General Privacy Policy Matters

At OKO Labs, Inc., we take the privacy of our users very seriously. This Privacy Policy describes our policies on the collection, use, and disclosure of information that identifies, describes, relates to, or is reasonably capable of being directly or indirectly associated with an individual ("Personal Data") in connection with a person’s use of our platform, OKO (the "Platform").

This Privacy Policy applies solely to the Platform and does not apply to our informational website located at https://okolabs.ai/ (the "Informational Site").

Information We Collect

Categories of Personal Data Collected

We have collected and stored the following Personal Data from or about users over the past 12 months:

Teachers and Administrators

• Name
• Title
• Email address
• Address, including State
• School district name
• School name
• Usage data, detected gestures, and interactions with the Service
• Teacher-generated content

Students

• Name
• Email address
• Grade level
• School district name
• School name
• Usage data, detected gestures, and interactions with the Service
• Student-generated content and speech transcriptions

When We Collect Personal Data

We collect Personal Data:

• When users directly provide it to us, such as when they:
  
  • Register or create an account
  • Request assistance from our customer support team
  • Complete contact forms, request newsletters, or participate in surveys
  • Participate in activities we promote that require user information
• Automatically, when users interact with the Service, including:
  
  • General activity on the Service
  • Anonymized session identifiers
  • Website traffic volume, visit frequency, and transaction history
  • Interaction with email messages (e.g., open/click rates)
  • Internet Protocol (IP) address
  • Device, operating system, and browser information
  • Data from cookies and similar technologies (see "Cookies and Similar Technologies" section)
• From other sources, such as service providers and business partners for analytics, data processing, payment processing, hosting, and other services.

How We Use Users’ Information

We do not share Personal Data for advertising or marketing purposes. We do not ask or require individuals under 16 to provide more information than necessary for the Service. We use user information to:

• Operate, maintain, and optimize the Service
• Improve service quality
• Diagnose security risks or errors
• Provide technical support
• Track and recover user accounts
• Conduct research and gather feedback
• Provide product and service updates
• Analyze service usage trends

Cookies and Similar Technologies

What Are Cookies?

Cookies are small text files stored on devices by websites for user identification. Cookies can be:

• Persistent Cookies: Remain on the device after going offline
• Session Cookies: Deleted when the browser is closed
  For details on managing cookies, visit http://www.aboutcookies.org/.

Use of Cookies and Other Technologies

We use cookies for preference storage, analytics, and improving user experience. By using the Service, users consent to cookie usage. Disabling cookies may limit access to certain Service features.

Sharing of Personal Data

We may share Personal Data with:

• Service Providers, including analytics, hosting, and technical support partners
• Business Partners and Affiliates providing additional products or services
• Other Users, for information posted in reviews
• Corporate Affiliates, including subsidiaries and joint ventures
• With Consent, for explicit sharing agreements

We may also share information:

• For legal compliance (e.g., subpoenas, law enforcement requests)
• As part of business transfers (e.g., mergers, acquisitions)
• As anonymized data, for analytics and reporting

No Sales of Personal Data: OKO does not sell or rent user Personal Data.

“Do Not Track” Signals

The Service does not respond to "Do Not Track" signals since we do not track users across third-party websites.

Data Retention and Account Termination

Users can close accounts by contacting support@okolabs.ai. Upon closure, data collection ceases, but some data may be retained as required by law or for security purposes. Users can update or request deletion of Personal Data by emailing support@okolabs.ai.

Student Privacy

Students under 13 require verifiable parental consent or consent from a school/district administrator. We do not knowingly collect Personal Data from individuals under 16 without proper authorization.

Schools remain in control of their students’ personally identifiable information (“Student PII”) used in the Platform at all times. OKO only collects, processes, and maintains Student PII on behalf of and under the direct control of the school.

Parental Requests‍

FERPA requires schools to provide parents with access to their children’s education records, and parents may request that the school correct records that they believe to be inaccurate or misleading. If you are a parent or guardian and would like to review, correct, or update your child’s data stored in our Platform, contact your school. We will work with your school to enable your access to and, if applicable, correction of your child’s education records. If you have any questions about whom to contact or other questions about your child’s data, you may contact us at privacy@okolabs.ai.

Security

We employ commercially reasonable security measures, but no method is 100% secure. Users are encouraged to take precautions to protect their Personal Data.

Location of Data and Transfers of Information

The Service operates in the United States. Personal Data is processed using Amazon Web Services and Google Cloud Platform, adhering to GDPR security standards.

Privacy Rights

California Privacy Rights (CCPA)

California residents may request:

• Deletion of Personal Data
• Access to Personal Data collected over the past 12 months
• Opt-out of Personal Data sales (if applicable in the future)
• Non-discriminatory treatment when exercising privacy rights
  Requests can be made via support@okolabs.ai. Responses are provided within 45 days.

Modifications to this Privacy Policy

We may update this Privacy Policy. Users are encouraged to review changes periodically. Continued use of the Service signifies agreement to the updated policy.

Contact Information

OKO Labs, Inc.
169 Madison Ave. #2202
New York, NY 10016
privacy@okolabs.ai

Effective Date of this Privacy Policy: November 17, 2025