LEARNMYO PRIVACY POLICY

This Privacy Policy explains how LearnMyo collects, uses, stores and otherwise processes personal data when you visit the LearnMyo website, create an account, purchase or use courses, communicate with us, or otherwise use the LearnMyo platform.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the GDPR), the laws of the Republic of Lithuania and other applicable data protection laws.

1. Data Controller

The LearnMyo platform is operated by:

UAB “Advansis LT”
Company registration number: 303127696
VAT number: LT100007971119
Registered address: Perkūnkiemio g. 19, Vilnius,  LT-12120, Lithuania
Email for privacy-related matters: info@learnmyo.com

In this Privacy Policy, UAB “Advansis LT” is also referred to as “LearnMyo”, “we”, “us”, “our” or the “Data Controller”.

LearnMyo determines the purposes and means by which the personal data described in this Privacy Policy is processed and therefore generally acts as the data controller.

2. Who This Privacy Policy Applies To

This Privacy Policy applies to personal data that we process about:

• visitors to the LearnMyo website;

• registered LearnMyo users;

• course purchasers and participants;

• professionals and other learners;

• LearnMyo Experts and content creators;

• persons who contact LearnMyo;

• newsletter recipients;

• other persons who interact with the LearnMyo Platform.

3. Personal Data We May Process

Depending on how you use LearnMyo, we may process the following categories of personal data.

3.1. Registration and Account Data

When you create a LearnMyo account, we may process:

• first name;

• last name;

• email address;

• account identifier;

• selected language;

• country;

• professional information, if provided;

• account creation and last login information;

• account status.

Passwords should not be stored in plain text and are processed using appropriate authentication and security measures.

3.2. Purchase and Billing Data

When you purchase a course or another LearnMyo product, we may process:

• first and last name;

• email address;

• billing address;

• country;

• company name, where applicable;

• company registration number and/or VAT number, where applicable;

• purchased course or service;

• order number;

• price;

• currency;

• applicable VAT;

• payment status;

• payment transaction identifier;

• purchase and payment date;

• invoice information;

• refund and payment dispute information.

Payment card details are generally processed directly by our payment service provider. LearnMyo generally does not receive or store your full payment card number or card security code.

3.3. Learning and Course Usage Data

When you use LearnMyo courses, we may process:

• information about purchased courses;

• course start and completion information;

• learning progress;

• lessons viewed;

• assignments or tests completed;

• test results, where applicable;

• course completion status;

• information about certificates issued;

• learning activity time and other information related to course usage.

We use this data to provide the learning service, save your progress and, where applicable, issue a course completion certificate.

3.4. Professional Profile Data

If the Platform allows users or Experts to create a professional profile, we may process:

• profession;

• specialization;

• qualifications;

• professional experience;

• workplace;

• professional organizations;

• certificates;

• profile photo;

• biography;

• country or city;

• professional links and other voluntarily provided professional information.

If any part of such information is published publicly, the user must be clearly informed before publication which information will be public.

3.5. Expert Data

If you are a LearnMyo Expert or content creator, we may additionally process information necessary for cooperation, including:

• contact details;

• professional information;

• qualification and experience information;

• contractual data;

• information required for payments;

• information about amounts payable and paid;

• tax information;

• course authorship information;

• profile information;

• photographs and other materials that we are entitled to use on the Platform under the relevant agreement.

3.6. Communication Data

When you contact us by email, contact form or other channels, we may process:

• name;

• email address;

• message content;

• communication history;

• information necessary to resolve your enquiry.

3.7. Reviews and User-Submitted Content

If you submit through the Platform:

• a course rating;

• a review;

• a comment;

• a question;

• other user-generated content,

we may process this content together with the information necessary to associate it with your account.

If a review will be displayed publicly, this must be clearly communicated before it is published.

3.8. Technical and Security Data

When using the Platform, certain technical data may be automatically collected, such as:

• IP address;

• device type;

• operating system;

• browser type;

• login time;

• session information;

• approximate geographic information determined from the IP address;

• technical error information;

• security events;

• other technical log data.

