Privacy policy
Data Controller MB “Luxagente” Legal entity registration number: 307409593 Address: Z. Gerulaičio g. 4–34, LT-45391 Kaunas, Lithuania Email: info@luxrepetitor.ai Website:https://luxrepetitor.ai (hereinafter referred to as the Company, the Platform or we)
1. General Provisions
This Privacy Policy explains how MB “Luxagente” collects, uses, stores and otherwise processes personal data when you use the LuxRepetitor Platform and the services it provides. This Privacy Policy applies to all users of the Platform, including:
students;
parents and guardians;
tutors;
representatives of legal entities;
participants in the Affiliate Programme;
registered and unregistered visitors to the website. By using the Platform, you confirm that you have read and understood this Privacy Policy. The Platform complies with:
the General Data Protection Regulation (EU) 2016/679 (GDPR);
the Law on Legal Protection of Personal Data of the Republic of Lithuania;
other applicable legislation of the European Union and the Republic of Lithuania.
2. Personal Data We Collect
We process only the personal data necessary for the operation of the Platform, the provision of services, compliance with legal obligations and improvement of the Platform.
2.1. Registration Data When you register on the Platform, we may collect:
first name;
surname, where applicable;
email address;
telephone number, if provided;
account identifier;
hashed password.
2.2. AI Tutor Usage Data When you use the AI Tutor, we may process:
conversation history;
questions submitted;
AI-generated responses;
learning topics;
completed tasks;
learning progress;
personalised learning recommendations;
statistics relating to the use of AI features;
the subject and year group selected by the User, where this information is provided. This data is used to ensure the operation of the AI Tutor, personalise the learning experience and improve the quality of the service.
2.3. One-to-One Lesson Data When you use the one-to-one lesson booking system, we may process:
booking information;
selected Tutor;
selected subject;
lesson dates and times;
booking status;
payment status;
lesson history;
automatically generated lesson summaries;
information required for handling disputes. The Platform processes only the data necessary for organising one-to-one lessons.
2.4. Payment Data We process only such payment information as is necessary for the administration of services and compliance with legal obligations. This may include:
selected plan;
subscription status;
invoice details;
payment status;
transaction identifier;
payment date. Payment card details and other payment instrument information are processed only by licensed payment service providers. The Platform does not receive or store such data.
2.5. Communication Data We may process:
email correspondence;
communications through the Platform’s chat system;
support requests;
complaints;
feedback;
other information that you voluntarily provide when communicating with us.
2.6. Technical Data We automatically collect:
IP address;
browser type;
operating system;
device type;
login time;
session identifiers;
error logs;
statistics relating to the use of the Platform. This data is used to ensure the security and operational stability of the Platform.
2.7. Cookies and Similar Technologies The Platform uses cookies and similar technologies that enable us to:
ensure the proper operation of the Platform;
remember user preferences;
analyse website traffic;
improve the user experience;
carry out marketing activities where you have given your consent. Detailed information is provided in Section 9 of this Privacy Policy.
2.8. Data Obtained from Third Parties In certain cases, we may receive data from third parties, for example:
licensed payment service providers;
payment administration service providers;
Affiliate Programme administration systems;
other service providers required for the operation of the Platform.
3. Purposes and Legal Bases for Processing Personal Data
We process personal data only where we have a lawful basis for doing so under the GDPR.
3.1. Entering into and Performing a Contract(Article 6(1)(b) of the GDPR) Personal data is processed in order to:
create and administer a user account;
provide access to the AI Tutor;
organise one-to-one lessons;
administer bookings;
administer payments;
generate lesson summaries;
ensure the functionality of the Platform.
3.2. Compliance with a Legal Obligation(Article 6(1)(c) of the GDPR) Personal data is processed in order to:
comply with accounting requirements;
comply with tax obligations;
retain accounting documents;
respond to lawful requests from public authorities;
comply with other requirements established by applicable law.
