Privacy Policy

Cookd AI Inc., a Delaware corporation ("Company", "we", "us", or "our") provides the People Search platform (the "Service"). This Privacy Policy describes how we collect, use, disclose, and safeguard personal information through our website (peoplesearch.icu) and related online properties that link to this Privacy Policy (collectively, the "Service").

Before registering for or using the Service, please read and thoroughly understand this Privacy Policy. This Privacy Policy describes our practices regarding personal information. Your use of the Service is also governed by our Terms of Service. Where consent is required by applicable law, we will obtain consent separately.

1. Personal Information We Collect

Information You Provide to Us

• Account data: Email address, password (hashed — we do not store plaintext passwords), name, and login credentials (including Google OAuth).
• Invite code data: Invite codes you use during registration and invite codes generated for your account, including their usage status.
• Communications data: Messages, inquiries, or feedback shared with us through support channels.
• User activity data: Search queries, search results interactions, and other actions performed within the Service.

Information We Collect Automatically

• Device data: Operating system, browser type, IP address, device identifiers, screen resolution, and approximate geolocation derived from IP address.
• Online activity data: Logs of interactions with the Service, session duration, referral URLs, pages visited, and features used.
• Cookies and tracking technologies: Used to maintain sessions, store preferences, and analyze usage patterns. Where required by applicable law, we obtain your consent before placing non-essential cookies.

Information from Third-Party Sources

• Third-party login services: If you register or log in using Google OAuth, we receive your email address and display name from Google. We only access information you have authorized through the OAuth consent flow.
• Public sources: The Service may access and process information obtained from publicly available websites or databases to provide search results.

Information About Individuals Appearing in Search Results

The Service may collect, process, organize, enrich, infer, and display personal information about individuals who are not registered users of the Service. This information may include names, professional or educational history, publicly available profile information, contact information, social or web presence, and other information derived from publicly available sources, third-party data providers, user-provided inputs, AI-generated or inferred information, and/or other lawful sources. Public availability of information does not mean that such information may be used for all purposes. Users are responsible for using search results only for lawful and legitimate purposes as described in our Terms of Service.

2. How We Use Your Personal Information

We may use personal information for the following purposes:

• Service delivery: To provide and maintain the Service, including account management, authentication, search functionality, and invite code administration.
• Security and compliance: To detect, prevent, and address fraud, abuse, violations of our Terms of Service, or other harmful activity. To verify account integrity and prevent unauthorized access.
• Service improvement: To analyze usage trends, optimize performance, debug issues, and develop new features. We may use aggregated or de-identified data for this purpose.
• Communications: To send service-related announcements, support responses, or administrative notices necessary for the operation of your account.
• Legal compliance: To comply with applicable laws, regulations, legal processes, or lawful government requests.

We do not use your personal information to train AI models in an individually identifiable manner. We do not send marketing or promotional communications without your explicit consent.

3. How We Share Your Personal Information

We may share personal information with the following categories of recipients:

• Service providers: Hosting, analytics, communication, and support vendors who process data on our behalf and are contractually obligated to protect your information.
• Third-party AI services: Inputs may be processed by third-party AI service providers to deliver search results. These providers are subject to confidentiality obligations.
• Affiliates: Where necessary for business operations, with entities under common control with the Company.
• Legal authorities: Where required by law, legal process, or governmental request, or to protect the rights, property, or safety of the Company, our users, or others.
• Corporate transactions: In connection with mergers, acquisitions, financing, reorganization, or sale of assets, where personal information may be transferred as part of the transaction.

We do not sell or share registered users' account information for cross-context behavioral advertising. However, the Service may make certain search-result information about individuals available to authorized users as part of the Service. Where such activity is considered a "sale," "sharing," or data broker activity under applicable law, we will comply with applicable opt-out, deletion, registration, and disclosure requirements.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Maintain your authentication session
• Remember your preferences
• Analyze usage patterns and improve the Service
• Ensure security and prevent fraud

Cookie choices: You may control cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Service. We recognize and honor Global Privacy Control (GPC) signals sent by your browser.

5. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

Rights for All Users

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete personal information
• Request deletion of your personal information
• Opt out of non-essential communications
• Request information about how your personal information is used and shared
• Log out or request account deletion

Search Result Removal and Opt-Out Requests

If you are an individual whose personal information appears in search results, you may request removal, deletion, correction, or opt-out by contacting us at privacy@peoplesearch.icu. Please include sufficient information for us to identify the relevant record, such as your name, profile URL, email address, company, or other identifying details. We may request additional information to verify your identity or locate the relevant record.

