Privacy Policy

1. Introduction

This Privacy Policy describes how Cognein LLC ("we," "us," or "our") collects, uses, and shares information about you when you use our mobile and web application and related services (collectively, the "Service"). This Policy applies to information we collect through the App and in email, text, and other electronic communications. By using the Service, you consent to the data practices described in this Policy.

2. Information We Collect

2.1. Information You Provide to Us

• Account Information: When you create an account, we collect your name, email address, and password.
• Profile Information: You may optionally provide additional information such as your job title, industry, company name, and professional interests.
• User Content: Any content you submit, post, or share through the Service, including posts in the Community Hub, comments, and feedback.
• Communications: If you contact us directly, we may receive additional information about you, such as the contents of your message.

2.2. Information We Collect Automatically

• Usage Data: We collect information about your interactions with the Service, including the courses you access, lessons completed, quiz results, time spent on the App, and navigation patterns.
• Device Information: We collect information about the device you use to access the Service, including device type, operating system, unique device identifiers, and mobile network information.
• Advertising Identifiers: On the free tier, we and our advertising partners may collect device advertising identifiers (such as Apple's IDFA or Google's Advertising ID), IP address, and coarse, IP-based location, for the purposes described in Section 4.
• Log Data: Our servers automatically record information created by your use of the Service, such as IP address, browser type, referring/exit pages, and timestamps.

2.3. Information from Third Parties

We may receive information about you from third-party services if you choose to connect your account with such services (e.g., social media platforms for authentication). If you purchase a Premium subscription, Apple or Google will share with us limited transaction information (such as purchase confirmation, subscription status, and renewal dates) needed to provide you the subscription; we do not receive your full payment card number or billing address from Apple or Google.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service
• Personalize your learning experience and provide tailored content recommendations, including through Google's Gemini API
• Process and track your progress through courses and learning paths
• Generate certificates upon course completion
• Provide, manage, and validate your Premium subscription and entitlements
• Select and measure the advertising shown to you on the free tier, as described in Section 4
• Communicate with you about the Service, including updates, security alerts, and support messages
• Analyze usage patterns to improve our content and features
• Detect, prevent, and address technical issues and fraudulent activity
• Comply with legal obligations and enforce our Terms of Service

4. Advertising & Analytics

4.1. The free tier of the Service is supported in part by advertising delivered through Google AdMob and/or related Google advertising products. These partners may use advertising identifiers, IP address, coarse location, and app usage signals to select, deliver, measure, and limit the frequency of ads, and to prevent fraud.

4.2. Depending on your device settings, region, and applicable law, ads may be personalized based on this information or based on general context (non-personalized). You can learn more about, and manage, Google's use of data for advertising at adssettings.google.com and Google's own privacy policy. You can also limit ad tracking at the device level through Apple's "Allow Tracking" / App Tracking Transparency prompt (iOS) or your Google Account's ad personalization settings (Android).

4.3. If you purchase a Premium subscription, advertising is turned off within the Service for the duration of your active subscription.

4.4. We may also use privacy-preserving analytics tools, including Google Firebase, to understand aggregate usage of the Service and to diagnose technical issues.

5. Cookies & Tracking Technologies

5.1. Our website and web app use cookies, local storage, and comparable technologies to keep you signed in, remember your preferences, and understand aggregate usage of the site. Our mobile apps use comparable device-level storage and SDK identifiers for the same purposes, as well as for the advertising purposes described in Section 4.

5.2. Most browsers let you block or delete cookies through their settings; doing so may affect the functionality of the website. Where required by law, we will present a cookie or tracking consent notice before non-essential cookies are set.

6. Information Sharing and Disclosure

We do not sell your personal information for money. We may share your information in the following circumstances:

• With Your Consent: We may share your information when you give us explicit permission to do so.
• Service Providers: We share information with third-party service providers who perform services on our behalf, including cloud hosting and analytics (e.g., Google Firebase), AI processing of your lesson interactions to generate personalized content (Google's Gemini API), and customer support. These providers are contractually obligated to protect your information and to use it only to provide services to us.
• Advertising Partners: As described in Section 4, we share device and usage identifiers with advertising partners such as Google AdMob so that they can deliver and measure ads on the free tier. Certain laws, including the California Consumer Privacy Act as amended ("CCPA/CPRA"), define this kind of sharing as a "sale" or "share" of personal information even though no money changes hands. See Section 8 for how to opt out.
• App Stores / Payment Processing: Apple and Google process Premium subscription payments as described in Section 6 of our Terms of Service, and handle the payment information you provide to them under their own privacy policies.
• Legal Requirements: We may disclose information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
• Business Transfers: If we are involved in a merger, acquisition, financing, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
• Community Features: Information you share through the Community Hub may be visible to other users of the Service. Please exercise caution when sharing personal information in public forums.

