Privacy Policy

This Privacy Policy explains what personal information we collect about you, why we collect it, who we give it to, how long we keep it, and the choices and rights you have. It applies to our website, our learning platform, our training programs, and our marketing and enrollment activities.

It does not apply to a third-party service you reach through a link from us, or to a tool a Program asks you to use that you sign up for in your own name. Those services have their own privacy policies and we do not control them.

The Platform is directed to users in the United States and this Policy is written to United States federal and state privacy law. Section 21 explains what this means if you are outside the United States.

Where a term is defined in our Terms of Service, it has the same meaning here.

GENIUS CUBE INC., a Delaware corporation doing business as StudyCube, is the business responsible for the personal information described in this Policy. Under state privacy laws we are the “business” (California) or “controller” (other states) for that information.

You can reach us about privacy at:

Two ways to submit a privacy request are set out in Section 12, as California law requires.

This Section is our notice at collection. It sets out, by category, the personal information we collect, why we collect it, and how long we keep it. Fuller detail on each point follows in Sections 4 to 10.

We disclose these categories to the recipients listed in Section 8. We share certain of them for targeted advertising as described in Section 9. We do not sell personal information.

We do not use personal information for a purpose that is not listed here without telling you first and, where the law requires it, obtaining your consent.

Information you give us. You provide personal information when you:

• register for an account or an event, or submit an enquiry or application form;
• enroll in a Program and pay for it;
• complete a profile, submit assignments and assessments, or post in a cohort community;
• contact our team by email, telephone or chat; or
• give us feedback, a review, or a testimonial.

Information collected automatically. When you use the Platform we collect:

• device and browser information, and the pages and features you use;
• an approximate location derived from your IP address — not precise geolocation;
• session participation data for live sessions you join — whether you joined, and when you joined and left; and
• cookie and similar identifiers, as described in Section 14.

Information from others. We receive personal information from:

• our payment processor, which confirms a payment and gives us the last four digits and expiry of your card, but not the full number;
• advertising and analytics providers, which tell us how our campaigns performed and may give us an approximate audience segment;
• an employer or sponsor, where they enroll you or pay for your seat; and
• a person who refers you to us, who gives us your name and contact details.

Where someone refers you or enrolls you, we rely on them to have the right to give us your details. You can ask us to stop contacting you at any time — see Section 15.

Being clear about what we do not collect is as useful as listing what we do. The following statements are commitments, not descriptions of current practice that might quietly change.

We do not collect:

• (a)Government-issued identification. No passport, driver’s license, Social Security number, visa or immigration document.
• (b)Gender or nationality. We removed both from our signup forms because neither serves a purpose we could identify.
• (c)Racial or ethnic origin, religious belief, health information, sexual orientation, union membership, or philosophical belief.
• (d)Biometric identifiers or biometric information. No facial geometry, voiceprints, fingerprints or keystroke biometrics, and no remote proctoring technology of any kind.
• (e)Precise geolocation.
• (f)Recordings of you. We do not record learner camera, microphone or screen during a session, and we do not record telephone calls.
• (g)The contents of your private communications with anyone other than us.

It follows that we do not collect sensitive personal information as California defines it, or the equivalent category under other state laws. Because we collect none, the California right to limit the use of sensitive personal information has nothing to operate on. We will tell you before that changes.

We do not knowingly collect personal information from children under 13. See Section 19.

We obtain personal information from four sources: directly from you; automatically from your device when you use the Platform; from service providers acting for us, including our payment processor and our analytics and advertising providers; and from a person or organization that refers or enrolls you.

We do not buy personal information from data brokers, and we do not build profiles of people who have never contacted us.

We use personal information only for the following purposes:

• (a)to create and administer your account;
• (b)to process your enrollment, take payment, issue receipts and handle refunds;
• (c)to deliver a Program, including scheduling, materials, assessment and support;
• (d)to record session participation, and to identify learners who may need support;
• (e)to respond to your enquiries and provide customer support;
• (f)to send service communications about your enrollment, billing and security;
• (g)to send marketing communications where you have not opted out, and text messages only where you have separately consented;
• (h)to measure and improve the Platform, our Programs and our marketing;
• (i)to show relevant advertising, including through the sharing described in Section 9;
• (j)to detect, investigate and prevent fraud, abuse and security incidents;
• (k)to comply with law and to establish, exercise or defend legal claims; and
• (l)for any other purpose we describe to you at the time we collect the information.

