Privacy Policy

1. Scope of This Policy

This Policy applies to all visitors, registered Peers, and Organizations who access or use the Platform, regardless of how they access it (mobile app, website, or otherwise). It does not apply to third-party websites, services, or applications that may be linked to or from the Platform, which are governed by their own privacy policies.

2. Information We Collect

2.1 Information You Provide Directly

We collect information you provide when you:

• Create an account (name, email address, date of birth, password, phone number)
• Build your Cooper Card and Portfolio (video recordings, audio recordings for CoopCast, photos, written descriptions, work samples, links)
• Interact with other Peers (testimonials given or received as Real Proof, Impact Stars, messages, comments)
• Register or operate as an Organization (company name, role, business email, payment information, job or opportunity postings)
• Submit a Request to a Peer, or respond to a video pitch (Pitch Your Potential)
• Contact us for support, or report content or another user

2.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical information, including:

• Device information (device type, operating system, unique device identifiers)
• Log data (IP address, browser type, pages viewed, time and date of access, referring URLs)
• Usage data (features used, videos viewed or uploaded, Requests sent or received, Impact Stars granted)
• Approximate location derived from IP address, and precise location only if you separately grant device-level permission
• Cookies and similar tracking technologies (see Section 9)

2.3 Information From Third Parties

We may receive limited information from third-party services you choose to connect to Cooper (for example, single sign-on providers), from Organizations who upload information about opportunities, and from payment processors who confirm that a transaction has been completed.

3. No Biometric Recognition

Cooper is a video-first platform, but Cooper does not currently perform, and has no plans to perform, facial recognition, voice recognition, or any other form of biometric identification or biometric information processing on the video or audio content Peers upload (including Cooper Card videos, video pitches, video testimonials, or CoopCast audio). Video and audio content is stored and displayed for viewing by other users as described in this Policy, but is not analyzed to extract, scan, or derive biometric identifiers. If this changes in the future, we will update this Policy and obtain any consent required by applicable law (including, where applicable, laws such as the Illinois Biometric Information Privacy Act) before implementing any such processing.

4. How We Use Information

We use the information we collect to:

• Create, maintain, and secure your account and your Cooper Card, Portfolio, and Digital Footprint
• Operate the Platform’s core features, including Requests, Real Proof, Impact Stars, CoopCast, and the Peer Algorithm
• Enable Organizations to browse, search, and send Requests to Peers, and process the associated payment
• Communicate with you about your account, transactions, and updates to the Platform
• Monitor, investigate, and enforce our Terms of Service and Community Guidelines, including reviewing reported content
• Detect, prevent, and address fraud, abuse, security incidents, and other harmful or illegal activity
• Improve and develop the Platform, including analyzing aggregated usage trends
• Comply with legal obligations, including responding to lawful requests from public authorities

5. How Information Is Shared

5.1 With Other Users

Your Cooper Card, Portfolio, Real Proof testimonials, Impact Stars, and related public profile content are visible to other Peers and to Organizations on the Platform, consistent with the visibility settings available to you. Cooper’s Search is designed to help Organizations and Peers find and discover profiles; it does not filter, rank, or exclude any user from being discoverable based on eligibility criteria.

5.2 With Organizations

When an Organization browses Portfolios or reviews a video pitch, they see the profile information you have made visible. When an Organization sends a Request, additional contact information necessary to facilitate that connection may be shared with the Organization, consistent with the Platform’s functionality and any in-product notice shown to you at that time.

5.3 With Service Providers

We share information with third-party vendors who perform services on our behalf, such as cloud hosting and video storage, payment processing, customer support tooling, analytics, and content moderation support. These providers are authorized to use information only as necessary to provide services to Cooper.

5.4 Legal and Safety Disclosures

We may disclose information if required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect the rights, property, or safety of Cooper, our users, or the public.

5.5 Business Transfers

If Cooper is involved in a merger, acquisition, financing, or sale of assets (including a future reorganization as a Delaware corporation), information may be transferred as part of that transaction, subject to standard confidentiality protections.

5.6 We Do Not Sell Personal Information for Advertising

Cooper does not sell Peer personal information to third parties for cross-context behavioral advertising purposes. To the extent any data sharing with service providers is later determined to constitute a “sale” or “share” under applicable state law, we will provide the opt-out mechanisms described in Section 7.

6. Data Retention

We retain information for as long as your account is active and as needed to provide the Platform. Following account deletion, we remove or de-identify personal information within a reasonable period, except where we are required or permitted to retain it longer, including to comply with legal, tax, accounting, or safety obligations, to resolve disputes, or to enforce our agreements. Content shared with other users (such as a Real Proof testimonial you gave to another Peer) may remain associated with that other user’s profile after you delete your account, unless removal is requested and legally required.

7. Your Privacy Rights

Depending on where you live, you may have rights under applicable privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and similar laws in states such as Colorado, Connecticut, Virginia, Utah, and others. Subject to certain exceptions, these rights may include the right to:

• Know what personal information we have collected about you
• Access a copy of your personal information
• Correct inaccurate personal information
• Delete your personal information
• Opt out of the sale or sharing of personal information (see Section 5.6)
• Not be discriminated against for exercising these rights

To exercise any of these rights, contact us at legal@thecooperapp.com. We will verify your request before responding, consistent with applicable law.

8. Children’s Privacy

The Platform is intended for users who are 18 years of age or older and is not directed to children. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a user under 18, we will take steps to delete that information and terminate the associated account. If you believe a user under 18 has provided us with personal information, please contact us at the address in Section 12.

9. Cookies and Similar Technologies

The Platform currently uses only essential cookies and similar identifiers necessary to keep you signed in, maintain your session, and support core functionality. Cooper does not currently use third-party analytics, advertising, or tracking tools. If we adopt such tools in the future, we will update this Policy accordingly and provide any consent or opt-out mechanisms required by applicable law. You can control cookies through your browser or device settings; disabling essential cookies may limit some features of the Platform.

10. Data Security

We use administrative, technical, and physical safeguards designed to protect information from unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. International Users

Cooper is based in the United States, and information is processed and stored in the United States. If you access the Platform from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your jurisdiction.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, contact us at:

The Cooper App LLC

11815 Globe St, Orlando, FL 32832

Email: legal@thecooperapp.com

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify users through the Platform or by other reasonable means before the changes take effect. The “Effective Date” at the top of this Policy indicates when it was last revised.