Oswin AI Privacy Policy

Version: 1.1 Effective: October 18, 2026

Key points. This summary does not replace the full text of this Policy.

• Your data is processed by Oswin Technologies LLC, a U.S. company. Your data is stored primarily in the United States and the European Union.
• We collect information you provide to us yourself (your name, phone number, email address, assignments, and messages) and information recorded automatically (how you use the website and your Account, and the devices and IP addresses you use).
• We use your data to teach you, to sell you our Programs, to protect our Materials, and to improve our products.
• We do not sell your personal data for money. We share it with the services the school cannot operate without (hosting, CRM, email, video, payments, and advertising); the list is in Section 8.
• You may unsubscribe from our marketing at any time and ask for a copy or deletion of your data, subject to the exceptions described in Section 11.

1. Who We Are

1.1. The party responsible for the processing of your personal data (the controller) is Oswin Technologies LLC, a North Carolina limited liability company that does business under the Oswin AI and Oswin Labs brands and formerly operated under the VADYM.AI school brand (the "Company," "we," or "us").

1.2. Address: 212 W Main St, Suite 309, Durham, NC 27701, USA. Questions about personal data: privacy@oswin.ai.

1.3. Representative in the European Union (Article 27 of the EU General Data Protection Regulation, the "GDPR"): VADYM.AI prosta spółka akcyjna, ul. Jana i Jędrzeja Śniadeckich 20D/7, 35-006 Rzeszów, Poland, KRS 0001127305, email privacy@oswin.ai. Individuals in the EU and EU supervisory authorities may contact the representative on any matter relating to the Company's processing of data.

2. Scope of This Policy

2.1. This Policy applies to personal data that we process through the website https://oswin.ai, the learning platform https://learn.oswin.ai, the Live Session platform https://live.oswin.ai, our support service, our Telegram bots, channels, and chats, telephone calls and correspondence with us, and any other websites and services that link to this Policy, including websites operating under the former VADYM.AI name (collectively, the "Platform").

2.2. This Policy supplements the Oswin AI Terms of Use and Public Offer Agreement (https://oswin.ai/terms, the "Terms"). Capitalized terms defined in the Terms have the same meanings in this Policy.

2.3. This Policy does not apply to third-party websites and services that we link to or through which we provide part of the Services (including Telegram, YouTube, and Meta). Those services process data under their own rules, and we are not responsible for them.

2.4. Nature of this Policy. This Policy is a notice of how we process data. It is not a contract, does not create any contractual obligations of the Company, and does not grant you any rights beyond those expressly granted by applicable law. Any consents you give under this Policy remain effective notwithstanding the foregoing.

2.5. Disputes. Disputes concerning the processing of personal data are resolved in accordance with Section 24 of the Terms (informal pre-arbitration dispute resolution and arbitration). This does not limit your right to lodge a complaint with a data protection supervisory authority (Sections 11.5 and 11.6).

3. Personal Data We Collect

3.1. Data you provide to us:

1. Inquiries and registrations: name, phone number, email address, your question or comment, the Package you selected, and language.
2. Account: first name, last name, email address, phone number, password (in hashed form), your name in Latin characters for your certificate, avatar, and Telegram ID and username.
3. Questionnaires and surveys: age, occupation, role, field of business, country, experience with artificial intelligence, and goals and preferences.
4. Learning: homework assignments (text, files, and links), quiz answers, notes, comments, lesson ratings, questions to curators and to the AI assistant, questions asked during Live Sessions and votes on them, postings in the job board section, and projects and code (including in our code repository).
5. Communications: emails, support requests and attached files, messages in Live Session chats, bots, and Communities, and reviews.
6. Calls and meetings: recordings and transcripts of telephone calls, consultations, video meetings, and Live Sessions in which you participate, including your voice and image.
7. Payments: payer name, amount, currency, date, payment method, payment status, order number, the last digits of your card (if the payment service provides them), invoices, and, for business purchasers, business name, address, and tax identification number. We do not receive your full card details.
8. Case studies and reviews: descriptions of your results, photos, videos, and business name that you provide or that are created during your studies.

3.2. Data collected automatically:

1. Technical data: IP address, approximate location derived from your IP address (country and city), internet service provider, device type, operating system, browser, language, time zone, and screen resolution.
2. Usage data: the pages you visited, where you came from, the buttons you clicked, advertising campaign tags (UTM parameters), and click identifiers (fbclid, gclid, and ttclid).
3. Learning platform data: logins and logouts, session duration and frequency (including periodic activity signals while you watch), the number and type of devices, concurrent sessions, video viewing progress, seconds watched, picture-in-picture mode, and completion of assignments.
4. Data used to prevent Access sharing: the combination of IP addresses, internet service providers, countries, and devices from which your Account is used, and personalized watermarks in videos (your email address and a code that identifies your Account).
5. Cookies and similar technologies: see Section 7.

