AI Implementer Certification Privacy Policy
Version 2026-10-31
Effective: 2026-10-31
1. Who we are and what this covers
The AI Implementer Certification ("the course") is run by Digital Operations Institute LLC, 14478 Corallin Drive, Chesterfield, Missouri 63017 ("DOI", "we"), which also runs FDE App. We decide how and why your information is used. DOI is a wholly owned subsidiary of ClickDown, LLC, doing business as 3rd Brain Digital Operations ("3rd Brain"), which helps run the course. We share information with it as section 5 describes, and it uses that information under this policy.
This policy explains what we collect when you apply for or take part in the course, use the course site, its downloads or tools we offer for your AI assistant, or deal with us about the course; what we do with it; and the choices you have. It is part of the AI Implementer Certification Terms of Use.
FDE App, which you use for some exercises, has its own privacy policy.
2. What we collect
| What | Examples | Where it comes from |
|---|---|---|
| Account information | Your name, email address, password (stored only as a scrambled hash), course language, and sign-in sessions | You; our staff, when they invite you |
| Your application | Country and city, time zone, current role and work status, phone number, availability, LinkedIn and portfolio links, résumé, expected monthly pay, and how you heard about us | You |
| Scholarship request | Whether you asked for a scholarship; the monthly income you gave and your declaration that it is true, the wording you agreed to, and when; our decision, when it was made, and which of our staff made it | You; our staff |
| Location signals | The country of your IP address when you sign up, when you submit your application, and when you ask for a scholarship, along with the IP address itself; the country your phone number's code belongs to; and the time zone your browser reports. We find the country of an IP address with a copy of DB-IP's database kept inside the course app (IP geolocation by DB-IP), so your address isn't sent to anyone to look it up | Your browser; worked out by the app |
| Payment | Whether and when you paid, the amount, the tax, your billing address and any business tax ID, Stripe's references for the payment, and its receipt and invoice. Stripe's Link service sells you the course and collects your card details; we don't see or store your full card number | You, through Stripe and Link; Stripe |
| Background video | Your recording (your face, your voice and what you say), or a link to one | You |
| Personality assessment | Your answers to 120 questions, and your scores on five broad traits and 30 facets | You; scored by the app |
| Examples of past work | Titles, descriptions, tools used, videos, links and files | You |
| Review records | Rubric scores, interview notes, decision notes, your application's stage, and its dates | Our staff |
| Interview | The call, its recording and transcript, and notes | You and our staff; our meeting-recording tool |
| Course work | Lessons you have finished; your quick-check and module-review answers; exercise and project hand-ins (text, links and files) with their status, scores and reviewer notes; feedback and comments you leave on lessons; daily and weekly reports; and your messages in the persona chats | You; our staff |
| Learning analytics | For each lesson and step: when you open it and each visit; active time; idle time, both when the tab is in the background and when there has been no input for a few minutes; and when you finish. Your browser tells us only whether there was any input, not what you typed, where you clicked or what is on your screen | Your browser, while you use the course |
| Downloads and AI-assistant activity | Each download, including the reference code stamped into your copy of the reference pack. If we offer tools for your AI assistant, also each request it makes: the tool, the lesson or step, the time, and anything you hand in through it | The course site; your AI assistant |
| Acceptance records | Which version of the Terms and this policy you accepted, when, how (sign-up, invite or payment), your IP address and its country, and your browser at the time | Your browser |
| Communications | Emails, messages (including in Slack channels we give you), support requests, survey answers, and calls with us, which we may record and transcribe | You |
| Information from others | References you give us; public professional profiles, such as LinkedIn; people who refer you; and, for marketing only, business-information providers | Those sources |
| Website and marketing data | Pages you visit on our public sites, and the link, post or ad that brought you | Your browser, cookies and similar technologies (section 3) |
| Technical data | IP address, browser and device details in our hosting provider's request logs | Your browser and our hosting provider |
3. Cookies and similar technologies
The course site uses a cookie to keep you signed in. The service needs it to work. Staff tools use a few more for the same purpose.
We may also use cookies, pixels, local storage and similar technologies to:
- remember your settings;
- understand how people find and use our sites and the course; and
- measure and improve our marketing, including showing our ads on other sites.
Some of these may be set by analytics and advertising providers (section 5), who may also collect information about your visits to other sites and use it under their own terms.
Course videos play from YouTube in its privacy-enhanced mode. YouTube may store information in your browser when you play one.
You can block or delete cookies in your browser settings, but the course needs its sign-in cookie. Where the law requires your consent, we ask for it before setting cookies the course doesn't need to run. We honor Global Privacy Control signals where the law requires it. We do not respond to Do Not Track signals.