3.3. Legitimate Interests(Article 6(1)(f) of the GDPR) We process personal data in order to:
protect the Platform against fraud;
ensure the security of information systems;
analyse the operation of the Platform;
handle disputes;
ensure quality control;
improve the operation of the AI Tutor, learning recommendations and the quality of artificial intelligence models;
improve the functionality of the Platform. Where possible, anonymised or aggregated data is used for statistical and analytical purposes.
3.4. Consent(Article 6(1)(a) of the GDPR) We process personal data on the basis of your consent when:
sending newsletters;
using analytical cookies;
using marketing cookies;
sending promotional offers;
processing other data for which consent is required by applicable law. You may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the consent was withdrawn.
4. Who We May Share Your Personal Data With
We do not sell your personal data or share it with third parties for their own marketing purposes. Your personal data may only be shared where this is necessary for the operation of the Platform, compliance with legal obligations or the protection of our legitimate interests.
4.1. Payment Service Providers We use licensed payment service providers to administer payments. Depending on the service used, personal data may be shared with:
OPAY;
ComplyPay;
banks;
other licensed payment institutions. These service providers process personal data as independent data controllers or data processors in accordance with their respective privacy policies.
4.2. Information Technology Service Providers For the operation of the Platform, we may use third-party services such as:
server hosting services;
cloud computing services;
database services;
email delivery services;
analytics systems;
technical maintenance services. Such service providers process only the data necessary to provide their services. Where required by the GDPR, data processing agreements are entered into with all personal data processors, or other appropriate safeguards required by applicable law are implemented.
4.3. Artificial Intelligence Service Providers In order to ensure the operation of the AI Tutor, some information provided by the User may be shared with artificial intelligence technology providers. Such data is used only for:
generating responses;
completing learning tasks;
preparing learning recommendations;
performing other AI functions. The Platform shares only the data necessary to process a specific AI request and seeks to avoid sharing excessive personal data. AI service providers may not use the data shared with them for their own purposes, except where this is expressly provided for in their terms of service or permitted by applicable law.
4.4. Tutors When a User books a one-to-one lesson, only the data necessary to organise the lesson is shared with the selected Tutor. This may include:
first name;
booking information;
selected subject;
communications through the Platform’s chat system;
other information that the User provides directly to the Tutor. Tutors undertake to use the personal data received solely for the purpose of providing one-to-one tutoring services and to comply with applicable personal data protection requirements.
4.5. Public Authorities Where required by law, personal data may be disclosed to:
courts;
law enforcement authorities;
the State Tax Inspectorate;
the State Data Protection Inspectorate;
other competent authorities. Personal data is disclosed only to the extent required by applicable law or by lawful requests from competent authorities.
5. How Long We Retain Your Personal Data
We retain personal data only for as long as necessary to provide our services, comply with applicable legal obligations, or protect our legal rights. Personal data retention periods: Lesson-related data is retained for 48 hours after the lesson has ended. If neither the student nor the teacher submits a complaint (dispute) during this period, the lesson-related data will be deleted. If a complaint (dispute) is submitted within 48 hours, the data will be retained until the complaint has been reviewed and resolved, after which it will be deleted, unless applicable laws require a longer retention period or the data is necessary for the establishment, exercise, or defence of legal claims. AI Tutor conversation and learning history – for as long as the User’s account remains active or until the User initiates the deletion of their account or the relevant data. One-to-one lesson booking history – for up to 1 year from the completion of the lesson or booking. Platform chat system history – for up to 6 months from the last communication. Customer support requests – fo r up to 1 year from the date on which the request is resolved. Information relating to disputes, complaints and legal claims – for as long as necessary to handle the relevant dispute, complaint or legal claim and for the establishment, exercise or defence of legal claims. Accounting, invoicing and payment documents – for the mandatory retention period prescribed by applicable law. Technical and security data – for as long as necessary to ensure the security of the Platform and to identify and resolve technical issues, but generally for no longer than 12 months, except where longer retention is necessary to investigate a security incident or for the establishment, exercise or defence of legal claims. Once the applicable retention periods have expired, personal data is deleted or anonymised, except where it must be retained for a longer period under applicable law or for the establishment, exercise or defence of legal claims. Where the same personal data is processed for several different purposes, it may be retained until the longest reasonable or legally required retention period applicable to the relevant processing purpose has expired.
