COOKD AI INC.

PRIVACY POLICY

Effective Date: August 16, 2026

Cookd AI Inc. (the “Company,” “Cook’d AI,” “Cook’d Academy,” “we,” “our,” or “us”) is committed to protecting the privacy and security of the personal information we collect from individuals who access or use our Services, which consist of (a) Cook’d Academy, our AI-enabled career coaching and career-preparation service, including our websites, platforms, bootcamps, tools, content, coaching-related services, and consultation services, and (b) the Networking Assistant, our AI-enabled people-search and professional-networking feature, and other related services. Information provided through the Networking Assistant, including search results and related outputs, is referred to in this Privacy Policy and in our Terms of Service as “Networking Assistant Outputs.”

This Privacy Policy is designed to be transparent, comprehensive, and accessible while maintaining the legal precision necessary to ensure compliance with applicable privacy laws across our operating jurisdictions. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning stated in our Terms of Service.

By accessing or using our Services, you acknowledge and agree to the practices described in this Privacy Policy. If you do not agree with the practices described in this Policy, please do not use our Services.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated Policy on our website and updating the “Effective Date” at the beginning of this document. You are encouraged to review this Policy periodically for any updates, and to use the information it contains to help you make informed decisions.

1. Personal Information We Collect

We may collect the following categories of personal information from individuals who use our Services, including but not limited to:

We may collect this information through various methods:

This product includes GeoLite2 data created by MaxMind.

2. Information About Individuals Appearing in Networking Assistant Outputs

The Networking Assistant may collect, process, organize, enrich, infer, and display personal information about individuals who are not registered users of the Services. This information may include names, professional or educational history, publicly available profile information, contact information, social or web presence, and other information derived from publicly available sources, third-party data providers, user-provided inputs, AI-generated or inferred information, and/or other lawful sources. If you are a registered user and you submit information about other individuals (such as contact lists or outreach context), that information may be processed to provide Networking Assistant Outputs and, depending on the feature, may be included in Networking Assistant Outputs available to other users; you are responsible for ensuring you have the right to provide such information.

An individual’s appearance in a Networking Assistant Output does not mean that the individual uses, endorses, is affiliated with, or has any relationship with Cook’d AI.

Mainland China Exclusion. The Networking Assistant does not index or display personal information of individuals located in mainland China (the People’s Republic of China, excluding Hong Kong, Macau, and Taiwan). If you believe your personal information appears in a Networking Assistant Output in error and you are located in mainland China, please contact us as described in Section 8.2 and we will remove it.

Public availability of information does not mean that such information may be used for all purposes. Users are responsible for using Networking Assistant Outputs solely for their own personal, non-commercial recruiting, networking, and career-development activities and may not redistribute, resell, publish, or use them for eligibility, screening, or any other prohibited purpose, as described in our Terms of Service.

If your personal information appears in a Networking Assistant Output and you are not a registered user, you may request removal, deletion, correction, or opt-out as described in Section 8.2 (Networking Assistant Output Removal and Opt-Out Requests), including opting out of the use of your information for AI model improvement as described in Section 7.

3. How We Use Your Personal Information

We may use the personal information we collect for the following purposes:

4. Cookies and Tracking Technologies

We and our service providers use cookies, pixels, software development kits (SDKs), and similar tracking technologies to automatically collect certain information when you access or use our Services. These technologies help us operate our Services, understand usage patterns, improve performance, enhance user experience, conduct analytics, and support security and fraud prevention. The information collected through these technologies may include IP address, device and browser information, operating system, pages viewed, features used, timestamps, referring URLs, and other usage data. We use third-party analytics providers, including Google Analytics (provided by Google LLC) and Mixpanel (provided by Mixpanel, Inc.), to help us analyze how users interact with our Services. These providers may use cookies or similar technologies to collect information about your use of our Services and may process such information in accordance with their own privacy policies. Where required by applicable law, we obtain your consent before placing non-essential cookies or using similar tracking technologies, and you may manage your cookie preferences through browser settings or other tools made available on the Platform. Cookie Choices. You may control cookies through your browser settings and, where available, through any cookie banner or preference center on our Services. You can also opt out of certain analytics and advertising cookies by using industry opt-out tools (such as the Network Advertising Initiative or the Digital Advertising Alliance), where applicable. We recognize and honor Global Privacy Control (GPC) signals sent by your browser where required by applicable law.

