Privacy Policy

1. Introduction

This Privacy Policy explains how SIA LONET (“SIA LONET”, “we”, “our”, or “us”) collects, uses, stores, processes, shares, and protects personal data when you access or use our websites, digital platforms, applications, educational programmes, diagnostics, assessments, dashboards, workshops, AI-powered services, and other related services (collectively, the “Services”).

SIA LONET is committed to protecting your privacy and processing personal data fairly, lawfully, transparently, and securely in accordance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation — GDPR);
• applicable laws of the Republic of Latvia; and
• other applicable international data protection laws where relevant.

By accessing or using our Services, you acknowledge that you have read this Privacy Policy.

2. Data Controller

SIA LONET
Registration No.: 40203091983
Registered Office: Vidzemes aleja 3–63, Rīga, LV-1024, Latvia
Director: Kristine Baltaca
Legal contact by email: lonet@lonet.academy

3. Scope

This Privacy Policy applies to all digital products and services operated by SIA LONET, including but not limited to:

• Regenerative Human Systems™
• Regenerative Life Architecture™
• Regenerative Intelligence Platform (current and future)
• Lonet.Academy
• websites
• member portals
• learning platforms
• dashboards
• online diagnostics
• assessments
• tracking tools
• AI-assisted services
• educational resources
• workshops
• webinars
• mobile applications
• APIs
• future digital services developed by SIA LONET

4. Eligibility

Our Services are intended solely for individuals aged 18 years or older.

We do not knowingly collect personal information from children.

If we become aware that personal data has been submitted by an individual under 18 years of age, we reserve the right to remove such information without prior notice.

5. Categories of Personal Data We Collect

Depending on the Services you use, we may collect:

Identity Information

• first name
• last name
• age
• profession
• company
• job title
• country

Contact Information

• email address
• billing information
• correspondence with us

Account Information

• login credentials
• account preferences
• subscription status
• authentication information

Diagnostic & Assessment Information — when using our educational diagnostics and assessment tools, we may collect:

• questionnaire responses
• assessment scores
• progress indicators
• indexes
• reports
• self-assessments
• historical assessment data
• longitudinal progress information

Dashboard Information — where applicable, users may voluntarily store:

• observations
• reflections
• journals
• personal notes
• planning information
• goals
• experiments
• tracking information
• uploaded files
• educational exercises

Usage Information — we automatically collect information such as:

• browser type
• operating system
• IP address
• device information
• pages visited
• session duration
• clicks
• navigation behaviour
• platform interactions
• diagnostics usage
• dashboard usage
• feature usage

Communication Information

• emails
• support requests
• survey responses
• workshop registrations
• event participation

6. Special Categories of Data

Our Services are educational in their purpose and are not designed to collect health or medical information.

However, users may voluntarily enter personal reflections or notes that contain sensitive information.

If you choose to provide such information, it will be processed solely for providing the requested Services and improving your experience.

You remain responsible for deciding what information you choose to submit.

7. Purposes of Processing

We process personal data to:

• create and manage user accounts;
• provide educational programmes;
• deliver diagnostics and assessments;
• generate reports and insights;
• maintain user dashboards;
• enable historical progress tracking;
• personalise educational experiences;
• provide customer support;
• communicate regarding workshops and events;
• process registrations;
• process payments;
• improve our Services;
• conduct product research and development;
• develop new diagnostics and methodologies;
• improve AI-assisted functionality;
• perform analytics;
• ensure security;
• detect fraud;
• comply with legal obligations;
• send newsletters and marketing communications where permitted by law or consent has been provided.

8. AI-Assisted Processing

Some Services may use artificial intelligence technologies to assist in:

• analysing assessment responses;
• generating educational insights;
• preparing summaries;
• identifying patterns;
• generating recommendations;
• supporting educational content.

AI-generated outputs are intended exclusively for educational and informational purposes.

They do not constitute:

• medical advice;
• psychological advice;
• psychiatric advice;
• legal advice;
• financial advice;
• employment advice;
• clinical assessment;
• diagnosis;
• treatment recommendations.

SIA LONET does not make solely automated decisions that produce legal effects or similarly significant effects on individuals.

9. Legal Bases for Processing

Depending on the circumstances, we process personal data based on:

• your consent;
• performance of a contract;
• compliance with legal obligations;
• our legitimate interests;
• protection of vital interests where applicable.