This information may be necessary for the operation and security of the Platform, fraud prevention and identification of technical problems.

4. Special Categories of Data and Health Information

LearnMyo is a professional learning and educational platform.

LearnMyo is not intended for storing patient medical records, diagnoses, treatment plans or other individual health information.

Please do not upload or provide patient or other third-party health data through the LearnMyo Platform, except where a specific Platform feature expressly provides for such data processing and an appropriate legal basis and safeguards have been established.

Where clinical examples are used in learning discussions, users should ensure that the information is properly anonymized and that a specific patient cannot be identified from it.

5. Purposes and Legal Bases for Processing Data

We process personal data only where we have a lawful basis for doing so.

5.1. Account Creation and Management

We process data in order to:

• create and administer an account;

• authenticate the user;

• provide access to purchased courses;

• save learning progress;

• provide Platform functionality.

Legal basis: performance of a contract or steps taken prior to entering into a contract – Article 6(1)(b) GDPR.

5.2. Provision of Courses and Digital Services

We process data in order to:

• provide access to a course;

• record progress;

• administer learning activities;

• issue course completion certificates, where applicable;

• provide course-related support.

Legal basis: performance of a contract – Article 6(1)(b) GDPR.

5.3. Payments and Orders

We process data in order to:

• accept and administer payments;

• confirm orders;

• administer refunds;

• resolve payment disputes;

• issue invoices.

Legal basis: performance of a contract – Article 6(1)(b) GDPR, as well as compliance with legal obligations – Article 6(1)(c) GDPR, where we are required to process data for accounting, tax or other purposes established by law.

5.4. Customer Support

We process data in order to respond to questions, resolve technical issues, administer complaints and provide support.

Depending on the situation, the legal basis may be:

• performance of a contract – Article 6(1)(b) GDPR; or

• our legitimate interest in properly administering LearnMyo operations and communications – Article 6(1)(f) GDPR.

5.5. Compliance with Legal and Tax Obligations

We process and retain certain data in order to:

• comply with accounting and tax obligations;

• comply with consumer protection requirements;

• respond to lawful requests from public authorities;

• comply with other legal obligations.

Legal basis: compliance with a legal obligation – Article 6(1)(c) GDPR.

5.6. Platform Security and Fraud Prevention

We may process technical and other necessary data in order to:

• protect user accounts;

• identify unauthorized logins;

• prevent fraud;

• protect Platform infrastructure;

• identify misuse;

• investigate security incidents.

Legal basis: our legitimate interest in ensuring the security of the Platform and its users – Article 6(1)(f) GDPR.

5.7. Defence of Legal Claims

We may process data to the extent reasonably necessary to protect our rights and legitimate interests, bring claims or defend against claims.

Legal basis: our legitimate interest – Article 6(1)(f) GDPR, as well as other applicable legal bases.

5.8. Newsletters and Direct Marketing

If you subscribe to the LearnMyo newsletter or otherwise provide the required consent, we may use your email address to send information about:

• new courses;

• new Experts;

• learning opportunities;

• LearnMyo news;

• special offers.

Where marketing is based on your consent:

Legal basis: consent – Article 6(1)(a) GDPR.

You may withdraw your consent at any time, for example by clicking the unsubscribe link included in the newsletter.

Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

6. Cookies and Similar Technologies

LearnMyo may use cookies and similar technologies.

Some cookies are necessary for the proper functioning of the Platform, for example for:

• login sessions;

• authentication;

• security;

• the purchase process;

• saving user preferences.

Non-essential cookies, such as analytics or marketing cookies, are used only where and to the extent that we have the legal basis required under applicable law and, where necessary, your consent.

Users must be able to manage their cookie preferences.

More detailed information about the specific cookies used by LearnMyo, their providers, purposes and duration is provided in a separate Cookie Policy and/or in the cookie settings interface.

