Privacy Policy – Learnico.io

1. General information

1. This Privacy Policy sets out the rules for processing personal data of users of the Learnico.io Application.
2. This Policy has been prepared in accordance with Regulation (EU) 2016/679 (GDPR).

2. Data controller

1. The controller of personal data is Piotr Kosoń, conducting business under the name GHackers Piotr Kosoń, ul. Wizjonerów 2/39, 31-356 Kraków, Poland, NIP (tax ID): 5130109703, REGON: 123111371.
2. Contact: hello@learnico.io.

3. Categories of personal data

1. Depending on how the Application is used, the Controller may process:
   • identification and contact data (e.g., name, surname, e-mail),
   • account and authentication data,
   • data related to activity within the Application (e.g., course content, schedules, activity history),
   • student data entered by teachers,
   • parent and child data where accounts are created for persons under 18,
   • billing and transactional data,
   • technical data (e.g., IP address, device identifiers, logs, browser information).
2. Card payment data is processed directly by external payment providers (e.g., Stripe) in accordance with their own privacy policies.

4. Purposes and legal bases

1. Personal data is processed for the purposes of:
   • concluding and performing the digital services agreement (Art. 6(1)(b) GDPR),
   • handling payments, settlements, and accounting/tax obligations (Art. 6(1)(c) GDPR),
   • ensuring security of the Application, preventing abuse, and pursuing claims (Art. 6(1)(f) GDPR),
   • communication with users, support, and handling requests (Art. 6(1)(b) and (f) GDPR),
   • analytics and statistics (Art. 6(1)(f) GDPR),
   • marketing communications – where required, based on consent (Art. 6(1)(a) GDPR).

5. AI and data processing

1. The Application offers AI features supporting educational content planning and creation.
2. Data entered into AI features may be sent to external AI service providers.
3. Data sent to AI features is not used for model training by the Service Provider.
4. AI features are available only to users of paid plans.

6. Data recipients

1. Personal data may be shared with processors acting on behalf of the Controller, in particular providers of:
   • hosting and IT infrastructure,
   • payments (including Stripe),
   • e-mail communication,
   • analytics and monitoring,
   • AI tools used by the Application.
2. Data may also be disclosed to entities authorized under applicable law.

7. Transfers outside the EEA

1. Due to the use of technology providers, personal data may be transferred outside the European Economic Area.
2. The Controller ensures appropriate transfer safeguards, in particular Standard Contractual Clauses or another mechanism compliant with GDPR.

8. Data retention period

1. Data is stored for as long as necessary to fulfill the processing purposes.
2. Account-related data is generally stored for the term of the Agreement.
3. After the Agreement ends, data may be retained for up to 90 days to enable export, and then deleted, subject to legal and tax obligations.
4. Accounting and billing data is retained for the period required by law.

9. Data subject rights

1. Data subjects have the right to:
   • access personal data,
   • rectify personal data,
   • erase personal data,
   • restrict processing,
   • data portability,
   • object to processing,
   • withdraw consent at any time (where processing is based on consent).
2. Data subjects also have the right to lodge a complaint with the competent supervisory authority.

10. Children’s data

1. The Application is not intended for independent registration by persons under 18 years of age.
2. For users under 18, the account is created and managed by a parent or legal guardian, who provides the child’s data to the extent necessary to deliver the service.

11. Cookies and similar technologies

1. The Application uses cookies and similar technologies to ensure proper operation, security, and analytics.
2. Users can manage cookie settings via the mechanism available in the Application and browser settings.

12. Data security

1. The Controller applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

13. Changes to this Privacy Policy

1. The Controller may update this Privacy Policy due to legal, technological, or organizational changes.
2. The current version is published in the Application.

14. Contact

1. For all matters related to personal data processing, please contact: hello@learnico.io.