Updated 14.07.25

Privacy Policy

Cogknit Oy (3376829-4) operates (https://app.cogknit.io/) and (https://app.lukla.ai). In this privacy policy, we refer to ourselves as "Cogknit," "we," "us," or "our," and our platforms, features and tools collectively as "Service."

We are committed to respecting your privacy and securing your personal data across our integrated services connecting users, companies, educational institutions, public authorities, and other stakeholders. This policy outlines how we collect, use, safeguard, and provide control over our personal data.

Data We Collect

User Accounts:

• Our application does not collect or request age information from users. However, the Service is intended for use by individuals who are 13 years of age or older. By using our Service, you self-declare that you are at least 13 years old

• We collect self-declared info related to names, emails, education, profession, career, hobby, skills, interests, goals, competencies, assessments and evaluation logs that you’ve received and made, to create accounts and provide personalized services. We may collect profile pictures, personal projects, portfolio projects, language skills, job and career preferences, entrepreneurship ideas and stages, and personality profiles. Additionally, we may collect behavioral and engagement data and insights as produced within the scope of our Service such as results, analysis, acceptance, rejections, views, enrollments, votes and so on.

• For organizational users, we collect organization names, addresses, contact numbers, and emails.

• We collect and process only the personal information you choose to share with us, either directly or through connected services, such as importing your details from LinkedIn or other third-party platforms you authorize.

• While we respect your privacy, complete anonymity on our platform cannot be guaranteed. Your user account is linked to your email address and other identifiable details, which may allow us to associate your activity with your identity for support, compliance, or personalization purposes.

• For users under 16, in cases when known and if belonging to a bilateral B2B (Business to Business) contracted organization, we additionally obtain parental or guardian contacts and verifiable consent.
  

Usage Data:

We log technical details like IP addresses, browser information, device data, and usage statistics for analytics and service improvement.

User Content:

Users can create and share personal data on the Service platform among other users of the same institutions or even publicly through their actions in accessing following features or activities such as creating profiles, courses, assignments, projects, assessments, discussion forums, comments, notes, events, skills assessments or evaluations, attachments, jobs, projects, internships, mentorships, vibe matches, roadmaps, playground quizzes, sessions, communities and general events. Users themselves are solely responsible for such personal data published on the Service.

Use of Data

We use data for the following purposes only:

• Providing integrated services such as Learning Management System, Project Management System, Skills Assessment, Skills Development, Workshops, Insights, Sessions, Playground, Vibe Match, Courses and digital products etc.

• Facilitating user collaboration, engagement and professional development

• Analytics to improve features, evaluate usage patterns

• Communicating updates, support, provision of materials

• Coordination with accrediting educational institutions

• Providing recognition, certifications, financial benefits

• Recruitment and internship opportunities (with consent)

• Complying with legal and financial obligations

• Ensuring cybersecurity of the Service platform

We do not sell, rent or share personal data for marketing without explicit consent. Non-personal and encrypted data can be used for development of the Service and its services, research, analyses, results sharing, impact figures and stories, communication, dissemination, marketing and similar purposes.

Data Retention

We retain your personal data only for as long as it is needed to fulfill the purposes for which it was originally collected, such as providing services, maintaining your account, or meeting legal and regulatory obligations.

You have the right to request the deletion of your personal data at any time. Once we receive your request, we will process and complete the deletion no later than 60 days from the date of the request.

Non-personal data is retained for analytics.

Children's Privacy

For users under 16, we limit processing to only what is reasonably and legally necessary. Parents/guardians can access, rectify, restrict processing, or request erasure of their child's data.

Third-Party Partners

To deliver a seamless and personalized experience across our platform, we may work with trusted third-party service providers. These partners support us by:

• Hosting and maintaining key infrastructure

• Analyzing user behavior to improve our offerings

• Assisting in communication (e.g., video calls, messages, sending emails or notifications)

• Supporting matchmaking between jobseekers, mentors, and service providers

These partners may access limited personal data solely for the tasks they’re contracted to perform. We ensure they follow strict data confidentiality agreements and are prohibited from using your information for any unrelated purposes.

