Learney Privacy Policy

Effective Date: August 12, 2026

Learney Inc. ("Learney," "Company," "we," "us," or "our") operates an AI-powered learning platform (the "Service") available at en.learney.school, lms.learney.school, and app.learney.school. This Privacy Policy (the "Policy") explains how we collect, use, disclose, and protect the personal information of users of the Service in the United States. Our practices are governed by applicable U.S. federal and state laws, including the Family Educational Rights and Privacy Act (FERPA), the Children's Online Privacy Protection Act (COPPA), the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and other applicable state privacy laws.

This Policy is organized into two parts:

• Part 1 — General Privacy Policy applies to users aged 13 and older (teachers, school and district administrators, parents and guardians, and website visitors).
• Part 2 — Children's and Student Privacy Notice applies to the data of students who access the Service through their school and to children under the age of 13. This data is processed under the control of the school.

Defined terms are set out in Appendix A (Definitions).

Table of Contents

Part 1 — General Privacy Policy

1. About Learney and Scope of This Policy
2. Important Notice for School Users
3. Information We Collect
4. How We Use Information
5. AI-Powered Features
6. What We Do Not Do
7. Third-Party Service Providers (Sub-Processor List)
8. Data Security
9. Cookies and Automatically Collected Information