5. Legal Bases for Processing (European Users Only)

For users in the European Economic Area (EEA) and the United Kingdom, we process your personal information based on one or more of the following legal bases:

Controller. For purposes of the GDPR and UK GDPR, the controller of personal information processed as described in this Privacy Policy is Cookd AI Inc., 40 Wall St, 28th Floor, New York, NY 10005, United States, reachable at privacy@cookd.ai.

Processing of Networking Assistant Outputs Personal Information (Non-Users). Where the Networking Assistant processes personal information of individuals in the EEA or the United Kingdom who are not registered users, we rely on our legitimate interests and those of our users in providing lawful professional-networking and career-development functionality, balanced against the interests, rights, and freedoms of the individuals concerned, including through source limitations, use restrictions in our Terms of Service, retention limits, and the removal and opt-out rights described in Sections 7 and 8.2. Because this information is not collected directly from the individuals concerned and individually notifying each such individual would involve disproportionate effort within the meaning of Article 14(5)(b) of the GDPR, we provide the information required by Article 14 through this Privacy Policy.

6. How We Share Your Personal Information

We may share your personal information with the following categories of recipients:

These service providers are contractually obligated to use your personal information only to provide services to us and in accordance with our instructions and this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please contact us using the email in the “Contact Us” section of this Privacy Policy, or by visiting the respective third party’s privacy policy, including but not limited to the following:

Networking Assistant Processing. Inputs submitted to, and outputs generated by, the Networking Assistant may be processed by third-party artificial intelligence, data enrichment, hosting, and other service providers engaged by Cook’d AI. We require these providers to process personal information in accordance with our instructions, contractual obligations, this Privacy Policy, and applicable law.

Authorized Networking Assistant Users. To provide the Networking Assistant, we may make personal information contained in Networking Assistant Outputs available to authorized users, subject to our Terms of Service, usage restrictions, and applicable law. Networking Assistant Outputs are made available solely for users’ own personal, non-commercial recruiting, networking, and career-development activities and may not be redistributed, resold, published, or used for eligibility, screening, or other prohibited purposes.

We do not sell your personal information. We also do not share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws, unless otherwise disclosed to you and you are provided any required opt-out rights. To the extent that making personal information available through the Networking Assistant is treated as a “sale,” “sharing,” data broker activity, or similar regulated disclosure under applicable law, we will provide any disclosures and opt-out, deletion, or related rights required by that law. See Sections 8.2 and 8.3.

7. Use of Personal Information With Artificial Intelligence

We use artificial intelligence and machine learning technologies to help provide, personalize, support, secure, and improve Cook’d Academy, the Networking Assistant, and our Services. These technologies may support AI-enabled learning tools, mock interview tools, resume review tools, application tracking tools, AI Mentor support, feedback generation, coaching-related analysis, content recommendations, people-search, organization and enrichment of Networking Assistant Outputs, outreach-related suggestions and drafts, and other career-preparation, networking, or career-development features.

How AI May Be Used. Depending on the Services you use, we may process personal information, User Content, career-related information, resumes, application materials, interview responses, transcripts, practice activity, search queries, prompts, outreach context, personal information about third parties, or other Service-related information to generate feedback, recommendations, summaries, reports, practice materials, Networking Assistant Outputs, AI-generated outputs, or other Service outputs for you.

Third-Party AI Providers. In providing the Services, we may process personal information using third-party artificial intelligence service providers acting on our behalf and subject to contractual obligations to process such information only in accordance with our instructions, this Privacy Policy, and applicable law.

Model Improvement. We may use personal information and User Content provided by registered users, and information contained in Networking Assistant Outputs (including information about individuals who are not registered users), to maintain, evaluate, secure, develop, and improve our Services, including training, fine-tuning, evaluating, and improving AI models and other technologies, where permitted by applicable law and consistent with this Privacy Policy. Where feasible, we use de-identified, aggregated, or anonymized information for these purposes. Any use of personal information for AI model training, fine-tuning, evaluation, or improvement will be subject to this Privacy Policy, our Terms of Service, applicable law, and any consent requirements that may apply.

