Privacy Policy

Last updated October 7, 2025

Cohorts Inc. ("We" or "Us") want you to understand how we handle your data. We also want you to know your rights and choices. This policy describes how we handle your data when you use the Cohorts Application (the "Application").

What information do we gather about you?

The following describes the information we collect and how we obtain it.

A) Information collected through the Application

1. Information you voluntarily give us

For registration: When you sign up for access and to download and use the Application you must first register as instructed by us when you first download and open the Application. We collect your contact information. Once you've registered with your email address and phone number, you will be asked to create a password that only you know. This unique information helps us recognize you when you're signed in.

We might ask for information such as your name, telephone number, email address, and your location-tracking settings to match you with other users in your school, chosen location or geographic area, and any other relevant information ("Personal Identifiers").

For the Application experience and programs: We gather information through random feedback surveys that pop up in the Application, and when you click "Report a problem / submit feedback" at the bottom of the settings page. We ask for your consent to use this information when you participate in these programs and events. This can include your age, gender, geographic area/location, demographic or academic preferences, and any information about your goals or interests.

2. Information collected automatically

With tracking technologies in your mobile apps: We track and store data about how you use the Application, including your general location, device identifiers, advertising identifiers and other usage information. We combine this data with other information we collect about you.

With GPS technologies: You choose whether to enable GPS features when you first install the app, and you can edit that setting on your device at any time. If you enable these features, your GPS location can be determined by satellite, cell phone tower or Wi-Fi and used by the app. If you save a location-based search in your history, that data is stored on our service provider's servers.

B) Information collected from other sources

Social media platforms and other third-party services: You can choose to share the Cohorts Application to your social media accounts or other third-party sites, and share a link to the Application with your friends through text message (any costs associated with doing so are covered in full by you, the user).

We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., discussions, mentorship chats and interactions, event links, activity logs, program comparisons, journals), awareness data, and users' profiles or bios.

A note about future updates

We plan to improve our Application and we may create new features. These updates sometimes require us to collect new information, or use what we already have differently. If there is a significant or material change in the way we handle your personal information, we will notify you as detailed below.

Why is this data being collected?

The data is collected so the Application can be effective and to improve and personalize your experience by facilitating AI smart matching and mentorship matching, and to allow us to apply for and receive funding in order to sustain and improve the Application.

Personalized advertising and audiences for third-party advertisers

We gather data and work with third parties — including those who host, sponsor or run networking events — to show you personalized ads on behalf of advertisers. This data comes from ad-tracking technologies set by us or a third party (e.g., cookies), information you provide (e.g., your email address), your use of the Cohorts Application, information from advertisers or advertising vendors (e.g., demographic data), and anything inferred from this information. We only use or share this information in a manner that does not reveal your identity — all personal identifiers will be stripped and your data will be fully anonymized prior to disclosure.

We also identify groups of users to whom we show personalized ads on behalf of our advertisers. To do this, we combine information collected through surveys with information collected automatically using tracking technologies. This combined information is used to build models that help us measure users' attributes. Working with service providers, we use these measurements to group users by common interests; each group is associated with a random ID which is then passed to our ad server for use in targeting ad campaigns.

• We try to limit how our third-party advertising technology vendors use the information they gather from you. Many of these providers require us to enter into contracts that allow them to optimize their own services and products, or that help them create their own.
• These providers may combine information they gather about you through the Cohorts Application with information they receive from their other clients.

We aggregate (or de-identify) personal information into larger findings

Sometimes we aggregate or de-identify information so that it can no longer identify you, under applicable laws. This helps us better understand and represent our users for the Application programs or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.

With whom do we share the information we gather?

With service providers: We work with service providers to carry out tasks such as:

• Maintaining technology and related infrastructure
• Offering customer service
• Serving and targeting relevant ads
• Presenting surveys
• Distributing emails
• Analytics
• We sometimes allow third parties to use aggregated or de-identified information for other purposes, in accordance with applicable laws.

