COHORT1 PRIVACY POLICY
Last Updated: September 13, 2026
Welcome to Cohort1! Cohort1, Inc. (“Cohort1,” “we,” “us” or “our”) provides a high-quality tech-enabled peer network for middle- and high-school students of high academic achievement to develop relationships and life skills through facilitated group discussions.
This policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use our website and services as a registered user (collectively, the “Services”). This Privacy Policy further describes the rights and choices available to individuals with respect to personal information collected through the Services. For purposes of this Privacy Policy, we refer to any individual user of the Services as refer to “you” or “your.”
Cohort1 maintains a separate Website Privacy Policy that applies to data collection about general visitors to our websites who are not logged into a registered account.
Personal Information We Collect
Information you provide to us. Personal information you provide to us through the Services includes:
Personal and contact information, such as your first and last name and email address.
Demographic information, such as your city and state of residence, postal code, age, school, financial aid data.
Academic information, such as your school transcript or homeschool portfolio and your standardized test score documentation (optional for children 13-15 years of age).
Registration information, such as student authored narratives, including a Motivation Statement describing why you want to join Cohort1, and a letter of recommendation.
Service delivery information, such as your special education status and accommodation requests and availability for sessions.
Any communications or other information you voluntarily share with Cohort1 in connection with the Services, such as by email, phone, chat features, or through live discussion.
Session recording information, such as recordings and related transcripts of Cohort1 sessions.
Payment data, including payment card information or bank account number. (We use a third-party vendor to directly collect and process your payment card information, as described further below.)
Information collected automatically. When you use the Services, we, our service providers, and advertising partners may automatically collect:
Device information, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, and general location information such as city, state or geographic area.
Location data, which may be approximate (for example, as inferred from network data or device settings).
Session data, such as session attendance records, transcription data from sessions, session recordings, safety violation records, and webSocket connection data.
Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before using the Services, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Cookies and Tracking Technologies: Some of the automatic collection described above is facilitated by the following technologies:
Essential Cookies: Required for website functionality (session management, form submission)
Analytics Cookies: Google Analytics to understand site usage (anonymized where possible)
Advertising and Attribution Technologies: Tools such as Meta Pixel, related cookies, and pixel tags (web beacons) used to deliver advertisements and measure ad campaign effectiveness and user acquisition.
Local Storage Technologies: Browser local and session storage (HTML5) used to keep you signed in, remember your audio/video device preferences, store portal content (such as your group directory and messages) on your device, and remember a referral code if you arrived through a referral link.
How We Use Your Personal Information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
To provide the Services. We use your personal information to:
Process applications, administer entrance exams, match students with cohorts, and facilitate sessions
Send confirmation emails, program updates, and important notices
Bill membership fees and exam fees
Analyze usage patterns, improve matching algorithms, and enhance curriculum
Compliance, protection, and safety. We may use your personal information to comply with applicable laws, protect rights and safety, ensure internal compliance, enforce our terms, and prevent illegal activity.
With your consent. In some cases, including whenever required by law, we may specifically ask for your consent to collect, use, or share your personal information for further purposes, if those purposes are not compatible with the initial purpose for which that personal information was collected.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services.
Delivering, Tracking, and optimizing advertising campaign effectiveness. We and our third-party advertising partners may collect and use certain personal information for marketing and advertising purposes. For example, we and our third-party advertising partners may use cookies, pixels and other technologies (such as the Meta Pixel) to collect information about parents’ interactions (including the data described in the Information collected automatically section above) with the Services, our communications and other third party online services over time, and use that information to serve online ads that they think will interest parents and legal guardians. This is called interest-based advertising. Such activities are directed exclusively at parents and legal guardians in their capacity as applicants, account holders, and decision-makers for the Services. We do not engage in interest-based advertising targeting Student Participants. Any use of advertising tools such as the Meta Pixel is limited to parent-facing campaigns and is not used to track or target students. We may also share information about parent users with these companies to facilitate interest-based advertising to those or similar users on other online properties.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
To enhance the performance and functionality of our services.
To help us understand user activity of the Services, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.