This list is closed. We do not use your personal information, your Program work, your image or your name for marketing or promotion beyond the purposes above. If we want to feature your work or your story, we will ask you separately and you are free to say no.

We do not use learner work to train artificial intelligence models. See Section 17.

We disclose personal information to:

• (a)Service providers that act for us under contract — hosting, video conferencing, payment processing, email delivery, customer support, analytics and security. They may use the information only to provide the service to us.
• (b)Trainers and guest speakers delivering your Program, who see your name, your Platform username, the work you submit for assessment, and questions you ask. They are contractually restricted to using it to teach, assess and support you.
• (c)Other learners in your cohort, who see your name, your profile and anything you post to the cohort community. Consider what you post accordingly.
• (d)An employer or sponsor that paid for your seat, which receives confirmation of enrollment and completion — but not the content of your work or your communications with us.
• (e)Anyone you give the identifier of your Certificate of Completion to, who receives confirmation that the Certificate is genuine and which Program it relates to — nothing further. We do not publish a list of the learners we have issued Certificates to, and we operate no directory in which your name can be looked up.
• (f)Advertising and analytics partners, as described in Section 9.
• (g)Professional advisers — lawyers, accountants and auditors — under a duty of confidence.
• (h)Law enforcement, regulators and courts, where we are legally required to, or where we believe in good faith it is necessary to protect our rights, your safety or the safety of others.
• (i)An acquirer, in connection with a merger, acquisition, financing or sale of assets. The privacy policy in force when the information was collected continues to govern it unless we tell you otherwise and give you a choice.

We do not disclose personal information to anyone else without telling you.

We do not disclose the personal information of a learner aged 13 to 17 to a third party for that third party’s own purposes, including advertising, without separate verifiable parental consent.

In plain terms: when you visit our site, advertising and analytics cookies may pass identifiers such as a cookie ID, device identifier or hashed email address to partners including advertising platforms, so that we can measure our campaigns and show our ads to people who have shown interest in a Program. No money changes hands, but state law regulates this as sharing and gives you a right to stop it.

The categories shared for this purpose are identifiers, internet and network activity, approximate location, and inferences. We do not share your Program work, your assessments or the content of your communications with us.

Three ways to opt out. Any one of them is enough:

• use the “Do Not Sell or Share My Personal Information” page on studycube.ai, linked from this Privacy Policy;
• set your preferences in our cookie banner or preference center, where you can refuse advertising cookies outright; or
• turn on Global Privacy Control in your browser, which we honour automatically — see Section 13.

An opt-out applies to the browser and device you use to make it. If you clear your cookies, use a different browser, or use a different device, please set it again. Where you are signed in to an account, we also apply your opt-out to that account.

We do not sell or share the personal information of anyone we know to be under 16 years of age.

We keep personal information only as long as we need it for the purpose we collected it for, or as long as the law requires. The periods below are our standard periods.

Where a period is expressed as “account life, then n years”, the clock starts when your account is closed.

We may keep information longer where it is subject to a legal hold, an ongoing dispute, a regulatory investigation, or an unresolved payment or fraud matter. When a period ends, we delete the information or de-identify it so that it can no longer reasonably be linked to you. De-identified information is not re-identified.

Backups are overwritten on a rolling cycle, so a record you ask us to delete may persist in a backup for a short period after deletion from our live systems. It is not restored into use.

Depending on where you live, you have some or all of the rights below. We extend the core rights — access, correction, deletion, portability, and opting out of targeted advertising — to every user in the United States, regardless of whether your state has passed a privacy law, because operating one standard is simpler and fairer than operating twenty.

State privacy laws currently give residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Nebraska, New Hampshire, New Jersey, Iowa, Indiana, Tennessee, Minnesota, Maryland, Kentucky and Rhode Island a statutory right to enforce these. Other states join this list as their laws take effect.

We will not discriminate against you for exercising a right. We will not refuse you a Program, charge you a different price, provide a different standard of service, or suggest that we might.

California residents may also ask, once a year, what personal information we disclosed to third parties for their own direct-marketing purposes under California Civil Code § 1798.83 (the “Shine the Light” law). We do not disclose personal information for that purpose, so the answer is none.