We may preserve or share personal information if we believe it is necessary or the law requires us to comply with the law or with legal process.

What are your rights?

A) How do I opt out of email, phone and push notifications?

The opt-out methods described below are limited to the email address, phone or device used.

1. Email: support@cohorts.me
2. Telephone promotions: You can ask us to unsubscribe from our telephone contacts, and to not share your information with third parties for marketing purposes. Use the button below to send us an opt-out request — it will open a pre-filled email to support@cohorts.me with "Opt Out" in the subject line.
   Send opt-out request
3. Push notifications: You can opt out at any time by adjusting your device settings, or by uninstalling the app.
4. Text messages: You can opt out of text alerts at any time by replying "STOP," or any alternative keyword we've shared with you.

We complete any opt-out request as quickly as we can. Opting out won't prohibit us from sending you important non-marketing notices.

How do you access, change, delete, update or exercise your other rights?

In some parts of the world, you have the right to:

• Access, modify, or delete the personal information we have about you
• Receive an electronic copy of the personal information we have about you, for data portability
• Restrict, or object to, how we process personal information about you

You have the right to object to the processing of your personal information based on our legitimate interest or that of a third party — unless we demonstrate compelling legitimate grounds for the processing of, or the keeping of, your personal information for the establishment, exercise or defense of legal claims.

If you'd like to exercise any of the above rights, contact us. In your request, please be specific: state the information you want changed, whether you'd like your information suppressed from our database, or whether there are limitations you'd like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the address you provide us and wait for your response. In some instances we may also ask for additional information.

We'll respond to your request in a manner consistent with applicable law.

How long do we retain data?

It depends. We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.

When deciding how long to keep your information, we consider:

• How long we have had a relationship with you;
• Whether we are subject to any legal obligations (e.g., laws that require us to keep transaction records for a certain period before deletion);
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).

Rather than delete your data, we might de-identify it by removing identifying details.

How do we protect your information?

We protect your personal information with a series of organizational, technological and physical safeguards. We use AWS to help safeguard your data; AWS services are designed to securely encrypt all data.

Data on servers is managed and segregated by AWS and Firebase, but we cannot guarantee its absolute security.

We recommend that you use complex and unique passwords for your accounts, and do not share your password with anyone. If you have reason to believe your interaction with us is no longer secure, notify us immediately.

What is our legal basis?

In some jurisdictions like Canada and the EU, we only collect, use or share information about you when we have a valid reason. This is called "lawful basis." Our lawful basis includes one or more of the following:

• The clear and informed consent you provide to us at the point of collection of your information;
• Compliance with a legal obligation to which we are subject; or
• "Legitimate interest" — a technical term under international laws including the Personal Information Protection and Electronic Documents Act (PIPEDA) and the European Union General Data Protection Regulation (GDPR). It means there are good reasons for processing your personal information and that we take measures to minimize the impact on your privacy rights and interests. It also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.

We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer the Application programs; and (3) to conduct our marketing activities, provided all of your personal identifiers are removed.

What about links to third-party services?

The Cohorts Application contains links to third-party websites, mental health and other resources, vendors and advertisers not affiliated with us. We do not control (and are not responsible for) third-party content or privacy practices. Any personal data you decide to provide to them is not covered by this Privacy Policy.

How are changes to this Privacy Policy communicated?

We periodically update this Privacy Policy and will post any changes on this page.

If we make a significant or material change in the way we collect, use or share your personal information, we will notify you at least 30 days prior to the changes taking effect, via email or prominent notice within the Cohorts Application. If you object to any change, you can stop using the Cohorts Application. Otherwise, you are responsible for periodically reviewing this policy for any changes we do not deem to be substantive or material.

After we post any changes on this page, your continued use of the Cohorts Application is subject to the updated Privacy Policy.

How can you contact us?

If you have any questions, email us at support@cohorts.me.