Last Updated: May 14, 2025

CoLearn Privacy Policy

CoLearn ("CoLearn", "we", "us", or "our") operates the CoLearn online platform. We are committed to protecting the personal information and privacy of our users ("you"). When you register, log in, and use the CoLearn platform, we collect, use, and store your personal information. This Privacy Policy explains how we handle your personal information. We are committed to processing your personal information in strict accordance with this Privacy Policy.

By using our services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.

If you are under the age of 18, or the age of majority in your jurisdiction, please review this policy with your parent or legal guardian to ensure you understand it. Our services are not directed to children under the age of 16 (or a lower age if permitted by the laws of your residence, such as 13 in the United States under COPPA, with verifiable parental consent), and we do not knowingly collect personal information from children without appropriate consent.

This Privacy Policy applies to all products and services offered on the CoLearn platform. Please read this Privacy Policy carefully before using CoLearn to fully understand its terms, including those that may limit our liability.

This Privacy Policy will help you understand the following:

I. Definitions

II. Information We Collect and How We Use It

III. Lawful Basis for Processing (for EU/EEA Users)

IV. How We Store and Retain Your Personal Information

V. How We Share, Transfer, and Disclose Your Personal Information

VI. International Data Transfers

VII. Cookies and Similar Technologies

VIII. Third-Party Products or Services

IX. How We Protect Your Personal Information

X. Your Rights Regarding Your Personal Information

XI. How We Handle Children's Personal Information

XII. Updates to This Privacy Policy

XIII. How to Contact Us

I. Definitions

  1. User: Includes registered and non-registered users, referred to as "you" in this policy.
  2. CoLearn: The online co-working and study platform.
  3. Study Room Services: Real-time video call services provided by CoLearn to users.

II. Information We Collect and How We Use It

  1. Account Registration When you register for a CoLearn account, we collect personal information such as your email address, and username (nickname). We create your account and login credentials. We collect this information to complete your registration, secure your account, and provide our services. If you do not provide this information, we cannot create an account or provide services to you. You may also choose to provide an avatar to personalize your profile; this is optional.

  2. Using Online Learning and Study Services When you use CoLearn's browsing, learning, and study services, we may collect information necessary to provide these services, such as usage data, and interactions within the platform. For identity verification in certain contexts (e.g., for specific services or compliance), we may request additional information. If you do not provide this information, some features may be unavailable.

  3. Payment Processing When you make payments on CoLearn, we collect order information, transaction status, and payment account information (processed by our third-party payment processors). We use this to confirm your order, provide services, protect your financial security, and resolve disputes. If you do not agree to this collection, you may not be able to complete transactions. Invoicing information (if requested) such as name, contact details, and company information may also be collected.

  4. Chat and Comment Features When you communicate or post comments on CoLearn, we store the chat information and content you provide. If you do not agree, you may not be able to use these features effectively.

  5. Network Access and Basic Service Security To ensure network and service security, we collect your IP address, access dates and times, and service log information. This helps us secure our platform and your access.

  6. Service Reliability and Stability To ensure service reliability, we collect device model, operating system version, browser type, language used, network access method, and network quality data. This is essential for the stable operation of CoLearn.

  7. Customer Support When you contact us for support, we may collect your communication records, account information, contact details, and any information you provide to substantiate your query. This is to provide effective customer service.

  8. Video Call Recording, Storage, and Security To ensure the safety and protection of our users and community, user-to-user video calls on the CoLearn platform are recorded and securely stored on our servers for twenty-four (24) hours, after which they are automatically deleted. We use industry-standard encryption and security measures to protect these recordings from unauthorized access. In rare cases of misconduct, relevant recordings may be shared with law enforcement. This is a key measure for community safety. If you do not agree to this, please discontinue using the service.

  9. Security Assurance To enhance the security of our services and protect users, we may collect and use account information, transaction data, device information, and log data to assess risks, authenticate users, detect and prevent security incidents, and take necessary actions as required by law.