In particular, we utilize services from OpenAI (OpenAI, L.L.C., 3180 18th St, San Francisco, CA 94110, USA) to support certain core features and enhance the functionality of our platform. When interacting with OpenAI’s systems, we take measures to anonymize or pseudonymize personal data wherever feasible, in accordance with relevant data protection regulations. To learn more about how OpenAI processes data, please see their Privacy Policy.

International Transfers

To deliver our Services, we sometimes work with partners located outside the EU/EEA. This means your personal data may be transferred to countries such as the United States, where some of our key service providers; including Google, Amazon, Microsoft, and OpenAI are based.

These transfers occur only when necessary and are safeguarded by legally approved mechanisms. Specifically, we rely on the European Commission’s Standard Contractual Clauses (SCCs), which require non-EU recipients to uphold data protection standards equivalent to those in the EU.

Your data is treated with the same level of care, regardless of where it is processed.

Data Security

Protecting your personal information; whether you're a learner building your portfolio or a mentor guiding others, is a top priority. We implement industry-standard security measures, including encryption, access controls, and regular audits to safeguard your data.

While we implement robust technical and organizational measures like encryption, access controls, and testing to secure data against unauthorized access or breaches, it’s important to note that no method of digital transmission or storage is infallible. We continuously monitor threats and improve our practices, but we cannot guarantee absolute security.

To further enhance safety, we recommend you:

• Exercise rigorous privacy settings of features as they become available

• Log out after using shared devices

• Be cautious of phishing attempts pretending to be our platform

User Rights

All users have the following data protection rights:

• Access: Request copies of personal data we hold about you.

• Rectification: Correct any inaccurate personal data.

• Erasure: Request deletion of your account and personal data.

• Restrict Processing: Request restricting processing by rendering account inactive.

• Object: Object to processing activities like marketing by opting out.

• Data Portability: Obtain a portable copy of personal data in standard format.

• Withdraw Consent: Withdraw consent for processing based on consent at any time.

Our websites use cookies to gather information and enhance your experience on our website. You can choose to accept or decline cookies, and your browser will notify you when a cookie is being sent. Please note that if you choose to decline cookies, some features of our website may not function properly.

You can exercise these rights by contacting contact@cogknit.io. We will handle requests without undue delay and may require proof of identity.

We comply with regulations and support these rights regardless of location. In case of a data breach affecting your personal data, we will notify you without undue delay.

We do not knowingly process data of children under 13. If we become aware, we will promptly delete it. If you suspect someone under 13 as users or data of children under 13 in the Service platform, please contact contact@cogknit.io for prompt deletion and other actions that may be required.

Profiling and Automated Decisions

Our Services rely on automated processing to deliver personalized recommendations, match you with relevant opportunities, and enhance your overall experience. Profiling is done, based on your consent, to offer you personalized recommendations for jobs, projects, internships, mentorships, vibe matches, roadmaps, playground quizzes, sessions, courses, communities and general events matching your interests and competences.

We do not use your data for any automated decision-making or profiling that produces legal effects.

If you choose not to consent to this automated use of your personal data, we regret that we will be unable to offer you access to our platform or allow you to create an account.

Accountability and Governance

Where we act as joint controller or service provider with educational institutions or other institutions for specific processing activities related to user accounts, trainings, career services or similar, we ensure appropriate joint controller agreements defining roles and responsibilities are in place.

For business prospects, we process contact details including users of legally registered entities such as companies, municipalities, organizations etc., based on legitimate interests or consent for prospecting purposes, retaining data for 3 years from last contact unless you object.

Links to External Resources

Our Service may include links to third-party resources, such as online courses, forums, job boards, portfolio tools, community forums, and so on. These links are provided for our efficient Service delivery, your convenience and growth, but please be aware that we do not control these external sites.

We encourage you to review the privacy policies of any website you choose to visit from our platform. We are not responsible for how those third parties collect, use, or protect your information.

Changes

We may update our Privacy Policy occasionally. We encourage you to check this page regularly for any changes. Any updates will be posted here and will take effect immediately upon publication. By continuing to use the Services after the effective date of any changes, you agree to be bound by the modified Terms.

Contact

For any privacy queries, to exercise data rights or report concerns, contact our Data Protection Officer at contact@cogknit.io.

Cogknit Oy

c/o Hanken Business Lab
Arkadiankatu 22
00100 Helsinki, Finland