Privacy Policy

Version of 11 September 2026

1. General provisions

1.1. This Policy explains what personal data Individual Entrepreneur Kateryna Viktorivna Badyko, operating under the trade name Lexoria Education (Lexoria Education), processes, for what purposes and on what legal grounds, how long the data is kept and what rights data subjects have.

1.2. Lexoria Education is the owner of personal data under the Law of Ukraine “On Personal Data Protection” and the data controller under the EU General Data Protection Regulation (GDPR).

1.3. This Policy applies to data received through:

the website https://lexoria.education (the Website);
the learning platform https://platform.lexoria.education (the Platform);
the Telegram bot @lexoria_education_bot;
Lexoria Education pages on Instagram and other social networks;
Telegram, WhatsApp, phone and email.

1.4. The terms Course, Student, Customer and Assessment have the meaning given in the Public Offer Agreement for Educational Services.

2. Data we process

2.1. Requests and consultations: name, phone number, email, messenger username, country of residence, chosen programme, learning goal.

2.2. Level test and Assessment: test answers, language level on the CEFR scale (Common European Framework of Reference for Languages), teacher’s notes.

2.3. Agreement and payment: full name, contact details, Course, payment data (amount, date, payer’s bank and account, payment reference). For legal entities and individual entrepreneurs: company details. We do not receive or store bank card data.

2.4. Studies on the Platform: login, login history, attendance, homework, test results, grades, teacher’s comments, certificate data. The Student’s image and voice if a Lesson is recorded.

2.5. Admission support under a separate agreement: passport data, photo, education documents and their translations, contact details of parents or a representative, chosen institution and major.

2.6. Technical data: IP address, device and browser type, language, pages viewed, referral source (including UTM tags, i.e. advertising link parameters), cookies as described in the Cookie Policy.

2.7. Reviews, photos and videos: name, country, review text, image. Published only with separate consent.

2.8. We do not request data on health, religious or political beliefs, racial or ethnic origin or other special categories of data. Please do not send us such data.

2.9. We receive data from the person, from a Customer paying for another person’s studies, or from a partner the person has asked to submit a request.

3. Purposes of processing

handling requests, consultations and Assessments;
concluding and performing the agreement, organising studies, Platform access, issuing certificates;
receiving payments, making refunds, tax accounting;
communication about schedules and the learning process;
admission support under a separate agreement;
sending news and offers, subject to consent;
analysing Website and advertising performance, improving services;
securing the Website and Platform, preventing fraud;
complying with the law and protecting Lexoria Education’s rights in disputes.

4. Legal grounds

4.1. Under Article 11 of the Law of Ukraine “On Personal Data Protection” and Article 6 of the GDPR, we process data on the following grounds:

consent: requests, newsletters, analytics and marketing cookies, publication of reviews, photos and videos;
concluding and performing a contract with the person: studies, Platform, certificate, refunds;
legal obligation: tax accounting, requests from public authorities;
legitimate interest of Lexoria Education: Website security, fraud prevention, handling complaints.

5. Who receives the data

5.1. We do not sell personal data. Data is accessed only by those who need it for the purposes in Section 3:

Lexoria Education teachers and assistants bound by confidentiality obligations;
hosting providers of the Website and the Platform;
the video conferencing service used for Lessons (Zoom, BigBlueButton or another);
Telegram, WhatsApp and Instagram when the person contacts us through them;
email, web analytics and advertising services within the consent given for the relevant cookies;
JSC UNIVERSAL BANK and payment services for payments and refunds;
an accountant for tax accounting;
higher education institutions and translators, only under an admission support agreement;
public authorities and courts where required by law.

5.2. Service providers process data on our behalf or under their own terms and privacy policies.

6. International transfers

6.1. Some services (video conferencing, messengers, social networks, cloud services) store data on servers outside Ukraine, including in EU countries and the USA.

6.2. Transfers are made under Article 29 of the Law of Ukraine “On Personal Data Protection”: to countries ensuring adequate protection of personal data, with the person’s consent, or where the transfer is needed to conclude or perform a contract in the person’s interest.

6.3. For persons located in the EU, we take into account Chapter V of the GDPR and choose services that apply EU Standard Contractual Clauses or other safeguards provided by the GDPR.

7. Retention periods

requests that did not lead to an agreement: 12 months from the last contact;
agreements, invoices, payment data: at least 1095 days from the deadline for filing tax reports for the relevant period, as required by the Tax Code of Ukraine;
study records and certificates: 3 years after the Course ends;
Lesson recordings: no longer than 30 calendar days after the Course ends;
admission support documents: the term of the agreement plus 1 year, unless the agreement states otherwise;
newsletter data: until consent is withdrawn;
cookies: as set out in the Cookie Policy.

After these periods, data is deleted or anonymised.

8. Your rights

8.1. Under Article 8 of the Law of Ukraine “On Personal Data Protection”, every person has the right to:

know the sources of collection, location of their data, purpose of processing, the owner and processors;
receive information about third parties to whom their data is transferred;
access their data;
receive an answer on whether their data is processed and what it contains within 30 calendar days of the request;
submit a reasoned objection to processing or a demand to correct or delete data that is processed unlawfully or is inaccurate;
be protected from unlawful processing, accidental loss or destruction of data;
withdraw consent at any time;
know how automated processing works and be protected from automated decisions with legal effects;
file complaints with the Ukrainian Parliament Commissioner for Human Rights or a court.

8.2. Persons located in the EU also have GDPR rights to restriction of processing, data portability and lodging a complaint with the data protection supervisory authority in their country of residence.

8.3. Withdrawal of consent does not affect the lawfulness of processing before withdrawal and does not apply to data we must keep by law.

8.4. Send requests about your data to [email protected]. To avoid disclosing data to the wrong person, we may ask you to confirm your identity.

9. Data security

9.1. The Website and Platform use a secure HTTPS connection. Access to data on the Platform is role-based (administrator, teacher, Student) and protected by individual passwords. Teachers and assistants can access only the data of their own groups and must keep it confidential.

9.2. In the event of a data breach that may affect people’s rights, we notify the people concerned and take steps to limit the consequences.

10. Persons under 18

10.1. Lexoria Education services are intended for persons aged 18 and over. Data of persons under 18 is processed only with the consent of a parent or legal guardian.

11. Newsletters

11.1. We send news and offers only to those who have agreed to receive them. You can unsubscribe via the link in the email or by contacting us through any channel.

12. Third-party links

12.1. The Website may contain links to third-party resources. Lexoria Education is not responsible for their data practices.

13. Changes to this Policy

13.1. We may update this Policy. The new version takes effect on the day it is published on the Website. The version date is shown at the top of the document.

14. Contact

Data controller: Individual Entrepreneur Kateryna Viktorivna Badyko (Lexoria Education)

Address: 2A Lihinska St., Odesa, 65038, Ukraine

Email: [email protected]

Phone: +380 96 902 60 91