10. Marketing Communications

Where you provide consent, we may send:

• educational materials;
• programme updates;
• diagnostic interpretations;
• intervention suggestions;
• event invitations;
• newsletters;
• marketing communications.

You may withdraw your consent at any time by using the unsubscribe link included in our communications or by contacting us.

Withdrawal of consent does not affect processing carried out before withdrawal.

11. Research, Benchmarking and Product Improvement

One of the objectives of SIA LONET is the continuous improvement of its educational frameworks, diagnostics, digital platforms and methodologies.

Accordingly, we may use information in an aggregated, anonymised or de-identified form for:

• research;
• benchmarking;
• statistical analysis;
• improving diagnostics;
• improving educational methodologies;
• improving AI systems;
• scientific publications;
• academic collaboration;
• product development;
• quality assurance.

Information used for these purposes will not identify individual users.

12. Cookies and Similar Technologies

Our Services use cookies and similar technologies to:

• operate the platform;
• remember preferences;
• improve performance;
• analyse traffic;
• enhance security;
• personalise user experience.

We use a single session cookie to keep you logged in. This cookie is strictly necessary and does not require consent under the ePrivacy Directive.

We use Google Analytics to understand overall site usage (pages visited, general location, device type). By default, before you make a choice on the cookie banner, we only receive anonymous, aggregated traffic data from Google — no cookies are set and you are not individually identifiable. If you accept via the cookie banner, Google Analytics additionally sets its own cookies to provide more complete, per-session analytics. Google Analytics is not required for the site to function. You can give, withdraw, or change your consent at any time: Manage cookie preferences.

13. Payments

Payments may be processed through authorised third-party payment providers or by bank transfer.

SIA LONET does not intentionally store complete payment card information on its own systems unless expressly stated otherwise.

Payment providers process payment information under their own privacy policies.

14. Third-Party Service Providers

We may engage trusted third-party providers including cloud hosting, analytics, communication, AI, payment, and infrastructure providers.

Current providers may include, among others:

• Google Workspace
• OpenAI
• Anthropic
• Supabase

Additional providers may be introduced as our Services evolve.

Each provider processes personal data under applicable contractual and legal safeguards.

15. International Data Transfers

Some service providers may process personal data outside the European Economic Area (EEA).

Where such transfers occur, SIA LONET implements appropriate safeguards in accordance with the GDPR, including, where appropriate:

• European Commission adequacy decisions;
• Standard Contractual Clauses (SCCs);
• other legally recognised transfer mechanisms.

16. Data Retention

We retain personal data only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, including legal, contractual, accounting, security, research and operational requirements.

As a general guideline:

• active user accounts are retained while the account remains active;
• educational records, diagnostics and progress history may be retained while necessary to provide longitudinal services;
• marketing information is retained until consent is withdrawn;
• invoices and accounting records are retained for the period required by applicable law;
• backup copies may remain temporarily in secure archives before permanent deletion.

Where appropriate, data may be anonymised rather than deleted to support research and product improvement.

17. Security

SIA LONET implements appropriate technical and organisational measures designed to protect personal data against:

• unauthorised access;
• accidental loss;
• misuse;
• alteration;
• disclosure;
• destruction.

No electronic transmission or storage system can be guaranteed to be completely secure.

18. Your Rights

Subject to applicable law, you may have the right to:

• access your personal data;
• correct inaccurate information;
• request deletion;
• restrict processing;
• object to processing;
• withdraw consent;
• receive a portable copy of your data where applicable;
• lodge a complaint with the competent supervisory authority.

Requests may be submitted to: lonet@lonet.academy

19. Intellectual Property and User Content

Users retain ownership of personal content they submit through the Services.

However, all rights, title and interest in:

• methodologies;
• algorithms;
• scoring systems;
• indexes;
• diagnostics;
• educational frameworks;
• AI-generated analyses;
• reports;
• platform architecture;
• software;
• educational materials;
• dashboards;
• system outputs;

remain the exclusive intellectual property of SIA LONET unless expressly agreed otherwise in writing.

20. Changes to this Privacy Policy

SIA LONET may update this Privacy Policy from time to time to reflect changes in law, technology, business operations or the Services.

Updated versions become effective upon publication unless stated otherwise.

Continued use of the Services after publication constitutes acknowledgement of the updated Privacy Policy.

21. Contact

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

SIA LONET
Email: lonet@lonet.academy
Registered Office: Vidzemes aleja 3–63, Rīga, LV-1024, Latvia