4. How we use it
- To run the course for you: your account, your progress, your hand-ins and reviews, your certificate, and the course's emails.
- To review applications. We review your application, background video, personality assessment, examples, interview and course record to decide whether to accept you into the course and whether to certify you.
- To take payment, issue receipts and invoices, handle refunds and disputes, collect and report taxes, and keep accounts.
- To decide scholarship requests. We compare the country you give with your location signals. A difference raises a question we may ask you, for example in the interview; it never decides a request on its own. A person decides every request.
- To comply with sanctions law, which bars us from offering the course in some countries and regions.
- To understand how you learn, using learning analytics: to see how long lessons take, where people slow down or stop, and how engaged each trainee is; to coach you; and to consider your progress and engagement in certification.
- To protect the course: to detect and stop copying or sharing of Course Materials, including with marks on served material and records of what each account opens and requests (Terms 6 and 7).
- To support you when you ask.
- To improve the course and build new courses, products and features, including AI models. We may train and evaluate AI models on your submissions, answers, persona-chat messages, feedback and usage data.
- To market DOI, 3rd Brain and FDE App to you.
- By email: you get our emails by default, and every marketing email has an unsubscribe link.
- By phone, and on social networks.
- By showing our ads to you and to people like you on other sites, including by giving advertising platforms a scrambled (hashed) form of your email address.
- To name you as a trainee or graduate, and to use your feedback and non-confidential work samples in our marketing, as Terms 10 allows.
- To create de-identified, combined data that doesn't identify you, and use it for any lawful purpose, such as publishing benchmarks of how long people take to learn a skill.
- To meet legal obligations, enforce our terms, and protect our rights.
We do not use AI to score or rank applicants today. If we start, we will update this policy and tell you first, as the law requires.
We do not sell your information for money. Some US state laws may treat letting advertising providers collect information through cookies for ads on other sites as a "sale" or "sharing" of personal information. To opt out, email us (section 9). We do not knowingly sell or share information about anyone under 16.
5. Who we share it with
Providers that run the course and our business for us, each with what it needs:
| Provider | What it does | What it handles |
|---|---|---|
| Fly.io | Hosts the course site and its database (Chicago, United States) | Everything, while the course runs |
| Tigris | Stores files | Résumés, videos, hand-in files and course files |
| Stripe, and its Link service | Sells you the course as seller of record: takes your payment, works out and pays the tax, sends receipts and invoices, and handles payment questions, refund requests and disputes | Your name, email address, billing address, card details, tax ID, any Link account, and your IP address and device when you pay. Stripe and Link handle this as independent controllers under their own privacy policies, not on our behalf, including for preventing fraud and meeting their legal duties. Ask them directly to see or delete it |
| Resend | Sends our emails | Your name, your email address, and what the email says, including reviewer notes |
| OpenAI, or another AI model provider we choose | Writes the personas' replies in the case chats | Your chat messages and the persona's instructions. Not your name or email address |
| YouTube (Google) | Plays course videos | Your IP address and browser, when you play a video |
| DigitalOcean | Serves the DOI logo on course pages | Your IP address, when a page loads |
| Scheduling, meeting-recording, email, chat and CRM tools (for example Calendly, Fireflies, Google Workspace, Slack and our CRM) | Book and record interviews, and keep track of our communications and relationship with you | Your name and email address, the call and its transcript, and your messages |
| Analytics and advertising providers (for example Google and Meta), where we use them | Measure how people use our sites and how our ads perform, and show our ads | Website and marketing data, cookie identifiers, IP addresses and hashed email addresses, under their own terms |
Also:
- 3rd Brain, our parent company, which helps review applications and run the course, and markets its services, under this policy.
- Our staff at DOI and 3rd Brain, who review applications and run the course.
- Your AI assistant's provider. When you use course materials or course tools with your AI assistant, its provider (for example Anthropic or OpenAI) handles what it reads and sends, under your agreement with them, not this policy.
- FDE App, for the exercises that use it, under its own terms and privacy policy.
- Other trainees, who see what you post in shared course channels, and anyone who sees our public list of graduates (Terms 10).
- Our affiliates, current and future, under this policy.
- Anyone, when the information is de-identified and combined, as section 4 describes.
- When the law requires it, to protect our rights or someone's safety, or to a buyer of all or part of our business, who would have to honor this policy.
- With your consent, or at your direction.
6. The personality assessment
- What the assessment is: a public-domain questionnaire that scores five broad personality traits and 30 facets. There are no right or wrong answers. It is not designed to diagnose any condition.
- How we use it: as one input among several. Reviewers read it alongside the rest of your application.
