Privacy Policy

1. Data We Collect

• Account data: name, email, and password (passwords are stored encrypted; we never see the original).
• Billing data: when you subscribe, payment is processed by Stripe. We receive limited billing details (such as plan, status, and the last digits of your card); we do not store full card numbers.
• Content you create: photos, videos, audio, exercises, and homework created or uploaded through the Services, including via camera, microphone, and photo library (only with your permission).
• Student data (handled on behalf of the Teacher): when a Teacher enrolls Students, we process Student information (such as name and learning activity) on the Teacher’s behalf. See Section 6.
• Usage and diagnostic data: navigation events, device model, operating system, app/device identifiers, and crash reports.
• Website and tracking data: when you visit oceanenglish.app, we and our partners collect data through cookies and similar technologies (such as pages viewed, referring source, and advertising identifiers). See Section 4.

2. How We Use Your Data

We use data to: create and manage accounts; process payments; enable features; maintain security and prevent fraud; analyze and improve the Services; measure and improve our marketing; and comply with legal obligations. We do not sell your personal data. (For California “sharing” for advertising, see Section 8.)

3. Legal Basis for Processing

We process personal data based on: performance of our contract with you; your consent (for example, device permissions and non-essential cookies); our legitimate interests (to improve and secure the Services and measure marketing); and compliance with legal obligations.

4. Cookies and Tracking Technologies

Our website uses cookies and similar technologies, including:

• Essential cookies — required for the site to function.
• Analytics — Google Analytics, to understand site usage.
• Advertising / measurement — the Meta Pixel and Google tags, which help us measure and optimize our ads and may allow Meta and Google to associate your visit with your accounts on their platforms.

Where required by law (for example, in the EU/UK, Brazil under the LGPD, and California), we ask for your explicit consent before setting non-essential cookies, and tracking scripts will remain blocked until such consent is provided. You can change your choices at any time through our cookie banner or your browser settings. Learn more in Meta’s Privacy Policy and Google’s Privacy Policy.

5. Sharing and Third-Party Services

We use third-party providers that process data on our behalf:

• Stripe — payment processing.
• Google Firebase / Google Analytics — infrastructure, analytics, crash reporting.
• Meta (Pixel) — advertising measurement.
• OpenAI — to generate exercises and assist with homework grading.
• Microsoft Azure (AI Speech) — pronunciation assessment and text-to-speech.
• Video-conferencing provider(s) — for live classes.

We share data only as needed to provide the Services and require providers to maintain adequate safeguards. We may also disclose data when required by law.

6. Student Data — Teacher as Controller

For personal data of Students enrolled by a Teacher, the Teacher is the data controller and Cortex acts as a processor that processes Student data only on the Teacher’s instructions to provide the Services. The Teacher is responsible for having a lawful basis and for obtaining any required consents (including parental/guardian consent for minor Students). Our obligations as processor are described in our Data Processing Addendum.

7. International Data Transfers

Some providers (such as Stripe, Google, Meta, OpenAI, and Microsoft Azure) may store and process data on servers outside your country. We take steps to ensure such transfers comply with applicable data-protection laws, including the use of Standard Contractual Clauses (SCCs) for data transferred from the EEA, UK, or Brazil to countries without an adequate level of protection.

8. Your Rights and Choices

Depending on where you live, you may have the right to: confirm and access your data; correct it; request deletion; request portability; withdraw consent; and object to or restrict certain processing. Users in Brazil have specific rights under the LGPD, including the anonymization, blocking, or deletion of unnecessary data.

California residents: we do not “sell” personal information for money. Our use of advertising tools like the Meta Pixel may be considered “sharing” for cross-context behavioral advertising under California law; you may opt out via our cookie banner / “Do Not Sell or Share My Personal Information” control.

To exercise any right, contact denise@thecortexdigital.com. You can also delete your account and data on our Data Deletion page.

9. Storage and Security

We use reasonable technical and administrative measures (including password encryption and access controls) to protect data. No method of transmission or storage is 100% secure, but we work continuously to protect your information.

10. Data Retention and Deletion

We keep personal data only as long as necessary for the purposes described here or as required by law. You may delete your account and associated data at any time in the app, via the Data Deletion page, or by contacting us. After deletion, data is removed except what we are legally required to keep.

11. Children and Minors

The Services are intended for users 13 years of age and older and are not directed to children under 13. We do not knowingly collect personal data from children under 13. Teachers must not enroll Students under 13 and are responsible for obtaining any parental/guardian consent required for minor Students (ages 13–17). If we learn we have collected data from a child under 13, we will delete it. Parents/guardians may contact us at denise@thecortexdigital.com.

12. Changes to This Policy

We may update this Policy. We will revise the “Last updated” date and, for material changes, provide notice within the Services. Continued use after changes means you accept the updated Policy.

13. Contact

Cortex Digital Studio LLC (d/b/a Córtex Digital)

Email: denise@thecortexdigital.com · 133 N Pompano Beach, Apt 106, Pompano Beach, FL 33062