COSMO PRIVACY POLICY
Effective Date: June 8, 2026
ALGORITHM OF LEARNING INC.(operating under the brand name Cosmo, hereinafter referred to as “Company”, “us”, “we” or “our”), is a leading education technology company. This Policy applies to the following products and services operated by Company: websites, mobile applications, and all other products, services, websites and/or applications which reference this Policy in a link or otherwise, (collectively referred to as “Services”). Before you (hereinafter referred to as "User" or “you”) use the Services provided by the Company, you shall carefully read, fully understand and choose whether to accept the provisions of the Terms and Conditions (hereinafter referred to as "T&C") and the Privacy Policy (hereinafter referred to as "Policy"). Minors shall be accompanied by their legal guardians to read it.If you are a parent or legal guardian permitting a minor to use our Services, you are responsible for providing consent on the minor's behalf as described in Section 13 (Children's Privacy).
In connection with our Services, some of the information you provide may be personal information (hereinafter referred to as “Personal Information”). Also, some information we collect may be non-personal information (hereinafter referred to as “Non-Personal Information”). You are responsible for ensuring the accuracy of the Information you provide to us. Inaccurate information may affect your use of the Services.
This Policy applies to all Personal Information and Non-Personal Information (collectively referred to as “Information”) that you provide to us, or that we may collect about you. Please do not provide any such information to us if you do not accept this Policy. Should you notify us that you do not accept this Policy, please note that we may only be able to provide you with limited access to the Services.
1. INFORMATION WE COLLECT
The Company records the following information you provide when you download and register for the Services:
(1) Basic information: nickname, phone number, email address;
(2) Device basic information such as mobile phone model, system version, device number, screen height & width, device language, mobile phone system time zone;
(3) Application usage data (browsing and click records, software usage records, etc.);
(4) Network status;
(5) Live classes sound and video data.
2. USE OF YOUR PERSONAL INFORMATION
In accordance with applicable local laws, the Personal Information we collect is used to (1) help you become our user; (2) in order to make the User’s experience smoother when taking live courses; (3) to provide the products or services, such as customer support services.
Contacting you
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The Company may use the Personal Information to contact you from time to time, to provide you with the Services, important information, required notices and marketing promotions. The Company may contact you when it needs additional information that personally identifies you or allows us to contact you. Mobile numbers will not be shared or sold to third parties for marketing/promotional purposes.
Sending you transactional communications
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The Company will occasionally send email notices or contact you to communicate about its Services, products and benefits, as they are considered an essential part of the Services you have chosen.
As required by law
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We may access, preserve, and disclose your Personal Information or other account information if we believe doing so is required or appropriate to (1) comply with law enforcement requests and legal process, such as a court order or subpoena; (2) respond to your requests; (3) protect your, our or others’ rights, property, or safety; or (4) as otherwise required by law.
Sharing with Affiliates
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The Information will be stored in the Company’s database, which is only accessible through a Virtual Private Network (VPN) or similar secure methods, with access restricted to authorized personnel only. Following termination or deactivation of your account, the Application, its affiliated companies, or its service providers may retain information associated with your profile for a commercially reasonable period of time for backup, archival, audit, or other business purposes permitted by laws.
3. ACCESS TO YOUR PERSONAL INFORMATION
The Company will provide you with the means to ensure that the Personal Information is correct and current. If you have filled out a user profile, it will provide an obvious way for you to access and change your profile from the Services. The Company adopts stringent security measures to protect your password from being exposed or disclosed to anyone. Only upon you forgetting the password for the Services, the Company will have a right to reset it for you with your prior approval as per standard web practices.
4. STORAGE AND TRANSFER OF THE PERSONAL INFORMATION
This Policy only applies to residents of the United States. Please note as well that when you use the Services, the Personal Information may be accessed or transferred outside of the United States. Such countries may have data protection laws that are different in some respects than the laws of the U.S. For these transfers, we rely on appropriate safeguards as permitted under applicable law and standards. If you do not want your information transferred to, processed, accessed, or maintained outside of the United States, you should immediately stop accessing or using the Services.
5. UPDATING OR DELETING THE REGISTRATION INFORMATION
As part of the requirements for your use of the Service, you are responsible for updating your submitted registration information so that it is current, complete and accurate. You can update this information by logging into your account and accessing your account settings. If you would like to remove some of the Personal Information you have posted on the Services, such as information you posted in profiles, you may do so by editing or deleting that item. To request removal of other Personal Information you have voluntarily posted, such as information you may have posted in online group forums, you can contact us. We strive to accommodate your request, though we cannot guarantee that the information can be successfully removed in all cases.