6. Your Rights
Under the GDPR, you have the right to:
receive information about the processing of your personal data;
access your personal data;
request the rectification of inaccurate personal data;
request the deletion of personal data (the “right to be forgotten”), where permitted by law;
restrict the processing of your personal data;
object to the processing of your personal data where the processing is based on legitimate interests;
receive the personal data you have provided to us in a structured, commonly used and machine-readable format (data portability);
withdraw your consent at any time;
lodge a complaint with the State Data Protection Inspectorate. If you wish to exercise your rights, you may contact us by email at luxagente@gmail.com. We will respond to your request within the time limits prescribed by applicable law.
7. Personal Data Security
The Platform implements organisational and technical security measures designed to protect personal data against:
unauthorised access;
loss;
destruction;
alteration;
unlawful disclosure. The measures used may include:
SSL/TLS data encryption;
access control mechanisms;
password hashing;
backup systems;
access logging;
security monitoring. Despite the measures implemented, no information system can guarantee absolute security. The User must therefore also protect their login details and must not disclose them to third parties.
8. Transfers of Personal Data Outside the European Economic Area
Some technologies or service providers used by the Platform may process personal data outside the European Economic Area (EEA). In such cases, the Platform ensures that personal data is transferred only in accordance with the requirements of the GDPR and subject to appropriate safeguards, such as:
European Commission adequacy decisions or other recognised transfer mechanisms;
Standard Contractual Clauses (SCCs);
other safeguards provided for by applicable law. When selecting service providers, the Platform seeks to ensure that personal data is processed in accordance with the requirements of the GDPR and subject to appropriate organisational and technical safeguards.
9. Cookie Policy
9.1. What Are Cookies? Cookies are small text files stored on the User’s computer, telephone or other device when they visit the Platform. Cookies enable the Platform to:
function properly;
recognise a logged-in User;
save the User’s settings;
ensure the security of the Platform;
analyse the use of the Platform;
improve the functionality of the Platform.
9.2. What Cookies Do We Use? The following categories of cookies may be used on the Platform. Strictly Necessary Cookies These cookies are necessary for the proper operation of the Platform. They are used for:
logging into an account;
user authentication;
maintaining a session;
ensuring security;
the booking process;
payment administration. Without these cookies, the Platform would not be able to function properly. The User’s consent is not required for these cookies. Functional Cookies These cookies enable the Platform to remember the User’s preferences. For example:
language;
login status;
selected theme;
most recent AI Tutor settings;
other individual settings. Analytics Cookies Analytics cookies help us understand how the Platform is used. They may be used to collect information about:
the number of visits;
the most popular pages;
use of the AI Tutor;
the most frequently used features;
booking statistics;
technical errors. This data is used solely to improve the Platform. Analytics cookies are used only with the User’s consent where such consent is required by applicable law. Marketing Cookies Where marketing tools are used on the Platform, marketing cookies may be used. They may be used for:
measuring advertising effectiveness;
analysing advertising campaigns;
operating the Affiliate Programme;
tracking conversions. Such cookies are used only with the User’s consent.
9.3. Third-Party Cookies Third-party technologies may be used on the Platform. Depending on the services used, cookies may be set by:
Google Analytics;
Google Tag Manager;
Meta Pixel;
YouTube;
OPAY;
ComplyPay;
technologies provided by AI service providers, where they use cookies or similar technologies;
other technology service providers used by the Platform. The use of these cookies is governed by the privacy policies of the relevant service providers.
9.4. How Can You Manage Cookies? When visiting the Platform for the first time, the User is shown a notice regarding the use of cookies. The User may:
accept all cookies;
reject non-essential cookies;
select individual categories of cookies. The User may change their choices at any time through the Platform’s cookie settings.
