Privacy Policy

Last updated: October 26, 2026

1. Introduction

This notice explains how we process personal data, as a data controller, relating to visitors and users ("Users") of our website and web application located at https://ocean-ai.co/ (together, the "Website"), including our onboarding quiz, our courses, our prompt library and our AI tools. In this notice, "you" and "your" refer to any User.

We update this notice from time to time, so Users should check back on a regular basis.

Please note that other websites or services mentioned on the Website are not operated by us, and you should refer to the privacy policies on those websites to understand how your personal data is used there.

We are committed to safeguarding the privacy of our Website visitors and users. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

In this policy, "we", "us" and "our" refer to TIKI PUNCH APPLICATIONS LIMITED, the company behind Ocean Learn. For more information about us, see Section 12 (Our details).

2. Credit

2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. The personal data that we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

3.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name and email address. The source of the contact data is you.

3.3 We may process your Website account data ("account data"). The account data may include your account identifier, name, email address, account creation and modification dates, subscription status, Website settings and marketing preferences. The primary source of the account data is you, although some elements of the account data may be generated by our Website.

3.4 We may process the answers you give in our onboarding quiz and your learning activity ("learning data"). The learning data may include your goals, experience level, the AI tools you use, your interests, your answers to questions about your work or income range, the courses and lessons you open, your progress and completion status, and the prompts you save or use. The source of the learning data is you and your use of the Website.

3.5 We may process the content that you enter into our AI tools ("AI input data"), such as questions, prompts and other text, together with the responses generated for you.

3.6 We may process information relating to transactions, including purchases of subscriptions and other products, that you enter into with us through our Website ("transaction data"). The transaction data may include your name, your email address, the products purchased, the amount, the currency, the payment method type and the transaction status. The source of the transaction data is you and/or our payment services provider. We do not receive or store your full payment card details.

3.7 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.

3.8 We may process data about your use of our Website and services ("usage data"). The usage data may include your IP address, approximate geographical location, device identifiers, browser type and version, operating system, referral source, advertising campaign information, length of visit, page views and Website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems and the cookies and similar technologies described in Section 6.

4. Purposes of processing and legal bases

4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal basis of the processing.

• Operations - We may process your personal data for the purposes of operating our Website, providing our courses, prompt library and AI tools, creating and managing your account, processing and fulfilling orders and subscriptions, and generating invoices, bills and other payment-related documentation. The legal basis for this processing is our legitimate interests and the performance of a contract between you and us.
• Personalization - We may process contact data, account data and learning data for the purposes of personalizing your learning plan, course recommendations and the content shown to you. The legal basis for this processing is our legitimate interests and the performance of a contract between you and us.
• Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by the means of communication you provided, sending you sign-in codes and service messages, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our Website visitors, service users and customers, the maintenance of relationships, and the proper administration of our Website.
• Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is consent and/or our legitimate interests. You can unsubscribe from marketing emails at any time using the link in the email or by contacting us.
• Research and analysis - We may process usage data, learning data and/or transaction data for the purposes of researching and analysing the use of our Website and services, measuring and improving our advertising and onboarding funnel, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent and/or our legitimate interests.
• Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests.
• Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis for this processing is our legitimate interests.
• Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5. Providing your personal data to others

5.1 Your personal data held in our Website database will be stored on the servers of our hosting services providers.

5.2 Financial transactions relating to our Website and services are handled by our payment services provider, Solidgate, and by the payment methods you choose at checkout, such as card payments, Apple Pay, Google Pay and PayPal. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. We will not store or collect your payment card details. Any card details you give will go straight to our third-party payment processor, which uses your personal information according to its own privacy policy. You can find information about the privacy policies and practices of our payment providers at:

• https://solidgate.com/legal/privacy-policy-web/
• https://www.paypal.com/us/legalhub/privacy-full
• https://www.apple.com/legal/privacy/data/en/app-store
• https://policies.google.com/privacy

5.3 We use analytics and advertising technologies, such as the Meta Pixel and our own analytics tools, to measure how our Website and advertising perform. These providers may use cookies and similar technologies and may receive usage data and limited contact data (for example, a hashed email address) as described in Section 6. You can find information about their privacy policies via the links below:

• Meta: https://www.facebook.com/privacy/policy/
• Google: https://policies.google.com/technologies/ads

5.4 Integration with third-party AI model providers

Our AI tools use large language models provided by third parties, such as OpenAI, Anthropic, Google and DeepSeek, to generate responses to your inputs. The following information explains how this affects your data:

• Data collected: When you use an AI tool, the text you enter is sent to the provider of the model you select. The provider processes your input to generate a response, which is then displayed on the Website.
• Purpose of data processing: The data is used to generate responses to your inputs in real time and to operate and secure the feature.
• Data security: We use secure transmission methods to ensure your data is encrypted during transmission. Model providers also implement their own security measures.
• User consent: By using our AI tools, you consent to the processing of your inputs by the selected model provider. If you do not agree with this, please do not use the AI tools.
• Sensitive information: Please do not enter sensitive personal information, such as health, financial account or government identification details, into the AI tools.
• Feedback and moderation: If you encounter any inappropriate content, please report it to us at support@ocean-ai.co. We review and address all reports promptly.

For more information on how each provider handles your data, please refer to the privacy policy of that provider.

5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6. Cookies and similar technologies

6.1 We and our partners use cookies, local storage, pixels and similar technologies to keep you signed in, to save your progress in the onboarding quiz, to remember your preferences, to measure the performance of our Website and advertising, and to show you relevant advertising.

6.2 You can control cookies through your browser settings and, where available, through the consent options we show on the Website. Blocking some cookies may affect how the Website works, for example you may need to start the onboarding quiz again.

7. International transfers

7.1 We are established in Cyprus, and our Website is hosted in Cyprus and other locations where our service providers operate. If you access the Website from a region with laws governing personal data that differ from those in Cyprus, your data may be transferred to, stored and processed in Cyprus and in other countries where our service providers operate.

7.2 Where required, we use appropriate safeguards for such transfers, such as standard contractual clauses.

8. Retaining and deleting personal data

8.1 This Section 8 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

8.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We generally keep account data and learning data for as long as your account is active, and transaction data for as long as required by tax and accounting law.

8.3 You can ask us to delete your account and associated personal data at any time by writing to support@ocean-ai.co.

8.4 Notwithstanding the other provisions of this Section 8, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

9. Your rights

9.1 In this Section 9, we have listed the rights that you have under data protection law.

9.2 Your principal rights under data protection law are:

(a) the right to access - you can ask for copies of your personal data;

(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure - you can ask us to erase your personal data;

(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e) the right to object to processing - you can object to the processing of your personal data;

(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

9.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ .

9.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

10. Children

10.1 Our Website is intended for users who are at least 18 years old. We do not knowingly collect personal data from anyone under the age of 18. If you believe that a person under 18 has provided us with personal data, please contact us at support@ocean-ai.co and we will delete it.

11. Amendments

11.1 We may update this policy from time to time by publishing a new version on our Website.

11.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

11.3 We may notify you of significant changes to this policy by notification or email (if provided).

12. Our details

12.1 TIKI PUNCH APPLICATIONS LIMITED, a company with the registered office at 2 Sofouli Street, Chanteclair Building, Floor 8, Flat/Office 801, 1096 Nicosia, Cyprus, will be the controller of your personal data.

12.2 You can contact us:

(a) by post, to the postal address given above; or

(b) by email, using the email address published on our Website or support@ocean-ai.co.