Where the information is controlled by a third-party data provider, API, or public source, we may remove or suppress the information from our Service where required or appropriate, and we may direct you to the relevant third-party provider to exercise deletion, correction, or opt-out rights at the source.

United States Privacy Rights

If you are a resident of California, Virginia, Colorado, Connecticut, or other states with comprehensive privacy laws, you may have additional rights including:

• Right to Know/Access: Request information about the categories and specific pieces of personal information we have collected.
• Right to Delete: Request that we delete personal information we have collected from you, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information where applicable. We do not sell or share registered users' account information for cross-context behavioral advertising. To the extent search-result information is considered a "sale" or "sharing" under applicable law, we will honor applicable opt-out rights.
• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights.

California Data Broker and Deletion Requests

To the extent the Company is considered a data broker or is otherwise subject to data broker laws, we will comply with applicable registration, disclosure, opt-out, and deletion request obligations. California residents may have the right to request deletion of personal information maintained by registered data brokers through applicable deletion request mechanisms, including the California Delete Request and Opt-Out Platform ("DROP"), where applicable. We will process such requests as required by applicable law.

European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have additional rights under the GDPR including:

• Right of Access: Obtain confirmation of whether we process your personal data and access to that data.
• Right to Rectification: Have inaccurate personal data corrected.
• Right to Erasure: Have your personal data erased under certain circumstances.
• Right to Restriction: Restrict processing of your personal data under certain circumstances.
• Right to Data Portability: Receive your personal data in a structured, machine-readable format.
• Right to Object: Object to processing of your personal data, including for direct marketing.
• Right to Lodge a Complaint: File a complaint with your local data protection supervisory authority.

Legal bases for processing (EEA/UK users): We process your personal information based on contractual necessity (to provide the Service), legitimate interests (to improve and secure the Service), compliance with legal obligations, or your consent where required.

To exercise any of these rights, please contact us at privacy@peoplesearch.icu.

No Consumer Reporting Use

The Service is not designed or intended to be used as a consumer report, background check, employment screening tool, tenant screening tool, credit eligibility tool, insurance eligibility tool, or for any purpose regulated by the Fair Credit Reporting Act ("FCRA") or similar laws. We do not use personal information to determine any individual's eligibility for employment, housing, credit, insurance, education, public benefits, licensing, or other rights, benefits, or opportunities.

6. Data Security

We implement administrative, technical, and physical security measures to protect your personal information, including:

• Encryption of data in transit using TLS/SSL
• Secure password hashing (bcrypt)
• Access controls and authentication requirements
• Regular security assessments

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

7. Data Retention

We retain personal information for as long as necessary to provide the Service, comply with legal obligations, resolve disputes, enforce our agreements, protect against abuse, and comply with applicable privacy, opt-out, or deletion requests.

• Account information: Retained for the duration of your account and for a reasonable period thereafter to comply with legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
• Search activity data: We retain search queries, result interactions, and related logs for as long as reasonably necessary for security, abuse prevention, debugging, legal compliance, and service improvement, unless a longer retention period is required or permitted by law. We may retain aggregated or de-identified analytics data for a longer period.
• Search-result information: We retain information about individuals appearing in search results for as long as reasonably necessary to provide the Service, comply with opt-out or deletion requests, maintain suppression records, prevent re-ingestion of deleted information where required, resolve disputes, and comply with applicable law.
• Communications: Retained as necessary to provide support and maintain records.
• Suppression records: Where an individual requests deletion or opt-out, we may retain limited information necessary to honor the request and prevent the individual's information from being re-added to the Service, unless prohibited by applicable law.

When personal information is no longer needed, we securely delete or anonymize it.

8. International Data Transfers

We may transfer personal information outside your jurisdiction, including to the United States, where our servers and operations are primarily located. Where required by law (e.g., GDPR), we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission.

9. Children's Privacy

The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a minor, we will take steps to delete such information promptly.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at privacy@peoplesearch.icu.

10. Third-Party Links and Services

The Service may contain links to third-party websites or services not owned or controlled by us. This Privacy Policy applies only to our Service. We encourage you to review the privacy policies of any third-party services you access.

11. Updates to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last Updated" date and, where required, notify you through the Service or by email. Your continued use of the Service after the effective date constitutes acceptance of the updated Privacy Policy.

12. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us:

• Company: Cookd AI Inc.
• Address: 40 Wall St, 28th Floor, New York, NY 10005
• Email:privacy@peoplesearch.icu