  10. Service Improvement and New Features We continuously strive to improve our services. This may involve collecting new personal information or changing how we use existing information for new features. If so, we will update this policy and/or provide notice and seek your consent where appropriate.

  11. SDK Usage Our application may use Software Development Kits (SDKs) from third parties for functionalities like payment processing, analytics, and customer support. These SDKs may collect your personal information according to their own privacy policies. We will list significant third-party SDKs and link to their privacy policies where feasible.

    • Payment Processors (e.g., Stripe, PayPal - illustrative examples): For processing payments. Data collected may include payment card details, transaction information. Please refer to the specific payment processor's privacy policy.
    • Analytics Services (e.g., Google Analytics, Sentry - illustrative examples): To understand service usage, improve performance, and monitor errors. Data collected may include device identifiers, IP address, usage patterns, crash reports.
      • Sentry: Used for error tracking and performance monitoring. Collects application crash reports, performance data, and device usage information. See Sentry Privacy Policy.

III. Lawful Basis for Processing (for EU/EEA Users)

If you are in the European Union (EU) or European Economic Area (EEA), we process your personal data based on the following lawful grounds:

  1. Performance of a Contract: We process your personal data to provide and maintain our services to you as set out in our Terms of Service. This includes account registration, providing learning features, and payment processing.
  2. Legitimate Interests: We process your personal data for our legitimate interests, such as:
    • Ensuring the security and stability of our services.
    • Improving and developing our services and features.
    • Protecting our rights and the safety of our users.
    • Customer support.
    • Analytics and service optimization (where it does not override your rights and interests).
  3. Consent: We may process certain personal data based on your explicit consent, for example, for sending marketing communications or using certain types of cookies. You can withdraw your consent at any time.
  4. Compliance with Legal Obligations: We may process your personal data if necessary to comply with a legal obligation.

IV. How We Store and Retain Your Personal Information

We will retain your personal information for the minimum period necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements). When we no longer have an ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

Your personal information may be stored and processed in countries where we have facilities or in which we engage service providers, including the United States and countries in the European Union. We take steps to ensure that the data we collect is processed according to this Privacy Policy and the requirements of applicable law wherever the data is located.

V. How We Share, Transfer, and Disclose Your Personal Information

  1. Sharing with Service Providers: We may share your information with third-party vendors, consultants, and other service providers who perform services on our behalf (e.g., payment processing, data analytics, hosting, customer support, security). These service providers are authorized to use your personal information only as necessary to provide these services to us and are obligated to protect your information.
  2. Business Transfers: We will not transfer your personal information to any company, organization, or individual, except in the event of a merger, acquisition, asset sale, or bankruptcy. In such cases, we will inform you and require the new entity holding your personal information to continue to be bound by this Privacy Policy or seek your renewed consent.
  3. Legal Requirements and Public Disclosure: We may disclose your personal information if required by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will only publicly disclose your personal information with your explicit consent, or as legally required in specific circumstances (e.g., for public safety).
  4. Anonymized or Aggregated Data: We may share or disclose de-identified or aggregated information that cannot reasonably be used to identify you. This data is not considered personal information.

We do not sell your personal information to third parties.

VI. International Data Transfers

CoLearn operates globally, and your personal information may be transferred to, stored, and processed in countries other than your own, including the United States and countries within the European Economic Area (EEA). These countries may have data protection laws that are different from the laws of your country.

When we transfer personal information of users in the EEA, UK, or Switzerland to a country outside of these regions that has not been deemed to provide an adequate level of data protection, we will implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, or rely on other lawful mechanisms for such transfers. You can request a copy of these SCCs by contacting us.

