.
• We do not see what you type into your AI tools. The modules teach you to work in Claude, ChatGPT, Copilot and the rest; that work happens in your own accounts, under those vendors' terms, and none of it passes through us.
• No advertising and no cross-site tracking. We count visits to our site, and the steps companies take from signing up to buying, to learn whether the product works, and we note which link or other website a company's first visit came from, to learn which of them are worth paying for. The counts name nobody, and they use no cookie. The Service sets three cookies and keeps four things in your browser's own storage. Every one does a job, and Section 4 lists them all.
• We do not sell or share your personal information, and we never have.
• Ask us anything about your data at support@fluentorg.com.

1. Who is responsible for your data

Which of us answers for your record depends on how you got your seat.

If you bought seats yourself, we are the controller of the information you gave us, and this policy governs it.

If your employer, or an IT partner or reseller acting for them, bought your seat, they decide what happens with your learning record: who is seated, what is visible to whom, and when it is deleted. They are the controller; we hold and process it on their instructions. Their own privacy notice governs that record, and a request to delete or correct it is usually theirs to grant. Write to us anyway if you cannot reach them (Section 9).

2. What we collect

Everyone who visits the site. Our content delivery network and our API keep ordinary request logs: IP address, user agent, the URL requested, and the time. We use them to keep the Service running and to investigate abuse, and for nothing else.

How many people visit. When a page of our site loads, it tells us whether you arrived from another website or from another of our pages. We add one to that day's totals, and that is all the count keeps: no IP address, no cookie, and nothing stored in your browser. If your browser sends a Do Not Track or Global Privacy Control signal, the page does not tell us at all.

Where your first visit came from. When you first arrive at our site from another website, or by a link that names a campaign (an advert, or a link in a newsletter or a post), the page keeps a note in your browser's own storage of where you came from: the other website's name, never the page you were on, and the campaign names the link carried. It keeps nothing when you typed our address or came from one of our own pages, and nothing at all if your browser sends a Do Not Track or Global Privacy Control signal. The note stays in your browser and is sent to us only if you sign up or buy, with that form. We then keep it with the steps your company takes (below) and with your order, to count which links and websites lead to sign-ups and sales. It names nobody. Your browser discards it after 90 days.

The steps a company takes. When someone signs up, takes the AI Fluency Check for the first time, sees a team report, starts a free trial, finishes a first module on it, has three or more people start a module, keeps a card on file, pays, buys on our site without a trial, is refunded, or ends a trial without paying, we record that the step happened: with the organization, the company's email domain, the company size given at sign-up, where the company's first visit came from (above), and the time. We do not record your name, your email address, your Check result or your answers with it. We use these records only to count how many companies reach each step.

When you buy. Your name, work email, company name, and the email of the person who will administer the seats. Stripe collects your billing address and your card details on its own checkout page; your card number never reaches us. From the completed purchase we keep what was bought, how many seats, the price and the term, and the Stripe customer, subscription and session identifiers that let us match a renewal to your account. Where your browser holds a note of where your first visit came from, it goes with the order through Stripe and is kept with it.

When someone gives you a seat. Your first name, last name and work email, entered or uploaded as a spreadsheet by whoever administers your organization. Nothing about you is collected from anywhere else: we do not buy lists or enrich records.

When you sign in. A sign-in account holding your email address, first name and last name. Passwords are set and checked by Amazon Cognito; we never see yours, and no one at Caldermont can read it.

While you use the program. Which modules you have marked complete and when; each exam attempt, its score, the total, and whether you passed; and when you last signed in. This is held against your email address so it follows you between your laptop and your phone.

When you administer an organization. We keep a history of administrative actions (who added, invited, renamed, revoked or removed what, and when) so an organization can account for changes to its own seats.

When you write to us. Whatever you put in the email, for as long as it takes to deal with it and to keep a record of the answer.

When you sit a proctored exam. A proctored sitting of the AI Cyber Security Foundations or AI Cyber Security Operations exam is optional and bought separately, in one of two modes: with a human invigilator, or under artificial intelligence proctoring. The same paper is sat in both. The mode is who watches.

In both modes we keep the paper you were given, your answers, your score, when the paper was started and submitted, who marked or reviewed the sitting and what they decided. This is kept with your learning record.

Under artificial intelligence proctoring, before the paper opens:

• You consent to what this part describes. We record when you did, which version of the text you read, and the internet address and browser you gave it from.
• Your computer is checked. We keep the names of the browser, the cameras and the microphones it reported, whether the whole screen was shared, whether a second display was present, and whether the page was in full screen.
• Your government identity document is checked by Stripe Identity, Stripe's identity verification service. Stripe reads the document and takes a selfie to match it to, and Stripe keeps the images of the document and the identity data under its own privacy policy. Stripe's answer to us carries more than we keep: we store only the outcome, the name on the document, the kind of document and the country that issued it, the time, Stripe's reference for the check, the reason a check failed, and the selfie Stripe matched to it. We do not keep the document images, its number, your date of birth or your address.
• A photograph of your face is taken at check-in and compared with that selfie by Amazon Rekognition, a face comparison service run by Amazon Web Services. The same comparison is made on some of the pictures from your camera during the sitting.
• You make a short scan of the room with your camera.

