California Privacy Notice

Effective Date: August 12, 2026

This California Privacy Notice ("Notice") provides additional information to residents of the State of California in accordance with the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA/CPRA"). This Notice supplements the Learney Privacy Policy.

Notice Regarding Student Data. Learney operates exclusively through schools. Student data is processed on behalf of, and at the direction of, the school as "school official" data and is governed by FERPA, COPPA, and California's student privacy laws (SOPIPA and AB 1584). This student data is controlled by the school, and the consumer rights described in this Notice apply primarily to adult users (teachers, school administrators, parents, and website visitors). See Sections 7 and 9 below.

1. Categories of Personal Information We Collect

The following categories of personal information (as classified under the CCPA) have been collected by the Company in the preceding 12 months:

• Identifiers: name, email address, account ID, IP address
• California Customer Records Information: name, contact information
• Internet or Network Activity: service usage records, access logs
• Geolocation Information: approximate location (IP-based)
• Audio or Electronic Information: speaking-practice voice recordings (student data, controlled by the school)
• Professional or Employment Information: affiliated school, role (teacher or administrator)
• Education Information: learning activity and achievement (student data, controlled by the school)
• Sensitive Personal Information (SPI): account login credentials (used solely to provide the service)

We do not collect biometric identifiers, precise geolocation, or advertising identifiers.

2. Sources of Collection

• Provided directly by users and schools
• Collected automatically through use of the service (e.g., cookies)
• Received from schools and third parties (Google Classroom / SSO rosters)