3.3. Data we receive from others:

1. Advertising platforms (Meta, Google, TikTok, and others): data from lead forms in ads, advertising identifiers, and campaign statistics.
2. Payment services and banks: payment status and details, installment plan information, and chargeback notifications.
3. Telegram: your Telegram ID, name, username, and interface language when you start our bot or join our chats.
4. Partners and other Users: the promo code or referral link through which you came to us, and contact details shared by a partner with your consent.
5. Public sources: publicly available information about your company or professional activities, if you purchase as a business.

3.4. Special categories of data. We do not ask for, and do not wish to receive, data concerning health, religious or political beliefs, ethnic origin, biometric data used for identification, or criminal convictions. Do not send such data to us in assignments, questionnaires, or chats. If you nonetheless provide such data on your own initiative, you expressly consent to its processing to the extent necessary to respond to you, and we may delete it without notice.

3.5. Other individuals' data. If you send us personal data of other individuals (for example, data of your clients in a homework assignment or of your colleagues in an inquiry submitted on behalf of a company), you represent and warrant that you have a lawful basis to do so and that you have informed those individuals of this Policy, you are solely responsible for doing so, and you will indemnify the Company for any losses arising from claims by those individuals.

3.6. Accuracy of data. You are responsible for the accuracy of the data you provide and for keeping it up to date. We are not responsible for the consequences of inaccurate or outdated data provided by you.

4. How We Use Your Data

1. To provide the Services: to create your Account, grant Access, conduct Live Sessions, review assignments, issue certificates, provide support, and send service messages.
2. To sell and advise: to contact you about your inquiry, recommend a Program, send Live Session reminders, send offers, keep a record of our communications in our CRM, and assess your level of interest (see Section 6).
3. To accept payment: to process payments, installment plans, invoices, and refunds, and to maintain accounting and tax records.
4. To protect the Materials and the Platform: to detect Access sharing, copying and distribution of the Materials, fraud, spam, attacks, and abuse of promo codes and the referral program, and to identify the source of any leak of the Materials.
5. To protect our rights: to contest chargebacks and payment disputes; to prove the formation of the contract and the provision of the Services (including through the login and viewing logs used to determine refund eligibility under Section 11.2 of the Terms); to collect debts; to record and preserve evidence of breaches of the Terms (including copies of publications, messages, and correspondence); to respond to public accusations without disclosing more data than necessary; to obtain legal advice; and to conduct disputes, arbitration, and court proceedings.
6. For advertising and analytics: to measure the effectiveness of our advertising, share information about inquiries and purchases with advertising platforms (in hashed or encrypted form where possible), build lookalike audiences, and understand how the website is used.
7. To improve the Services: to analyze how people learn, where they drop out of a course, and which topics are difficult, and to monitor the quality of work of our sales managers and curators, including through call recordings.
8. For research and development: to develop new products, adaptive learning systems, and artificial intelligence systems based on de-identified or aggregated learning data. De-identified and aggregated data is not personal data, and we may use and disclose it without restriction, including in publications, investor reports, and grant applications.
9. To market using your stories: to publish case studies, reviews, and excerpts from Live Session recordings within the scope of Section 15 of the Terms.
10. To comply with the law: to respond to lawful requests from public authorities and to comply with tax, sanctions, and other legal requirements.
11. For business reorganizations: in the event of a merger, a sale of the business or its assets, a rebranding, or a transfer of the Platform to another person.

5. Legal Bases for Processing

5.1. We process your data on the following legal bases: (a) performance of a contract with you, or steps taken at your request before entering into a contract (Section 4, items 1 and 3); (b) our legitimate interests, namely selling and promoting our Services, protecting the Materials, preventing fraud, protecting our rights and collecting debts, analytics, improving the Services, research and development, and operating our business (Section 4, items 2, 4–9, and 11); (c) compliance with legal obligations (Section 4, item 10); and (d) your consent, where the law specifically requires consent.

5.2. Consent. By submitting an inquiry, registering, paying for the Services, or continuing to use the Platform after reviewing this Policy, you consent to the processing of your personal data for the purposes described in Section 4, including its transfer abroad (Section 9) and our contacting you in accordance with Section 27 of the Terms. If you are located in Ukraine, you give this consent, among other things, under the Law of Ukraine "On Personal Data Protection," including consent to the transfer of your data to the United States and the other countries listed in Section 8.

5.3. If you withdraw your consent, the withdrawal does not affect the lawfulness of processing carried out before the withdrawal or of processing carried out on the other legal bases in Section 5.1.