During the sitting:

• Your camera takes a picture every few seconds, your whole screen is captured every fifteen seconds, and your microphone records in short chunks. Each picture from your camera is read by Amazon Rekognition to count the faces in it and which way they face, and some are compared with your photograph. The count, the direction and the comparison score of each picture are kept with the sitting.
• Your browser reports signals about the sitting: which camera and microphone are in use, whether the whole screen was shared, whether a second display is present, when full screen is left or the window loses focus, when text is pasted or copied or the right-click menu is opened, and key presses and clicks sampled to tell typed input from input sent by software.

An artificial intelligence model from Anthropic is shown pictures at two points. During the sitting, at a moment the rules flag as serious (a second face in view, a face that does not match, the camera changed), it is shown the 6 pictures from your camera and 2 of your screen around that moment, with what the rules found there and the face counts and comparison scores of those pictures, and writes what is visible in them. After the sitting, it is shown 24 pictures from your camera and 8 of your screen, sampled evenly across the whole sitting, the 8 pictures of the room scan, the moments the rules flagged with what it wrote about them, the browser signals, and the face counts and scores across the sitting, and writes a report of what is visible: how many people, and whether a phone, notes or a second screen can be seen. It is never asked who a person is, whether two faces are the same person, or how anyone feels. A person at Caldermont reads the report and the recording and makes every decision about the result; the artificial intelligence decides nothing on its own.

With a human invigilator, the invigilator sees you and your identity document on a video call and records that you attended. We keep no recording of the call.

Your consent to biometric data. The photograph of your face, the pictures from your camera and the comparison between them are biometric data. We collect them only with your written consent, which you give by ticking a box on the check-in screen before the sitting starts; the record of your sitting names the version of the text you read. You can withdraw that consent at any time: before the paper starts, by calling the sitting off from your Verified credential page in the portal; during the sitting, by closing the page; or at any point by writing to support@fluentorg.com. What withdrawing does depends on when. Before the paper starts, the sitting is called off. Once the paper has started, closing the page ends it: the paper is sent as it stands, and a person then voids the sitting at your request, so no result is released from it; the email that tells you so says it was called off at your request. In either case the recordings and the pictures are deleted. Before the paper starts the fee is refunded if you ask; a sitting whose paper was opened counts as sat, so its fee is not refunded and your next sitting is at the retake price and may be sat 14 days on. A result released before you withdrew stays, and so does the report it rests on, for the life of the credential (Section 8); the recordings behind it are deleted on your request, or after 90 days, whichever comes first.

3. What we do not have

• The work you do in your AI tools. The program teaches you to use them; it does not sit between you and them. Prompts, documents, PRDs and outputs stay in your own accounts with those vendors.
• The content you put into the prd-writer skill. The skill runs inside your Claude account. What you give it goes to Anthropic under Anthropic's terms, and never to us. Please do not put personal, confidential or regulated data into it that you are not authorized to share.
• Your exam answers: when you submit an exam, your answers are sent to us, graded, and kept with your result, so your score can be checked. Your organization's administrator sees your score, not your answers.
• The identity document you show under AI proctoring. Stripe Identity reads it and keeps its images. Stripe's answer to us carries more than we keep: we store only the outcome, the name, the kind of document and the issuing country, and we do not keep the document images, its number, your date of birth or your address.
• Your card number, as above.

4. Cookies and browser storage

We use no advertising cookies, no cross-site trackers, no analytics cookies, and no ad pixels. The counting in Section 2 uses none of them. Nothing the Service sets will follow you to another website. Here is the whole list: three cookies, and four things kept in the browser's own storage.

You can clear or block all of these in your browser. Blocking the first two means the program cannot verify your seat, so the paid pages will not open.

5. Who can see your learning record

An employer buys this program because it needs to know its teams can work with AI, so a learning record is not private from the organization that paid for it. Being straight about that:

• You see everything recorded about you.
• Your organization's administrators see each seated learner's name, email, modules completed and exam results, for the modules that organization bought and no others. If you also hold a seat somewhere else, that work stays out of this view.
• The partner or reseller that manages your organization, if one does, sees the same for its own clients.
• Caldermont staff see it when supporting your account or investigating a problem.
• Nobody else. One learner's progress is never shown to another.

6. Why we may use your information

To provide and support the Service; to take payment, invoice, and handle renewals; to create and manage sign-in accounts and seats; to send you the emails your account requires; to keep the Service secure and working; and to meet our legal, tax and accounting obligations.

The emails we send are about your account: your invitation, an order confirmation, a renewal reminder, an invoice, a reply to your question. We do not run a marketing list and we do not send promotional email to learners.

Legal bases (GDPR / UK GDPR). Performance of a contract, or steps taken at your request before one, to sell and provide the Service; our legitimate interests in operating, securing and improving it, balanced against your rights; and our legal obligations for tax and accounting records. Where we act on your employer's instructions we do so as their processor, on their legal basis. Counting visits and the steps in Section 2 is in our legitimate interest in knowing whether the Service works, and noting where a first visit came from is in our legitimate interest in knowing which links and websites bring us customers; none of it records anything that names you. The biometric data of a proctored sitting under artificial intelligence proctoring is processed on your explicit consent, and Section 2 says how to withdraw it.