VII. Cookies and Similar Technologies

  1. We use cookies and similar tracking technologies (like web beacons and pixels) to provide and improve our services, understand how our services are used, and for advertising purposes. Cookies are small data files stored on your device. They typically contain identifiers, site names, and some numbers and characters. Cookies help websites store your login records and preferences, simplifying repeated logins.
  2. We will not use cookies for any purposes other than those described in this Privacy Policy. You can manage or delete cookies based on your preferences. For details, see https://www.aboutcookies.org. Most web browsers allow you to block cookies. However, if you do so, you may need to change user settings each time you visit our site, previously recorded information may be deleted, and the security of the services you use may be affected.

VIII. Third-Party Products or Services

Our services may contain links to third-party websites or services that are not owned or controlled by CoLearn. This Privacy Policy does not apply to the practices of third parties that we do not own or control. We encourage you to review the privacy policies of any third-party services you access.

IX. How We Protect Your Personal Information

We take the security of your personal information very seriously. We have implemented appropriate technical and organizational measures designed to protect your personal information from unauthorized access, use, alteration, and disclosure. These measures include network segregation, data encryption, and access controls.

Please be aware that despite our efforts, no security system is impenetrable. If our security measures are breached, leading to unauthorized access, disclosure, alteration, or destruction of your information, and your legitimate rights and interests are harmed, we will take appropriate remedial action, including informing you and relevant authorities as required by applicable law.

X. Your Rights Regarding Your Personal Information

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal information:

  1. Right to Access: You have the right to request access to the personal information we hold about you.
  2. Right to Rectification: You have the right to request correction of inaccurate personal information.
  3. Right to Erasure (Right to be Forgotten): You have the right to request deletion of your personal information under certain conditions (e.g., if the data is no longer necessary for the purposes for which it was collected, or if you withdraw consent).
  4. Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information under certain circumstances.
  5. Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
  6. Right to Object: You have the right to object to the processing of your personal information under certain conditions, particularly for direct marketing purposes or processing based on legitimate interests.
  7. Right to Withdraw Consent: If we process your personal information based on your consent, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
  8. Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority (data protection authority) in your jurisdiction if you believe our processing of your personal information infringes applicable data protection laws.
  9. Automated Decision-Making: We do not currently engage in decision-making based solely on automated processing that produces legal effects concerning you or similarly significantly affects you. If this changes, we will inform you and provide you with an opportunity to object.

You can exercise these rights by logging into your CoLearn account and using the provided tools, or by contacting us using the details in the "How to Contact Us" section. We may need to verify your identity before processing your request. We will respond to your request within the timeframes required by applicable law. Reasonable requests are generally free of charge, but we may charge a fee for repetitive or excessive requests.

There are exceptions to these rights; for example, we may not be able to delete your data if we are legally required to keep it or if it's necessary for us to defend legal claims.

XI. How We Handle Children's Personal Information

CoLearn is not intended for children under the age of 16, or below the relevant age of consent in your jurisdiction for processing personal data without parental consent (e.g., 13 in the U.S. under COPPA, with verifiable parental consent). We do not knowingly collect personal information from individuals below this age without verifiable parental consent. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us, and we will take steps to delete such information.

XII. Updates to This Privacy Policy

Our Privacy Policy may change from time to time. We will post any changes on this page. For significant changes, we will provide a more prominent notice (e.g., via in-app notification or email). We will not reduce your rights under this Privacy Policy without your explicit consent. We will also keep prior versions of this Privacy Policy in an archive for your review.

Significant changes include, but are not limited to: major changes in our service model; changes in the main entities with whom personal information is shared, transferred, or publicly disclosed; significant changes in your rights regarding personal information processing and how you exercise them; changes in our responsible department for personal information security, contact methods, and complaint channels; or when a personal information security impact assessment report indicates a high risk.

XIII. How to Contact Us

If you have any questions about this Privacy Policy or our personal information protection practices, please contact us via:

Email: support@colearn.me

We will generally respond within thirty days or as otherwise required by applicable law. If you are unsatisfied with our response, especially if our processing of your personal information has harmed your legitimate rights and interests, you may also have the right to complain to the relevant data protection supervisory authority in your jurisdiction.