Two ways to submit a request. You may:

• email admin@studycube.ai with “Privacy Request” in the subject line; or
• use the privacy request form at studycube.ai/privacy-request.

Tell us which right you are exercising and give us enough information to find your records — ordinarily the email address on your account. You do not need to hold an account to make a request.

We verify requests before acting on them, because acting on a fraudulent request would itself be a breach of your privacy. Ordinarily we verify by confirming control of the email address on the account, and for a request to know specific pieces of information we may ask for one further matching data point. We use information given for verification only to verify, and delete it afterwards.

Authorized agents. You may use an agent. We ask for written authorization signed by you, or a valid power of attorney, and we may still contact you directly to confirm. An agent using Global Privacy Control on your behalf does not need to provide this.

Our timing. We acknowledge a request within 10 business days and respond within 45 calendar days. Where a request is complex we may take a further 45 days and will tell you why before the first period ends. Opt-out requests are actioned within 15 business days. There is no charge unless a request is manifestly unfounded or excessive, in which case we will tell you before doing anything.

If we refuse, you may appeal. Reply to our decision, or write to us at admin@studycube.ai with “Privacy Appeal” in the subject line, within 60 days. A different person reviews the appeal and we respond in writing within 45 days with our reasons. If we refuse the appeal we will tell you how to complain to your state Attorney General.

Some requests we must refuse in part — for example, we cannot delete an enrollment or payment record we are required to keep for tax purposes. Where that happens we will tell you which records we kept and why, and delete everything else.

Global Privacy Control (GPC). GPC is a signal your browser or a browser extension can send to tell every site you visit that you opt out of the sale and sharing of your personal information. We detect and honour GPC. When we receive it we treat it as a valid opt-out for that browser immediately, without asking you to do anything else, and we do not ask you to reconsider.

If you are signed in when we receive a GPC signal, we also apply the opt-out to your account so that it follows you across devices.

Do Not Track (DNT) is a different and older signal. No common industry standard for responding to DNT was ever settled, and we do not respond to DNT signals. This statement concerns DNT only and does not qualify anything said above about GPC, which we do honour.

We use cookies and local storage to keep you signed in, remember your display preference, and measure how the Platform is used.

Section 15 of our Terms of Service is the detailed statement. It lists every cookie and similar technology we use, with its provider, purpose, type and duration. We do not publish a separate cookie policy; read the two documents together.

Strictly necessary technologies are required to operate the Platform and cannot be switched off. Our analytics cookies are set when the page loads, and we do not ask you to opt in first. We do not currently set any advertising cookie.

Your browser lets you block or delete cookies and clear local storage at any time, and Google publishes an add-on that stops Google Analytics collecting data about your visits. Blocking strictly necessary technologies will stop parts of the Platform working.

Marketing email. Unsubscribe using the link in any marketing message, or email us at admin@studycube.ai. We action it within 10 business days.

Service messages are different. Notices about your enrollment, schedule, billing, security and changes to our terms are part of the service and continue while you hold an account or an enrollment. Unsubscribing from marketing does not stop them.

Text messages. We send SMS only where you have given prior express written consent to that channel, collected separately from your acceptance of our Terms. Consent to receive text messages is never a condition of enrollment or of any purchase. Reply STOP to any message to stop, or HELP for help. Message and data rates may apply. We do not share your mobile number or your text-messaging consent with third parties for their own marketing purposes.

Telephone calls. Our team may call you about an enquiry or an enrollment. We do not record these calls. Ask us to stop calling and we will, and we will add you to our internal do-not-call list.

We honour the federal and state do-not-call registries and maintain our own.

We do not record learners. We do not capture your camera, microphone or screen during a session. Where a recording of a session is made available to a cohort, it captures the trainer’s presentation and shared materials.

We do not use proctoring, identity-verification or attention-tracking technology, and we do not collect biometric identifiers of any kind.

Assessment records are disclosed to your trainer, and to an employer or sponsor that paid for your seat, as described in Section 8. We do not sell or share them for advertising.

We are not an educational institution that receives United States Department of Education funding, so the Family Educational Rights and Privacy Act does not apply to us. We nonetheless treat your Program records as confidential.