7. Data Retention

We retain your information for as long as your account is active or as needed to provide you with the Service. We may also retain and use your information to comply with legal obligations, resolve disputes, and enforce our agreements. When you delete your account, we will delete or anonymize your personal information, except where we are required to retain it by law, as described further on our Delete Account page.

8. Your Privacy Rights and Choices

8.1. General

• Access and Update: You can access and update your account information through the App's settings.
• Delete Your Account: You may delete your account at any time through the App settings or by contacting us at cognein@outlook.com. See our Delete Account page for details, including how deletion interacts with an active subscription.
• Marketing Communications: You can opt out of receiving promotional emails from us by following the unsubscribe instructions in those emails or by adjusting your notification preferences in the App.
• Advertising Opt-Outs: See Section 4 for how to limit ad personalization at the device and Google-account level, or purchase Premium to remove advertising entirely.

8.2. California Privacy Rights

If you are a California resident, the CCPA/CPRA gives you the right to: know what personal information we have collected about you; delete personal information we hold about you, subject to certain exceptions; correct inaccurate personal information; and opt out of the "sale" or "sharing" of your personal information, which, as described in Section 6, includes the advertising-identifier sharing used to serve ads through Google AdMob. To exercise these rights, email us at cognein@outlook.com with the subject line "California Privacy Request," or opt out of ad personalization using the device-level and Google Account controls described in Section 4, or by using an opted-in Global Privacy Control signal in a supported browser, which we honor as an opt-out-of-sale/sharing request. We will not discriminate against you for exercising these rights.

8.3. Other U.S. State Privacy Laws

If you reside in a state with a comparable privacy law (such as Virginia, Colorado, Connecticut, Utah, or others as they take effect), you may have similar rights to access, delete, correct, or port your personal information, and to opt out of targeted advertising. You can exercise these rights using the same contact method described in Section 8.2.

8.4. EU/UK/EEA Users

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process your personal information on the legal bases of performance of a contract (providing the Service), our legitimate interests (such as improving and securing the Service), your consent (such as for advertising, where required), and compliance with legal obligations. You have the right to access, rectify, erase, restrict, or object to our processing of your information, and to data portability, by contacting us at cognein@outlook.com. You also have the right to lodge a complaint with your local data protection supervisory authority.

9. Children's Privacy

The Service is intended for users who are at least 13 years of age. We do not knowingly collect personal information from children under 13. Where we have actual knowledge that a user is under 13, we do not serve that user personalized advertising, we limit data collection to what is necessary to operate the Service, and we take steps to delete such information as soon as possible. If you believe we have collected information from a child under 13, please contact us at cognein@outlook.com and we will investigate and, where appropriate, delete the information.

10. Security

We implement reasonable technical and organizational security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will notify you and the relevant supervisory or regulatory authorities as and when required by applicable law, without undue delay and within any timeframe that law prescribes. Notice to you will be sent to the email address associated with your account or provided by other means permitted by law.

11. International Data Transfers

We and our service providers, including Google, operate infrastructure in the United States and other countries. If you access the Service from outside the United States, your information may be transferred to, stored, and processed in a country with different data protection laws than your own. Where required by law, we rely on appropriate safeguards, such as standard contractual clauses, for these transfers.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated Policy in the App and updating the "Last Updated" date, and, where the change is material and relates to a new use of your personal information, we will provide additional prominent notice or seek consent where required by law. Your continued use of the Service after such changes constitutes your acceptance of the updated Policy.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Entity: Cognein LLC, a South Carolina limited liability company
App Name: Cognein
Support Email: cognein@outlook.com
Address: Spartanburg, South Carolina, United States