Cookie Policy

1. Preface

This Cookie Policy explains how the Company uses cookies and similar technologies on the Company’s websites and in connection with the Platform, and how End Users and other visitors can manage preferences. This Cookie Policy applies where the Company acts as a Controller for the relevant data collected through cookies and similar technologies. Effective Date: February 21, 2026. Last Updated: February 21, 2026.

2. Definitions and Relationship to Other Documents

Capitalized terms used in this Cookie Policy have the meanings set out in the Terms of Service, including Company, Platform, Customer, Organization, Instructor, Learner, End User, Content, Personal Data, Controller, Processor, and Subprocessor. This Cookie Policy forms part of the Privacy Policy and should be read together with it.

3. Cookies and Similar Technologies

Cookies are small text files placed on a device when a website is visited. Similar technologies may include local storage, pixels, tags, software development kits, and other identifiers that enable recognition of a device or browser. Depending on configuration, these technologies may collect information such as a session identifier, login state, preferences, device characteristics, and usage events.

4. Purposes of Use

4.1 Strictly Necessary Technologies

Some technologies are necessary to provide the website or Platform features requested by the user, such as maintaining session state, enabling authentication, preventing fraudulent activity, balancing load, and ensuring basic security. Where such technologies are strictly necessary, they may be used without separate consent to the extent permitted by applicable law.

4.2 Functional and Preference Technologies

The Company may use technologies that remember user choices and preferences, such as language selection, accessibility settings, or interface configuration, in order to improve user experience and provide consistent operation across sessions. Whether such technologies require consent depends on applicable law and the specific implementation.

4.3 Analytics and Performance Technologies

The Company may use analytics and performance technologies to understand how the website and Platform are used, to measure performance, and to identify errors and usability issues. The Company uses analytics tools such as Google Analytics to understand usage patterns and improve the Platform. Where consent is required, analytics technologies will be activated only after the user provides consent through the applicable mechanism.

4.4 Advertising and Marketing Technologies

The Company may use technologies that support advertising or marketing communications, such as measuring campaign effectiveness or limiting the frequency of marketing messages, where applicable. The Company does not currently use advertising or marketing cookies. Where required, such technologies will be used only after consent is obtained.

5. Consent and Preference Management

Where applicable law requires consent for certain cookies or similar technologies, the Company will provide a consent mechanism, such as a banner or preference center, that enables users to accept, refuse, or configure categories of technologies. The Company will also provide information about the consequences of refusal where relevant, including that certain features may not function as intended without particular technologies.

Users may also manage cookies through browser or device settings. Browser controls vary by browser and device, and disabling cookies may affect the availability or functionality of the Platform. Where a preference center is provided, changes made through the preference center will apply to the relevant website or device and may not automatically apply across all browsers, devices, or domains.

6. Third-Party Technologies

The Company may permit third parties, such as analytics or payment service providers, to set or read cookies or similar technologies in connection with the Platform. Third-party technologies may include those from analytics providers (such as Google Analytics) and payment service providers (such as Stripe). Third parties may process data collected through their technologies under their own policies, and users should review those policies where relevant.

7. Updates to this Cookie Policy

The Company may update this Cookie Policy from time to time. The Company will publish the updated version within the legal documentation portal and may provide additional notice of material changes by reasonable means. Unless otherwise stated, changes take effect on the effective date specified in the updated Cookie Policy.

8. Contact

Questions about this Cookie Policy may be directed to the Company using the contact details in the Contact and Notices page. Privacy contact email: heretohelp@openmirai.com.