Opting Out of Model Improvement. You may opt out of the use of your personal information for AI model training and improvement at any time: registered users may opt out by contacting us at privacy@cookd.ai (or through account settings, where available); individuals who are not registered users and whose information appears in a Networking Assistant Output may opt out through the process described in Section 8.2. When we receive and verify an opt-out, removal, or deletion request, we will exclude the relevant personal information from future model training and improvement. Opting out does not affect processing that has already occurred or model outputs generated before the opt-out took effect, and does not affect uses of de-identified, aggregated, or anonymized information.

Accuracy and Verification. Networking Assistant Outputs may contain information obtained from third-party or public sources or information inferred or generated by AI. We do not independently verify all such information and do not guarantee that it is accurate, complete, current, reliable, lawful for every use, or correctly attributed. Users must independently verify information before relying on or acting upon it. The fact that information is publicly available does not mean that it may lawfully be used for every purpose.

No Automated Employment or Similar Decisions. We do not use AI to make final employment, hiring, admissions, credit, or other legally significant decisions about you. AI-generated outputs are provided for career-preparation, networking, educational, and informational purposes only and should not be treated as a guarantee of any interview, offer, admission, employment, compensation, networking outcome, or career result. See also Section 9 (No Consumer Reporting Use).

Consent for Recordings. Where our Services involve audio or video recording, we will provide notice and obtain consent where required by applicable law. You should not record, upload, or submit any audio, video, or communications involving another person unless you have obtained all consents required by applicable law.

Safeguards. We use safeguards designed to protect personal information processed in connection with AI-enabled Services, including access controls, security measures, data minimization, and de-identification or anonymization where appropriate.

8. Jurisdiction-Specific Privacy Rights

Depending on your location, you may have specific rights regarding your personal information. Below, we outline the rights available to you based on your jurisdiction.

8.1 Rights for All Users. Regardless of your location, you have the right to:

8.2 Networking Assistant Output Removal and Opt-Out Requests (Non-Registered Individuals). If you are an individual whose personal information appears in a Networking Assistant Output, you may request removal, deletion, correction, or opt-out (including opting out of the use of your information for AI model training and improvement, as described in Section 7) by contacting us at privacy@cookd.ai. Please include sufficient information for us to identify the relevant record, such as your name, profile URL, email address, company, or other identifying details. We may request additional information reasonably necessary to verify your identity, locate the relevant record, protect against fraudulent requests, or comply with applicable law. When we complete a verified removal, deletion, or opt-out request, we will also exclude the relevant information from future AI model training and improvement as described in Section 7. Where the information is controlled by a third-party data provider, API, or public source, we may remove or suppress the information from our Services where required or appropriate, and we may direct you to the relevant third-party provider to exercise deletion, correction, or opt-out rights at the source. We may retain limited suppression records where reasonably necessary to honor an opt-out or deletion request and prevent the information from being reintroduced.

8.3 United States Privacy Rights. If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other states with comprehensive privacy laws, you may have the following additional rights:

Sensitive Personal Information. We do not use or disclose sensitive personal information (as defined under applicable U.S. state privacy laws) for purposes other than those permitted by such laws, and we do not use sensitive personal information to infer characteristics about individuals.

Submitting Requests; Verification; Authorized Agents. You may submit requests using the contact information in Section 15. We will verify your identity before fulfilling a request, and we may request additional information for that purpose. Where permitted by applicable law, you may designate an authorized agent to submit a request on your behalf; we may require the agent to provide proof of authorization and may require you to verify your identity directly with us. If we deny a request, you may appeal by replying to our decision, and we will respond as required by applicable law.

California residents may also have the right to request information about our disclosure of personal information to third parties for their direct marketing purposes under California’s “Shine the Light” law.