- Who decides: people at DOI and 3rd Brain make every decision about your application and your certification. No decision about you is made by software alone.
- Accommodations: if you need an accommodation for the assessment, the video, the interview or the course, email us (section 15).
- Fairness: we don't make decisions based on race, color, religion, sex (including pregnancy, sexual orientation and gender identity), national origin, age, disability, genetic information, veteran status or any other status the law protects.
7. Other people's information
If you give us information about someone else, you must have the right to share it. This covers a reference, a person in your background video, or a person in your examples of past work. Remove or redact other people's personal information, and your employers' and clients' confidential information, before you submit (Terms 8(d)).
8. How long we keep it
We keep information for as long as we need it for the purposes in this policy. That includes running and protecting the course, considering you for future cohorts and work, marketing to you, resolving disputes, enforcing our terms, and meeting legal obligations. In particular:
- Your account and course record stay while your account is open.
- Applications, including ones not accepted, are kept while we may need them to consider you again for a later cohort, to answer questions about our decision, or to meet legal obligations, unless you ask us to delete them.
- Your scholarship request, the decision and your location signals stay with your application. Where a scholarship was granted, we keep them as long as we may need them to enforce Terms 2(h).
- Payment and tax records are kept as long as tax and accounting law requires, including after your account is deleted.
- Learning analytics stay with your course record. De-identified, combined data may be kept indefinitely.
- Acceptance records and records of what each account opened and requested are kept as long as we need them to show what you agreed to and to enforce our terms, including after your account is deleted.
- Information already used to train or evaluate an AI model can't be removed from that model. Deleting your account stops its future use.
- Backups. Deleted information leaves our database provider's backups within its retention period.
9. Your choices and rights
- See it, and get a copy: ask us for the information we hold about you.
- Correct it: edit your profile in the course, or ask us.
- Delete it: ask us to delete your account and information. We keep what section 8 says we must or may keep.
- Object, or ask us to limit a use: for example, to publicity or AI training.
- Withdraw consent where we rely on it. This doesn't affect what we did before.
- Marketing email: use the unsubscribe link in any marketing email. We'll still send emails about your application and the course.
- "Sale" or "sharing": opt out of what section 4 describes.
- Ask us anything about your information at michael@3rdbrain.co. We may need to confirm your identity. We answer within the time the law sets, usually 30 days.
Depending on where you live, you may have further rights under your local law. These include appealing our answer to a request, and complaining to your data protection authority, such as a supervisory authority in the EU or UK. Write to us and we will honor them as that law requires.
10. Legal bases (EU, UK and other countries that require them)
| Use | Legal basis |
|---|---|
| Running the course and your account | Our contract with you (the Terms) |
| Taking payment, refunds, and tax and accounting records | Our contract with you; our legal obligations |
| Deciding scholarship requests, including the location signals | Our legitimate interest in giving scholarships only to people who qualify. You can object, but then we can't consider a request |
| Sanctions checks | Our legal obligations |
| Reviewing your application, the personality assessment and the interview | Steps you ask us to take before a contract; our legitimate interest in choosing who joins and who is certified |
| Learning analytics, protecting the course, and improving the course and our products, including AI models | Our legitimate interests in running a good course, protecting it, and building our business. You can object |
| Marketing email | Your consent where the law requires it; otherwise our legitimate interest in telling you about our services |
| Cookies the course doesn't need to run | Your consent |
| Acceptance records, and legal and tax obligations | Our legal obligations, and our legitimate interest in proving and defending our rights |
You have to give us the information the application asks for if you want to be considered. Everything else is up to you.
11. Where your information is
We store and process information in the United States. If you take part from elsewhere, your information comes to the United States, where the law may protect it differently. Where a transfer mechanism is required, we use one recognized by your law, such as standard contractual clauses. Where your law requires your consent for this transfer, you give it when you accept these terms in the app.
12. Security
Connections to the course are encrypted. Passwords are stored only as scrambled hashes. Access to applications and course records is limited to the person they belong to and to our staff. No system is perfectly secure. If a breach affects your information, we will tell you as the law requires.
13. Children
The course is for people 18 and older. We don't knowingly collect information from anyone younger.
14. Changes
We may change this policy by posting the new version here with its date. If a change is material, we will tell you by email or in the app before it takes effect, and we may ask you to accept it in the app. Using the course after a change takes effect means you accept it.
15. Contact
Digital Operations Institute LLC, 14478 Corallin Drive, Chesterfield, Missouri 63017; michael@3rdbrain.co.
Adapted in part from the Basecamp open-source policies / CC BY 4.0, via the AI Ops Cloud (now FDE App) Privacy Policy.