6. COOKIES
The Company sends cookies (small files containing a string of characters) to your computer, thereby uniquely identifying your browser. Cookies are used to track your preferences, help you log in faster, and are aggregated to determine user trends. This data is used to improve its offerings, such as providing more content in areas of greater interest to a majority of users. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some of the Company features and services may not function properly if your cookies are disabled.
7. LINKS
The Company may present links in a format that enables us to keep track of whether these links have been followed. The Company uses this information to improve its customized content. Clicking on links may take you to sites outside its domain. The Company is not responsible for the privacy practices of other web sites. The Company encourages its users to be aware when they leave its site to read this Policy / T&C of each and every web site that collects personally identifiable information.
8. ALERTS
The Company may alert you by email or phone to inform you about new service offerings or other information which it perceives might be useful for you.
9. PUBLIC FORUMS
When you use certain features on the Services such as discussion forums, any Personal Information you post or share — including comments, messages, files, or photos — may be visible to all users, and will be in the public domain. All such sharing of information is done at your own risk. Please keep in mind that if you disclose the Personal Information in your profile or post it on the forums, the information may become publicly available.
10. SECURITY
The Company is concerned about safeguarding the confidentiality of Personal Information. The Company provides physical, electronic, and procedural safeguards to protect the Personal Information it processes and maintains. An illustration being, the Company limits access to the Personal Information to authorized employees only who need to know that information in order to operate, develop or improve its Services. Please note that despite the Company’s efforts to provide strong security protections, no security system can prevent all potential security vulnerabilities for the information it possesses and maintains.
11. USER COMMUNICATIONS
When you send an email or other communication to the Company, it may retain those communications in order to process your inquiries, respond to your requests and improve our Services.
12. YOUR CALIFORNIA PRIVACY RIGHTS
California Privacy Rights
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If you are a California resident, you may ask us to refrain from sharing your Personal Information with our affiliates and other third parties for their marketing purposes. To opt-out of the disclosure of Personal Information about you for monetary or other valuable consideration, please contact us.
Your California Privacy Rights
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If you are a California resident, you have the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.
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Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in the provision. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
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Right to Know. You have the right to request in writing a list of the information we have collected or disclosed about you, the business purposes involved, and the sources of such information. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
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Right to Deletion. You have the right to request that we delete personal information about you that we have collected from you.
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Right to Opt-Out. You have the right to opt out of the disclosure of personal information about you for monetary or other valuable consideration. To opt-out, please contact us.
13. CHILDREN’S PRIVACY
We do not knowingly collect the Personal Information through the Services from persons under the age of 13. If you believe anyone under age 13 has provided Personal Information to us, please contact us as indicated in the "Contact Us" provision of this Policy and we will work to delete it.
14. MODIFICATIONS TO THE POLICY
We may change this Policy from time to time, to reflect how we are processing your Information, and if we make changes, we will notify you by revising the effective date or last modified data at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Services. Your continued access or use of our Services after receiving notice of the changes constitutes your acknowledgement that you accept the updated Policy.
15. YOUR CONSENT
The Company believes that, the User must be in a position to provide an informed consent prior to providing any Information required for the use of the Services. By registering with it, you are expressly consenting to its collection, processing, storing, disclosing and handling of your Information as set forth in this Policy now and as amended by us. Processing your Information in any way, including, but not limited to, collecting, storing, deleting, using, combining, sharing, transferring and disclosing the Information.
16. GOVERNING LAW
This Policy shall be governed by and construed in accordance with the laws of the United States.
17. PRIVACY NOTICE FOR USERS IN MAINLAND CHINA
If you are located in Mainland China, or if our Services are provided to you through our Mainland China entity, please review our separate Privacy Notice for Mainland China Users.
This notice explains how we collect, use, store, share, transfer, publicly disclose, and transfer personal information outside of Mainland China when you use Cosmo products and services in Mainland China. It also describes your rights under applicable Mainland China personal information protection laws.
For details, please refer to our Privacy Notice for Mainland China Users.
18. CONTACT US
If you have questions or concerns regarding any information in this Policy, please contact us via email at support@cosmoai.com.