If we ever propose to change any of the commitments in this Section, we will tell you before the change takes effect, obtain your consent where the law requires it, and not apply the change to sessions already delivered.

Some Platform features are built on artificial intelligence systems operated by us or by third-party providers. Where you interact with such a feature, you are told at the point of interaction that you are interacting with an artificial intelligence system.

Where an AI feature processes your input in order to return a response to you, the provider processes that input as our service provider, is contractually restricted to that purpose, and may not retain the input for its own purposes.

We do not use artificial intelligence to make a decision that produces a legal or similarly significant effect about you, and we do not use it to decide admission to a Program or the price you are charged.

Do not enter personal information about another person, or confidential information belonging to an employer or client, into an AI feature.

Where we offer a reward for referring another person to a Program — a discount, a credit or a payment — California law treats it as a financial incentive, because you receive something of value in connection with the collection of personal information. This Section is the notice that law requires.

Material terms.

• What we collect: your name and account identifier, and the name and contact details of the person you refer.
• What you receive: the reward stated in the referral offer at the time you take part.
• How to take part: by using the referral link or form we provide.
• How to withdraw: email us at admin@studycube.ai at any time. Withdrawing does not affect a reward already earned.

Our good-faith estimate of value. We calculate the value of the personal information involved by reference to the cost of the reward we pay, since that is what we are willing to pay to obtain it. We estimate the value of the personal information involved in a referral as no greater than the value of the reward offered for it. We do not assign a higher value to the personal information of any individual.

Participation is voluntary and the incentive is reasonably related to that value. Declining to refer anyone has no effect on your Program, your price, or the service you receive.

Before you refer someone, please make sure they are happy to hear from us. We will contact them once and stop if they ask us to.

This is an unconditional statement. It is not qualified by “where prohibited by applicable law” or any similar wording.

A person aged 13 to 17 may use the Platform only where a parent or legal guardian has given verifiable consent and accepted our Terms of Service on their behalf. We do not disclose the personal information of a user aged 13 to 17 to a third party for that third party’s own purposes, including advertising or AI development, without separate verifiable parental consent.

We do not sell or share for targeted advertising the personal information of any user we know to be under 16.

A parent or guardian may contact us at admin@studycube.ai to review, correct or delete their child’s personal information, or to withdraw consent and stop further collection. We will act on it and confirm when it is done.

We maintain administrative, technical and physical safeguards, including:

• (a)encryption of personal information in transit and at rest;
• (b)access control on a least-privilege basis, with individually named accounts and multi-factor authentication for administrative access;
• (c)written confidentiality and data-protection obligations in every contract with a trainer, contractor and service provider;
• (d)logging of access to learner records, retained for 12 months;
• (e)segregation of payment-card data, which is handled by a PCI-DSS compliant processor and never stored on our systems; and
• (f)an internal incident-response procedure with defined escalation and notification steps.

No system is perfectly secure. We cannot guarantee that personal information will never be accessed without authorization, and we do not ask you to rely on such a guarantee. You help by using a strong, unique password and not sharing your credentials.

If a breach affects your personal information, we will notify you and the relevant authorities as required by the breach-notification law of your state, without unreasonable delay.

The Platform is directed to users in the United States, and our systems and our service providers are located in the United States. If you use the Platform from outside the United States, your personal information will be transferred to, stored in and processed in the United States, where privacy law differs from the law where you live.

By using the Platform from outside the United States you understand that this transfer takes place. Where we transfer personal information from a jurisdiction that restricts such transfers, we rely on an appropriate transfer mechanism, including standard contractual clauses with the recipient, and we will tell you which one on request.

We do not target the Platform at, or market it in, the European Economic Area or the United Kingdom. Nothing in this Policy is intended to hold out compliance with the EU or UK General Data Protection Regulation, and we make no such claim. Where the law of your country nonetheless gives you rights over your personal information, contact us and we will deal with your request in good faith.

We may update this Policy. When we do, we change the “last updated” date at the top and post the new version here.

Where a change is material — a new purpose, a new category of recipient, a longer retention period, or any change to the commitments in Sections 5, 16 or 17 — we will notify you by email or through the Platform before it takes effect, and obtain your consent where the law requires it.

We do not apply a material change retroactively to personal information already collected without giving you the choice described above.

We keep previous versions of this Policy and will provide one on request.