We do not use your information for automated decision-making that produces legal or similarly significant effects about you. An AI's report on a proctored sitting is read by a person, who makes the decision (Section 2).

7. Who we share it with

We do not sell your personal information, and we do not share it for anyone else's marketing. We use a small number of service providers, each under contract and each able to use your information only to provide its service to us:

If you sit a proctored exam, these also handle your information, and only for that sitting:

Where a human invigilator is used, the invigilator is a Caldermont employee or a contractor bound by confidentiality. They see you and your identity document on the call and keep no copy of either.

Beyond those, we disclose information only where the law requires it or to protect the rights, property or safety of our users or others; and, if we are ever part of a merger, acquisition or sale of assets, to the acquirer, who inherits the commitments in this policy. We would tell you first.

If a partner or reseller manages your organization, its people have the access described in Section 5. They are separately responsible for what they do with it.

8. How long we keep it

• Seats and learning records for as long as the organization's access runs, and then while it may be renewed. When an organization is deleted, its seats and learners' records go with it.
• Sign-in accounts until the seat is removed or you ask us to delete the account.
• Order and invoice records for as long as tax and accounting law requires, typically seven years. These cannot be deleted on request.
• Administrative history for as long as the organization exists, so changes to seats stay accountable.
• Request logs for a short operational period.
• Visit totals and the steps in Section 2 for 25 months, and then they are deleted. A step keeps where the company's first visit came from for as long as the step is kept.
• A proctored sitting's recordings (the pictures from your camera and your screen, the audio, the room scan, the photograph of your face taken at check-in and the selfie Stripe matched it to) for 90 days after the sitting, and then they are deleted automatically.
• A proctored sitting's report, the outcome of the identity check, its check-in and the index of its recording for 36 months after the sitting was last moved (decided, called off or expired), the life of the credential, and then they are deleted automatically. That is the report; the outcome of the identity check (that the document was verified, the name on it, its kind and its country, Stripe's reference and the reason a check failed); the check-in (the address and browser the consent was given from, the browser and devices of the computer check, the face enrolment's score and the room scan); and the index of the recording (for each picture, the face count, the direction and the comparison score; the moments the rules flagged; and the browser signals). The paper, the answers, the score, the decision and who took it, and when you consented and to which text, are part of your learning record, above.
• The identity document itself is kept by Stripe under its own retention, never by us.
• Email you send us for as long as it takes to answer and to keep a record of the answer.

9. Your rights and how to use them

In the EEA or UK (GDPR / UK GDPR) you may ask for access to your data, correction, deletion, restriction, objection to processing, portability, and withdrawal of consent where we rely on it. You may also complain to your supervisory authority: in the UK the Information Commissioner's Office, in the EEA your national authority.

In California (CCPA / CPRA) you may ask what we hold about you, ask us to delete or correct it, and opt out of sale or sharing. We do neither: we do not "sell" and do not "share" your personal information as those terms are defined, and have not in the preceding twelve months. The biometric data of a proctored sitting is sensitive personal information; we use it only to run the sitting you asked for and to decide its result, and for nothing else. We do not use sensitive personal information for any purpose that would require us to offer a "limit" right, and we do not engage in cross-context behavioral advertising. We will not treat you differently for exercising any of these rights.

How to ask. Email support@fluentorg.com. We will verify the request and answer within the time the law allows, generally 30 days under GDPR and UK GDPR, 45 days under CCPA and CPRA, with an extension where permitted. You may use an authorized agent where the law allows one.

If your seat was bought for you, ask your own organization first: the record is theirs to correct or delete, and they can do it in the portal immediately. Tell us if you cannot reach them and we will help.

10. International transfers

We process and store information in the United States. If you are in the EEA or the UK, that is a transfer out of your region: where one is needed we rely on an appropriate safeguard, such as the European Commission's Standard Contractual Clauses with the UK Addendum. Our providers in Section 7 are bound by the same.

11. How we protect it

Sign-in is handled by Amazon Cognito, so no password is ever stored by us. Traffic is encrypted in transit. Access to the program is granted by a signed token that cannot be edited into somebody else's, and the portal refuses any request for an organization the caller does not administer. Staff access is limited to the people who need it. A proctored sitting's recordings are held in a private store that nothing but the portal can reach, and the store deletes them on the schedule in Section 8 by itself. No system is perfectly secure, and we do not claim otherwise.

12. Children

The Service is for working professionals and is not directed to children. We do not knowingly collect personal information from anyone under 16. If you believe a child has given us information, write to us and we will delete it.

13. Changes to this policy

We may update this policy. When we do we will change the effective date above, and for material changes we will give more prominent notice, by email to account administrators where it affects learners. Continuing to use the Service after an update means you accept the revised policy.

14. Contact us

Questions, requests, or complaints about this policy or your personal information:

Caldermont Management LLC support@fluentorg.com fluentorg.com

This policy is governed by the laws of Massachusetts, United States, without regard to its conflict-of-laws rules.