7. Payment Service Providers

LearnMyo may use third-party payment service providers, including Stripe, to process payments.

When making a payment, information necessary to process the payment, detect fraud, ensure security and comply with legal requirements may be transmitted to the relevant payment service provider.

Depending on the specific processing activity, the payment service provider may act as our data processor and/or as an independent data controller.

The processing of data by payment service providers may also be subject to their own privacy terms.

8. Who We May Share Your Personal Data With

We may share personal data only to the extent necessary for a specific purpose.

Recipients or categories of recipients may include:

• IT infrastructure and hosting service providers;

• database and authentication service providers;

• payment service providers;

• email and communication service providers;

• analytics service providers, where such services are lawfully used;

• accounting and financial service providers;

• legal and other professional advisers;

• LearnMyo Experts, where sharing certain information is necessary to provide a specific learning service;

• competent public authorities where we are required by law to provide the data;

• other service providers that help us operate the LearnMyo Platform.

Where a third party processes personal data on our behalf as a data processor, we seek to ensure that agreements compliant with GDPR requirements are in place and that appropriate data protection safeguards are applied.

We do not sell your personal data as a commodity to third parties.

9. Data Shared with Experts

LearnMyo is the seller of courses and the operator of the Platform; however, in certain cases a course Expert may require limited information about course participants, for example where:

• a live seminar or webinar takes place;

• the Expert answers participants' questions;

• an assignment needs to be assessed;

• the Expert provides another learning function specified in the particular course.

In such cases, only the data reasonably necessary to perform the relevant function is shared with the Expert.

Experts are not permitted to use LearnMyo user data for their own independent marketing unless the user has separately consented to this or another appropriate legal basis exists.

10. Transfers of Data Outside the European Economic Area

Some of our technology or service providers may operate or process data outside the European Economic Area (EEA).

Where personal data is transferred to a country outside the EEA, we ensure that the transfer is carried out in accordance with the requirements of Chapter V of the GDPR.

Depending on the circumstances, this may include:

• a European Commission adequacy decision;

• Standard Contractual Clauses (SCCs) approved by the European Commission;

• the EU–US Data Privacy Framework, where lawfully applicable to the recipient;

• other appropriate safeguards or lawful derogations provided for under the GDPR.

Where necessary, we apply additional technical, organizational or contractual safeguards.

11. How Long We Retain Personal Data

We retain personal data no longer than necessary for the purposes for which it was collected or for as long as required by law.

Indicative retention principles:

Account Data

Generally retained while the account remains active and, after closure of the account, for as long as reasonably necessary to comply with legal obligations, resolve disputes, ensure security and defend legal claims.

Learning Data

Generally retained for the duration of the account and the use of the relevant learning service, and for a reasonable period thereafter, taking into account certificate verification, contractual relationships and other legitimate purposes.

Order, Invoice and Accounting Data

Retained for the period required by law. VAT invoices and related data are retained for 10 years from the date of issue where required under Lithuanian law.

Customer Support Communications

Retained for as long as necessary to resolve the enquiry and for a reasonable period after its resolution, taking into account the nature of the enquiry and potential legal claims.

Marketing Data

Where marketing is based on consent, data is generally processed until consent is withdrawn or for as long as another lawful basis exists for retaining it.

Security Logs

Technical and security logs are retained for as long as reasonably necessary for Platform security, incident investigation and prevention of misuse.

At the end of the retention period, data is deleted or appropriately anonymized, except where we are required or entitled to retain it further under applicable law.

12. How We Protect Your Data

We apply appropriate technical and organizational security measures, taking into account the nature of the data, the risks of processing and the technologies used.

Such measures may include:

• access controls;

• user authentication;

• encryption of data in transit;

• restriction of access rights;

• backups;

• activity and security logs;

• software and infrastructure updates;

• oversight of data processors and service providers;

• other organizational and technical safeguards.

However, no system operating over the internet can guarantee absolute security.