How We Share Your Personal Information
We may share your personal information with the following parties or as otherwise described at the time of collection:
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us provide the Services, such as customer support, hosting, analytics, session recording and transcription, email delivery, marketing, and database management services. For example, such service providers may include:
AI Facilitation (OpenAI). We use OpenAI to facilitate group sessions and entrance assessments. During a session or assessment, live audio is streamed to OpenAI to transcribe speech and generate facilitator responses. We also use OpenAI to perform an automated review of recorded assessment video for integrity purposes, including a visual review and speaker diarization (identifying who is speaking). OpenAI does not use this data to train its foundational models under its applicable API terms of service.
AI Evaluation, Safety, and Scheduling (OpenAI, Anthropic). We use OpenAI and Anthropic’s Claude models to evaluate completed entrance-assessments, to review session content for safety and conduct concerns, and to assist with scheduling. The relevant transcripts and text are shared for these purposes only. Neither OpenAI nor Anthropic uses this data to train its foundational models under its applicable API terms of service.
Videoconferencing and Recording (Daily.co). We use Daily.co to host and record live video sessions. Session audio, video streams, and participant identifiers are processed by Daily.co solely to deliver the video conferencing service and to produce session recordings, which are stored in Amazon Web Services S3.
Cloud Infrastructure (Amazon Web Services). We use Amazon Web Services (AWS) to operate the Services — including Cognito (account authentication), S3 (storage of recordings, transcripts, and uploaded documents), and SES (transactional email). Personal information is stored and processed within AWS as part of delivering the Services.
Cohort group members. As part of the Services, the first and last name, grade level, school, and city and state of residence of each Student Participant are shared with the other members of that student's assigned cohort group (typically three other students) and their respective parents. This information is shared solely within the cohort group to facilitate the peer network experience and is not publicly visible on the internet or accessible to users outside the cohort group.
Payment processors. Any payment card information you use to make a purchase in connection with the Services is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/privacy.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above.
For compliance, protection, and safety. We may share your personal information with law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance, protection, and safety purposes described above.
Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Cohort1, financing of Cohort1, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Cohort1 or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Security and Retention Practices
Data security. We implement industry-standard security measures to protect your personal information. However, no system is 100% secure. We cannot guarantee absolute security but commit to promptly notifying you of any data breaches as required by law.
Data retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. The following retention periods generally apply:
Active Members: Data is retained for the duration of membership plus 7 years for financial and legal compliance.
Applicants (Not Admitted): Application data is retained for 2 years, after which it is deidentified or deleted.
Waitlist: Data is retained until you request removal or 2 years from submission, whichever comes first.
Deletion Requests: Requests are honored within 30 days, except where retention is required by law.
Your Choices
Cookies and browser web storage. You can control cookies through your browser settings. Disabling cookies may limit website functionality. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools::
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Some platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option for Google and Facebook at the following websites:
Google Analytics: https://tools.google.com/dlpage/gaoptout
Facebook: Adjust your ad preferences in your Facebook settings or visit https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: https://optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these advertising-related opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Access or update your information. You have the right to:
Access the personal information we hold about you
Request corrections to inaccurate information
Request a copy of your data in a portable format
Deletion. You may request deletion of your personal information, subject to legal retention requirements.
Opt-out of communications. You can opt out of marketing emails by clicking “unsubscribe” in any marketing message. You will continue to receive transactional emails necessary for the Services.
Declining to provide information. We need to collect personal information to provide the Services. If you do not provide the information we identify as required or mandatory, we may not be able to provide the Services.
Exercising Your Rights. To exercise any of these rights, contact us at hello@cohort1.org with your request. We will respond within 30 days.
Other Sites and Mobile Applications
The Services may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
International Data Transfers
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Students Under 13
The Services are intended for use by individuals who are at least 13 years of age. Students cannot apply or create accounts independently. All applications and registrations must be initiated by a parent or legal guardian. The parent or guardian must create their own account first and accept the Terms of Use and acknowledge this Privacy Policy before a Student Participant account can be created and linked. Student accounts are connected to and managed through the parent or guardian's account at all times.
We do not knowingly collect personal information from children under 13. If we discover that we have inadvertently collected personal information from a child under 13 without verifiable parental consent, we will delete that information promptly. If you believe we have collected information from a child under 13, please contact us at hello@cohort1.org.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. We will notify you of material changes via email and update the “Last Updated” date at the top of this page. Continued use of the Services after changes constitutes acceptance of the updated policy.
Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
Email: hello@cohort1.org
Website: cohort1.org
For privacy-related requests (access, deletion, etc.), please include “Privacy Request” in your email subject line and provide sufficient information to verify your identity.