For a current list of states with comprehensive privacy laws, please see: https://iapp.org/news/a/us-state-comprehensive-privacy-law-comparison/

8.4 European Privacy Rights (GDPR). If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have the following rights under the General Data Protection Regulation (GDPR) and applicable national laws:

8.5 China Privacy Rights (PIPL). If you are located in the People’s Republic of China, you have the following rights under the Personal Information Protection Law (PIPL). As described in Section 2, the Networking Assistant does not index or display personal information of individuals located in mainland China; the rights described in this Section apply to registered users located in the People’s Republic of China with respect to the personal information they provide to us in connection with the Services.

8.6 Hong Kong Privacy Rights (PDPO). If you are located in Hong Kong, you have the following rights under the Personal Data (Privacy) Ordinance:

To exercise your respective data privacy right, please contact the Company at the information in the Contact Us section of this Policy.

9. No Consumer Reporting Use

The Services are not designed or intended to be used as a consumer report, background check, employment screening tool, tenant screening tool, credit eligibility tool, insurance eligibility tool, or for any purpose regulated by the federal Fair Credit Reporting Act (“FCRA”) or comparable laws. Cook’d AI is not a consumer reporting agency, and Networking Assistant Outputs do not constitute “consumer reports” or “investigative consumer reports.” We do not use personal information obtained through the Networking Assistant to determine or verify any individual’s eligibility for employment, promotion, retention, housing, credit, insurance, education, government benefits, licensing, or any other personal right, benefit, or opportunity. Our Terms of Service prohibit users from using the Networking Assistant or its outputs for those purposes.

10. Data Security and Incident Response

Security Measures. We implement comprehensive administrative, technical, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include:

Administrative Safeguards:

Technical Safeguards:

Physical Safeguards:

Data Breach Response. In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will:

Our notification will include, to the extent known: a description of the breach; the types of information involved; steps we are taking to protect your information; measures you can take to protect yourself; and contact information for further questions.

11. Data Retention and Deletion

Retention Periods. We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory, tax, accounting, or reporting requirements. The specific retention periods depend on the nature of the information and the purposes for which it is used.

General Retention Guidelines:

Deletion Procedures. When personal information is no longer needed, we securely delete or anonymize it using industry-standard methods, including but not limited to the following:

Electronic Data:

Physical Documents:

Data Minimization. We implement data minimization principles to limit the collection and retention of personal information to what is directly relevant and necessary for the purposes for which it is processed. This includes:

12. International Data Transfers

Cross-Border Transfer Mechanisms. As a global company operating in several jurisdictions, we may transfer your personal information across international borders. When we transfer personal information from one jurisdiction to another, we implement appropriate safeguards to ensure that your information remains protected in accordance with this Privacy Policy and applicable data protection laws.

Depending on the countries involved, these safeguards may include:

For Transfers from the United States:

For Transfers from Europe:

For Transfers from China:

Because the Networking Assistant does not index or display personal information of individuals located in mainland China (see Section 2), the mechanisms above apply to personal information of registered users located in the People’s Republic of China.

For Transfers from Hong Kong:

Data Localization Requirements. In certain jurisdictions, we may be required to store specific categories of personal information locally. We comply with these data localization requirements by:

Additional Safeguards. Beyond the formal transfer mechanisms, we implement additional technical, organizational, and contractual measures to protect your information during international transfers, including:

13. Children’s Privacy

Our Services are directed towards college students and professionals and are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, or that personal information of an individual under 18 appears in a Networking Assistant Output, we will take steps to delete or remove such information as soon as reasonably practicable.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us using the information provided in the “Contact Us” section below, and we will take steps to remove such information from our systems.

14. Third-Party Links and Services

Our Services, including Networking Assistant Outputs, may contain links to or information obtained from third-party websites, applications, platforms, databases, or services that are not owned or controlled by us. This Privacy Policy applies only to our Services. We have no control over and assume no responsibility for the privacy practices, availability, or content of any third-party sites or services.

We encourage you to review the privacy policies of any third-party sites or services you visit or use to understand how they collect, use, and share your personal information.

Examples of third-party services that may be linked from our platform include:

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices — including Networking Assistant Outputs removal, deletion, correction, or opt-out requests under Section 8.2 — please contact Cookd AI Inc. using the subject “Privacy” and the information below:

Via Mail: Cookd AI Inc, 40 Wall St, 28th Floor, New York, NY 10005

Via Email: privacy@cookd.ai