13. Automated Decision-Making

LearnMyo currently does not use decision-making based solely on automated processing of personal data that produces legal effects concerning the user or similarly significantly affects the user, as defined in Article 22 GDPR, unless explicitly stated otherwise in the description of a specific Platform feature.

If we begin using such automated decision-making in the future, we will provide affected persons with the information required under the GDPR.

14. Children's Privacy

LearnMyo is primarily intended for adult professionals and learners.

Paid LearnMyo products may only be purchased independently by persons aged 18 or over or by representatives of legal entities who have the authority to enter into the relevant agreement.

If certain LearnMyo services are offered directly to minors in the future, their personal data will be processed in accordance with the GDPR and applicable Lithuanian and other relevant national legal requirements concerning the protection of children's data.

15. Your Rights

Under the GDPR, depending on the specific circumstances, you may have the following rights:

Right to Be Informed

To receive clear information about how your personal data is processed.

Right of Access

To obtain confirmation as to whether we process your personal data and to receive a copy of that data together with other information required under the GDPR.

Right to Rectification

To request correction of inaccurate personal data or completion of incomplete personal data.

Right to Erasure

In certain circumstances, to request the deletion of your personal data.

This right is not absolute. For example, we cannot delete data that we are legally required to retain.

Right to Restriction of Processing

In circumstances provided for under the GDPR, to request restriction of the processing of your data.

Right to Data Portability

Where data is processed by automated means on the basis of consent or a contract, in certain circumstances you may receive the data you have provided in a structured, commonly used and machine-readable format or request that it be transferred to another data controller where technically feasible.

Right to Object

Where we process data on the basis of legitimate interests, in certain circumstances you have the right to object to such processing on grounds relating to your particular situation.

Where personal data is processed for direct marketing purposes, you have the right to object to such processing at any time.

Right to Withdraw Consent

Where we process data on the basis of your consent, you may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

Rights Related to Automated Decision-Making

In circumstances provided for under the GDPR, you have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

16. How to Exercise Your Rights

To exercise your rights or ask a question regarding the processing of personal data, please contact:

info@learnmyo.com

Please provide sufficient information in your request so that we can understand your request and, where necessary, reasonably verify your identity.

We will not request more identity information than is reasonably necessary to verify your identity.

We will respond to a properly submitted request within the period established by the GDPR – generally within one month. In complex cases, this period may be extended in accordance with the GDPR.

17. Right to Lodge a Complaint

If you believe that your personal data is being processed in violation of applicable data protection laws, you have the right to lodge a complaint with the competent supervisory authority.

In Lithuania, this is:

State Data Protection Inspectorate (VDAI)
L. Sapiegos g. 17, Vilnius,  LT-10312, Lithuania

Website: vdai.lrv.lt

You may also have the right to lodge a complaint with the data protection supervisory authority in the EU / EEA country in which you have your habitual residence, place of work, or where you believe an alleged data protection infringement has occurred.

18. Changes to the Privacy Policy

We may update this Privacy Policy from time to time, for example:

• when LearnMyo features change;

• when we begin using new service providers;

• when data processing activities change;

• when laws or requirements of supervisory authorities change.

The latest version of the Privacy Policy will always be published on the LearnMyo Platform.

The date of the latest update is indicated at the top of the Policy.

If the changes are material and required under applicable law, we will provide additional notice in an appropriate manner.

19. Relationship with Other LearnMyo Documents

This Privacy Policy should be read together with:

• LearnMyo Terms & Conditions;

• LearnMyo Cookie Policy;

• specific consents or privacy notices that may be provided when using individual Platform features.

Where an additional privacy notice is provided for a specific feature, it supplements this Privacy Policy in relation to that feature.

20. Contact Details

For any questions regarding privacy, personal data processing or your rights, please contact:

LearnMyo / UAB “Advansis LT”
Perkūnkiemio g. 19, Vilnius,  LT-12120
Lithuania

Email: info@learnmyo.com