9.5. Disabling Cookies Most internet browsers allow Users to:
view cookies in use;
delete cookies;
block new cookies. Please note that disabling strictly necessary cookies may prevent some Platform features from functioning properly. This may affect:
logging in;
operation of the AI Tutor;
one-to-one lesson bookings;
payments;
other Platform features.
9.6. Analytics Information The Platform may collect aggregated statistical information about the use of the Platform. Such information is used to:
improve the quality of the Platform;
improve AI Tutor features;
analyse performance;
improve the user experience. Where possible, such data is anonymised or pseudonymised.
9.7. Changes to the Cookie Policy The Platform may periodically update this section of the Cookie Policy. The updated version will be published on the Platform. We recommend that Users periodically review the latest version of the Privacy Policy.
10. Protection of Minors’ Personal Data
LuxRepetitor is an educational platform intended for students, and we therefore pay particular attention to the protection of minors’ personal data. Persons under the age of 14 may use the Platform only through the account of their parent or legal guardian, or with their consent where required by applicable law. Parents or legal guardians are responsible for:
the accuracy of the data provided during registration;
the minor’s use of the Platform;
booking one-to-one lessons;
making payments;
the accuracy of data provided by the minor;
the minor’s use of the AI Tutor. If it becomes apparent that personal data has been collected in breach of applicable law, the Platform has the right to delete such data or restrict its processing.
11. Specific Aspects of AI Tutor Data Processing
The AI Tutor used on the Platform is a standalone digital learning service. When using the AI Tutor, the following data may be processed:
questions submitted by the User;
AI-generated responses;
learning history;
selected topics;
learning progress data;
personalised recommendations. This data is used to:
ensure the operation of the AI Tutor;
generate responses;
personalise the learning process;
improve the quality of the Platform’s services;
identify and resolve technical errors. The Platform seeks to share with AI service providers only the data necessary to process a specific request and to avoid sharing excessive personal data. AI Tutor responses are generated automatically using artificial intelligence technologies. Although the Platform seeks to ensure that responses are as accurate as possible, AI may provide inaccurate, incomplete or outdated information. The User should therefore not rely on AI-generated responses as their sole source of information. The AI Tutor is not a human tutor or an official educational institution and does not replace one-to-one tutoring services provided by independent Tutors. The AI Tutor is not intended to provide financial, legal, medical or other professional advice.
12. Processing of Data in the Affiliate Programme
If the User participates in the LuxRepetitor Affiliate Programme, the Platform may process additional data required to administer the Programme. This may include:
Affiliate identification data;
referral links (Referral ID);
statistics relating to referred users;
calculated commission;
payment information;
payment history. This data is used solely for:
administration of the Affiliate Programme;
calculation of commission;
making payments;
fraud prevention;
compliance with legal obligations. The Affiliate Programme may use cookies or unique referral links to identify users referred by an Affiliate.
13. Links to Third-Party Websites
The Platform may contain links to websites or services operated by third parties. We are not responsible for the content, privacy policies or data processing practices of such websites. We recommend that you review the relevant privacy policies before using third-party services.
14. Changes to this Privacy Policy
The Platform may update this Privacy Policy at any time. The updated version of the Privacy Policy will be published on the Platform. Where required by applicable law, registered Users may also be notified of material changes by email or through other means used by the Platform. The updated Privacy Policy will apply from its effective date. We encourage Users to review the Privacy Policy periodically to remain informed about how personal data is processed.
15. Contact Information
If you have any questions regarding this Privacy Policy or wish to exercise your rights under the General Data Protection Regulation (GDPR), you may contact: MB “Luxagente” Legal entity registration number: 307409593 Email: luxagente@gmail.com Website: luxrepetitor.ai
16. Final Provisions
This Privacy Policy is governed by the laws of the Republic of Lithuania and the legislation of the European Union governing the protection of personal data. If any provision of this Privacy Policy is found to be invalid or unenforceable, this will not affect the validity of the remaining provisions. Any disputes arising from the application of this Privacy Policy shall first be resolved through negotiation. If no agreement can be reached, disputes shall be resolved in accordance with the laws of the Republic of Lithuania.