Privacy Notice

Last Updated: September 21, 2026

This Privacy Notice applies to the processing of personal information by First Person Labs PBC (“FPL,” “we,” “us,” or “our”) including on our website available at https://2.computer, our downloadable application for macOS (the “Second App”), and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

How Second Works. The Second App is installed on and runs locally on your Mac device. It builds a store of context from activity on your device, and that information is stored on your device. FPL does not store or access it.

FPL does not receive the information the Second App captures on its own servers or systems. When you use the Second App to carry out an artificial intelligence or agent task, the relevant information is sent from your device to a supported third-party artificial intelligence model (each, a “Model”). FPL is not in that path and does not store or access the information exchanged. The personal information described in this Privacy Notice is limited to the personal information FPL itself collects, which is described in “Personal Information We Collect” below.

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below. Information that the Second App captures and stores locally on your device is described separately in Section 2A and is not collected by us.

A. Information Processed Locally on Your Device

The Second App runs locally on your Mac and builds a store of context from activity on your device. Depending on your settings, this may include screen content, keyboard input, files and documents, messages, and other application activity. The Second App does not capture audio.

This information is stored locally on your device. FPL does not store or access it, and it is not transmitted to FPL’s servers or systems.

Because the Second App captures activity on your device, the information stored locally may include personal information about other people, including people who communicate with you. You are responsible for your use of the Second App and for the information you choose to capture, retain, and share with the third-party Model providers and other users you select.

You can pause or disable capture, exclude sources from capture, and delete locally stored information at any time using the controls in the Second App. See “Your Privacy Choices and Rights” below.

B. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include your name, email address, and information associated with your subscription or license.
• Purchases or Transactions. We may collect personal information and details associated with your purchases or transactions on the Services, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the surveys.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and resume or CV.

C. Personal Information Collected Automatically

We may collect personal information automatically when you visit our website or use the Second App. This is limited to the information described below and does not include the information the Second App captures and stores locally on your device.

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, device and operating system type and version, browser information, Second App version, installation or license identifier, and an approximate location derived from your IP address.
• Usage Information. We may collect diagnostic, performance, and usage information relating to our website and the Second App, such as crash reports, error logs, feature usage counts, and session duration. This information reports on the operation of the Second App. It does not include the content of the information the Second App stores locally on your device.
• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
• Cookies. Cookies are small text files stored in device browsers.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

D. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. If you choose to connect your Google account to the Second App, we may receive basic Google account information, such as your name and email address, which we use to administer your account and to communicate with you. We do not receive the Google data that the Second App accesses to build the information stored locally on your device. See “Supplemental Notice for Google Information” below.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to provide the Services, such as:

• Providing access to certain areas, functionalities, and features of the Services;
• Communicating with you;
• Answering requests;
• Sharing personal information with third parties as needed to provide the Services; and
• Processing your financial information and other payment methods.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful basis is performance of a contract with you and, where the processing is not strictly necessary to perform that contract, our legitimate interest in operating and securing the Services.

B. Improve the Services and Develop New Products and Services

We use personal information to improve the Services, such as improving, upgrading, or enhancing the Services.

We do not use your personal information, and we do not use the information the Second App stores locally on your device, to develop, train, or fine-tune artificial intelligence Models.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful basis is our legitimate interest in maintaining, securing, and improving the Services.

C. Operate Our Business

We use personal information to operate our business, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Carrying out analytics;
• Creating de-identified and/or aggregated information;
• Processing applications if you apply for a job we post on our Services;
• Allowing you to register for events;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful bases are our legitimate interest in operating our business and compliance with our legal obligations.

D. Marketing

We may use personal information in connection with our marketing activities including to tailor and provide you with marketing communications, promotions, and offers that may interest you.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful basis is your consent or, where permitted by applicable law, our legitimate interest in marketing our own similar products and services to existing customers.

E. With Your Consent or Direction

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

EU/UK GDPR Lawful Bases: If the EU GDPR or the UK GDPR applies to our processing of personal information under this section, our lawful basis is your consent.

4. HOW WE SHARE PERSONAL INFORMATION

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

• Service Providers. We may share personal information with service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting and cloud infrastructure, payment processing, customer support, analytics, email delivery, and IT support. Our service providers do not receive the information the Second App stores locally on your device.
• Third-Party Model Providers You Select. The Second App allows you to select the third-party AI Model providers that process your requests, including by using your own BYOK, or by using secure computing hardware offered by a third party. Where you make that selection, information is sent from your device directly to that provider and is subject to your arrangement with, and the privacy policy of, that provider. FPL does not store or access that information.
• Other Second Users You Connect With. The Second App allows you to connect with other Second users you choose. Where you do, information is exchanged directly between your device and that user’s device using end-to-end encryption. FPL does not store or access the content of those exchanges.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface with, interact with, share information with, direct us to share information with, access, and/or use a Third-Party Service.

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners we work with to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

• Affiliates. We may share your personal information with our corporate affiliates.

B. Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the Services or updates to this Privacy Notice).
• The Second App. You can pause or disable capture, exclude sources from capture, delete locally stored information, and uninstall the Second App at any time using the controls in the Second App and your device settings. Uninstalling the Second App removes the application and the locally stored information from your device. To request deletion of your FPL account, please use the deletion functionality available via the Services or contact us using the information set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Request Access to or Portability of Your Personal Information;
• Request Correction of Your Personal Information;
• Request Deletion of Your Personal Information;
• Request Restriction of or Object to Our Processing of Your Personal Information;
• Withdraw Your Consent to Our Processing of Your Personal Information. Please note that your withdrawal will take effect only for future processing and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below.

We will process such requests in accordance with applicable laws.

To protect your privacy, we will take steps to verify your identity before fulfilling a request. These steps may involve asking you to confirm the email address we have associated with you.

If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe that our processing of your personal information violates applicable law.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below. Information that the Second App stores locally on your device is not transferred to us, and we do not transfer it.

7. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as long as necessary to fulfill the purpose(s) for which it was collected, or as long as necessary to pursue our business purposes. Information the Second App stores locally on your device is retained on your device until you delete it or uninstall the Second App.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements; the amount, nature, and sensitivity of the personal information; certain risk factors; the purposes for which we process your personal information; and whether we can achieve those purposes through other means.

8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR applies only to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

9. SUPPLEMENTAL NOTICE FOR GOOGLE INFORMATION

This section only applies to our processing of information that we obtain from Google that is subject to the Google API Services User Data Policy (“Google Information”).

FPL’s use of Google Information will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

FPL will use commercially reasonable efforts to implement and maintain safeguards designed to protect Google Information, including, if applicable, sensitive data. Examples of the safeguards we may use include, but are not limited to, encryption and access controls.

To the extent this Privacy Notice conflicts with the Google API Services User Data Policy, the Google API Services User Data Policy shall control with respect to our processing of Google Information.

If you choose to connect your Google account to the Second App, the Second App accesses the Google data you authorize and stores it locally on your device. FPL does not store or access that data. The only Google Information FPL receives is basic Google account information, such as your name and email address, which we use to administer your account and to communicate with you. You can disconnect your Google account at any time using the controls in the Second App or through your Google account settings.

10. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 18 and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

11. CONTACT US

First Person Labs PBC is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at: support@2.computer.