5.4. Providing the data required for an inquiry, an Account, and payment is a requirement for entering into the contract; without that data we cannot provide the Services. The processing of Access logs and of data used to prevent Access sharing (Section 3.2(3)–(4)) is an essential condition of providing the Services under the Terms; an objection to that processing, or a demand that it stop, made during your access period has the consequences described in Section 28.2 of the Terms.

5.5. We have balanced the legitimate interests on which we rely against your rights and have concluded that those interests are not overridden by your rights: you are a party to a contract with us or have submitted an inquiry, you expect to hear from us, and you can limit marketing at any time (Section 11.2). Upon request, we will explain this balancing for a specific purpose.

6. Automated Processing and Artificial Intelligence

6.1. We use artificial intelligence services to process your data, including to:

1. transcribe recordings of calls, consultations, and meetings (ElevenLabs) and prepare summaries and quality assessments of those conversations (Google Gemini);
2. answer questions in the Account's AI assistant and in Live Session chat (Google Gemini); your question and excerpts from the Materials are sent to the service to generate the answer;
3. help curators and our support team prepare responses; and
4. analyze de-identified learning data for research and development.

6.2. We assign interest and priority scores to leads and customers based on their actions (for example, registering for a Live Session, watching, or answering a call) in order to decide whom to call and when. Our system automatically flags Accounts that show signs of Access sharing; any decision to block an Account is made by a human.

6.3. We do not make decisions about you that produce legal effects for you based solely on automated processing, without human involvement.

7. Cookies, Pixels, and Analytics

7.1. We use: (a) strictly necessary cookies, to sign you in to your Account, maintain your session, remember your interface language, protect forms, and set a signed-in indicator visible on the oswin.ai website; (b) browser local storage, so that pop-ups are not shown to you again and to remember where you stopped in a video; (c) analytics, namely our own Umami system, which does not use cookies, and, where enabled, Google Analytics, Google Tag Manager, and Microsoft Clarity (session recording and click heatmaps); and (d) advertising technologies, namely the Meta Pixel and the Meta Conversions API, and Google Ads, TikTok, and other advertising network tags, which enable us to measure the effectiveness of our advertising and to show you ads.

7.2. Sharing of inquiries with advertising platforms. When you submit an inquiry or make a purchase, we send to Meta from our server (and may send to other advertising platforms) your hashed email address, phone number, name, city, and country, together with your IP address, browser data, advertising identifiers (_fbp and _fbc), and the page URL, so that the advertising platform can match the inquiry to an ad impression. Hashing means that the data is converted into an irreversible code before it is sent.

7.3. By using the Platform, you consent to the use of these technologies. You can block or delete cookies in your browser settings, install extensions that block trackers, and adjust your ad preferences in your Meta and Google accounts. If you block strictly necessary cookies, your Account and our forms may not work.

7.4. We do not respond to Do Not Track or Global Privacy Control signals unless the law applicable to us requires otherwise.

8. Who We Share Your Data With

8.1. We do not sell your personal data for money. We share it only as described in this Section 8.

8.2. Service providers that process data on our behalf:

We may change our service providers without prior notice; a current list is available on request at privacy@oswin.ai.

8.3. Our instructors, curators, and contractors, to the extent necessary to provide the Services. They are bound by confidentiality obligations.

8.4. Affiliates: companies under common control with the Company, or brands of the Oswin group, for the purposes described in this Policy.

8.5. Payment services and fraud prevention services: information about chargebacks and disputed and suspicious payments.

8.6. Other Users and the public: your name and messages in Communities and in Live Session chats (including Live Session replays), the public certificate verification page (name, Program, and date), and case studies and reviews within the scope of Section 15 of the Terms.

8.7. Public authorities, courts, arbitral tribunals, and lawyers: where required by law, a lawful request, or a court order, or where necessary to establish, exercise, or defend our rights, to protect the safety of Users, or to investigate violations, including disclosure to our lawyers, arbitrators, banks, and payment services in connection with a dispute, and to platforms to which we report infringements of our rights (Section 15.6 of the Terms).

8.8. Successors: in the event of a merger, sale, reorganization, bankruptcy, or transfer of the business or its assets; the new owner will continue to process the data in accordance with this Policy.

8.9. With your consent or at your request: in other cases.

9. International Data Transfers

9.1. The Company is located in the United States, and your data is processed in the United States and in the countries where our service providers operate (Section 8). The laws of those countries may provide a different level of protection than the laws of your country of residence.

9.2. For transfers of data from the EU, the United Kingdom, and Switzerland, we rely on transfer mechanisms provided by law, including the European Commission's Standard Contractual Clauses, adequacy decisions, and mechanisms offered by our service providers.

9.3. By using the Platform, you understand and agree that your data is transferred to and processed in the United States and the other countries listed in Section 8.

10. How Long We Keep Your Data

10.1. We may retain data for longer periods if required by law; if the data is needed for a pending or anticipated dispute, chargeback, investigation, or debt collection, until it is finally concluded; and for the limitation period applicable to claims that may be brought against us or by us in any country where you are located.

10.2. When the retention period expires, the data is deleted, de-identified, or stored in an archive with restricted access. Backups are overwritten in the course of their regular cycle.

11. Your Rights

11.1. You may ask us to: (a) tell you what personal data of yours we process and provide you with a copy of it; (b) correct inaccurate data; (c) delete data; (d) restrict processing; (e) provide your data to you in a machine-readable format; and (f) not use your data for marketing.

11.2. Opting out of marketing. The easiest way is the "unsubscribe" link in an email, the /stop command in a bot, replying STOP to a text message, or writing to privacy@oswin.ai. You will continue to receive service messages relating to training you have paid for.

11.3. Limits on the right to deletion. We do not delete, and we continue to retain, data needed for: performance of a contract that is in effect; accounting and tax records; evidence of the formation of the contract and the provision of the Services; defense against chargebacks and claims; debt collection; prevention of fraud and of re-registration by blocked Users; and compliance with the law. De-identified data and data already used in published materials cannot be withdrawn. Deletion of your Account at your request terminates your Access to the Services without a refund beyond the limits of Section 11 of the Terms (Section 28.2 of the Terms). While a dispute, chargeback, or debt collection is pending, requests to delete, or to restrict the processing of, data related to it will be carried out only after it is concluded.

11.3.1. Limits on the right of access. A copy of your data does not include internal notes and evaluations by our personnel, legal opinions and correspondence with our lawyers, data of other individuals, the Company's trade secrets and methodologies, or internal security logs and methods for detecting Access sharing, to the extent permitted by law (including Article 15(4) and Article 23 GDPR). We may provide call recordings in the form of transcripts instead of audio.

11.4. How to submit a request. Write to privacy@oswin.ai from the email address associated with your Account or inquiry. We may ask you for additional information to verify your identity and will not act on your request until your identity has been verified. We respond within 30 days; this period may be extended if the request is complex or if we receive a large number of requests. Where permitted by law, we may refuse to act on requests that are manifestly unfounded or excessive, including repetitive requests, or may charge a reasonable fee for them. Requests submitted through an authorized agent will be considered only if accompanied by a power of attorney signed by you and verification of your identity. We accept requests in Ukrainian, English, or Polish. A request does not suspend or extend any period under the Terms (including the period for requesting a refund under Section 11.2 of the Terms) and does not constitute a notice of dispute under Section 24.1 of the Terms.

11.5. Users in the EU, the EEA, the United Kingdom, and Switzerland also have the right to object to processing based on legitimate interests, to withdraw consent at any time, and to lodge a complaint with the data protection supervisory authority in their country of residence (in Poland, for example, the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych)). We ask that you contact us first, as most issues can be resolved faster directly.

11.6. Users in Ukraine have the rights provided by the legislation of Ukraine on personal data protection and may lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights.

11.7. Residents of U.S. states have the rights provided by the laws of their state only if those laws apply to the Company.

12. Security

12.1. We use organizational and technical safeguards, including encryption of connections, storage of passwords in hashed form, signed video links, segregation of personnel access, and backups.

12.2. No method of data transmission or storage is completely secure, and we cannot guarantee the absolute security of your data. You are responsible for keeping your password confidential and for the security of your devices.

12.3. If an incident occurs that creates a significant risk to your rights, we will notify you and the relevant authorities where required by applicable law.

12.4. You must notify us immediately at privacy@oswin.ai if you become aware of any unauthorized access to your Account. The Company's liability for security incidents is limited in accordance with Section 21 of the Terms to the extent permitted by law; we are not responsible for incidents on the side of third-party services that process data under their own rules (Section 2.3), or for incidents caused by your devices or password.

13. Children

13.1. The Platform is intended for persons aged 18 and over. We do not knowingly collect data from persons under 18 years of age. If you believe that a child has provided us with personal data, write to privacy@oswin.ai and we will delete it. A person who has provided us with false information about their age is in breach of Section 3.3 of the Terms; that person's Access will be terminated with the consequences set out in Section 23.3 of the Terms, to the extent permitted by law.

14. Changes to This Policy

14.1. We may change this Policy by posting a new version on this page with its effective date. We will also notify Users with active Access of material changes by email or in their Account. Your continued use of the Platform after the new version takes effect constitutes your acceptance of it. If the changes concern processing for which the law requires separate consent, we will request that consent separately. Previous versions are available on request.

15. Language

15.1. This Policy is made in English and Ukrainian. In the event of any discrepancy, the English version prevails, unless the law of your country of residence requires otherwise.

16. Contact Us

Oswin Technologies LLC 212 W Main St, Suite 309, Durham, NC 27701, USA Personal data: privacy@oswin.ai Support: support@oswin.ai