Privacy Policy

Contents

We are committed to protecting and respecting your privacy.

For this reason, we have set up all processes for processing our clients’ personal data to be fully in line with the current legal regulations,[1] and this policy sets out basic information about the conditions under which your personal data is processed.

If you have any further questions, please do not hesitate to contact us at any time.

[1] In particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the “GDPR”), and Act No. 18/2018 Coll. on the protection of personal data (hereinafter the “Act”).

I. Contact Details

For the purpose of data protection legislation, the data controller is Language mentoring s.r.o. and we are responsible for your personal data (referred to as “we”, “us” or “our” in this policy).

To exercise any of your rights concerning the protection of personal data (set out in Article VII below), please use our contact details:

Full name of legal entity: Language mentoring s.r.o.
Registered office: Jána Švermu 1178/12, 958 01 Partizánske, Slovakia
Company ID: 51676982
Registered in the Business Register of the District Court Trenčín, section: Sro, insertion No.: 36375/R
Acting through: Lýdia Hric Machová, managing director

Postal address: Language mentoring s.r.o., Jána Švermu 1178/12, 958 01 Partizánske, Slovakia
Email address: [email protected]

Further information is published on our website www.lydkamethod.com.

II. Data Protection Officer

Since we are not required to do so by law, we have not appointed a data protection officer. We fulfil all duties and obligations in this area ourselves, with the highest professional care, on which you can rely.

III. What Information Do We Collect From You and Why?

We process personal data only to the extent necessary (in particular name, surname, address, telephone number, email address), and we do not process special categories of personal data (so-called sensitive data).

We process our clients’ personal data for various purposes relating to the sale of goods and the provision of services in the field of language education, but only to the minimum extent, in line with the principle of purpose limitation set out in the GDPR, under which a controller may collect personal data only for specified, explicit and legitimate purposes.

We process our clients’ personal data lawfully, and only on the legal bases laid down in Article 6(1) GDPR (put simply, we may process your personal data only if one of these reasons applies[2]). Your consent is one of these legal bases, but we ask for it only where there is no other legal basis. For example, if we process your personal data in order to perform a contract with you – so that we can properly deliver goods or provide a service to you (e.g., send an order confirmation to your email or match your payment to the order) – your separate consent is not required.

[2] The controller may process personal data only if:

the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
the processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract;
the processing is necessary for compliance with a legal obligation to which the controller is subject;
the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

As the controller, we process only the following personal data, for the following purposes and on the following legal bases:

a) Video courses

Data	Purpose	Legal basis
first name, last name, address (street, city, postal code, country), telephone number, email address, bank details (bank, account number, IBAN), company name, company ID, tax ID, VAT ID	conclusion of a contract; processing the order and properly delivering the ordered goods or service, issuing an invoice, and receiving payment of the price and matching it to the order	Article 6(1)(b) GDPR: processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract

b) Free videos and e-books, registration on the website

Data	Purpose	Legal basis
first name, email address	sending a free video and/or e-book to the email address provided, tailoring our offer to the client’s individual needs	Article 6(1)(f) GDPR: legitimate interests pursued by the controller (under Recital 47 GDPR, the processing of personal data for direct marketing purposes may be regarded as a legitimate interest)

c) Competitions and promotions

Data	Purpose	Legal basis
first name, email address	participation in a competition organized by the controller, evaluation of the competition and handing over the prize to the winner, tailoring our offer to the client’s individual needs	Article 6(1)(a) GDPR: the data subject has given consent to the processing of his or her personal data for one or more specific purposes

d) Cookies

Data	Purpose	Legal basis
a small text file that a website stores on your computer or mobile device when you browse it; IP address	remembering your settings, tailoring advertisements to your interests, website functionality, improving customer support	Article 6(1)(a) GDPR: the data subject has given consent to the processing of his or her personal data for one or more specific purposes

e) Marketing communications

Data	Purpose	Legal basis
first name, email address	offering goods and services by email, information about planned promotions, advertising and marketing activities, sending news, advice, tips and tricks	Article 6(1)(f) GDPR: legitimate interests pursued by the controller (under Recital 47 GDPR, the processing of personal data for direct marketing purposes may be regarded as a legitimate interest)

You can ask us to stop sending you marketing messages at any time by following the opt-out link in any of our emails.

f) Lydka SAIL and Lydka BOAT (memberships with the AI language mentor ALMI in the Telegram application)

Data	Purpose	Legal basis
first name, last name, email address (if provided at registration or when contacting support); Telegram user ID/username; technical metadata (time a message was sent, delivery status, session identifiers); language level, goals and learning preferences; content of conversations with ALMI (text messages related to language learning)	providing and operating the ALMI service, personalizing language learning recommendations, customer support and incident resolution, security and integrity of the service	Article 6(1)(b) GDPR (performance of a contract) – providing and personalizing the service; Article 6(1)(f) GDPR (legitimate interest) – operational security, monitoring and improving the stability of the service
first name, last name, email address; payment card data (card number, expiry date, CVC code) – processed exclusively by our contractual payment gateway provider; information on whether the transaction was successful	processing and securing payment of the price of the membership, including automatic recurring payments (subscription)	Article 6(1)(b) GDPR (performance of a contract) – processing is necessary for the proper provision of the service and payment of the price

Note on Lydka SAIL and Lydka BOAT:

Lydka SAIL and Lydka BOAT do not use the content of your conversations to train artificial intelligence models.
As the operator of the service, we do not have access to the content of your messages.
Your payment card data is not made available to us; it is processed exclusively by our contractual payment gateway provider, which meets the requirements of payment industry standards (PCI DSS) and the GDPR. We only receive information about the result of the payment (successful/unsuccessful) or a transaction identifier.
Please do not share special categories of personal data with ALMI (e.g., health data, religious beliefs, political opinions).

IV. Who Might We Share Your Information With?

We protect our clients’ personal data and do not make it available or provide it to third parties, except for persons who provide us with accounting, IT infrastructure, shipping services, online invoicing tools and administrative assistance, and who are therefore considered not only processors but also recipients within the meaning of the GDPR. We select our partners with regard to guarantees of their reliability and professional care in processing our clients’ personal data, and we bind them to confidentiality and to adopting appropriate technical and organizational measures so that the processing of personal data meets the requirements of the GDPR and the Act. Where required by law or by a decision of a public authority, your personal data may also be provided to public authorities or other bodies.

Recipients and processors for Lydka SAIL and Lydka BOAT:
In operating ALMI, we work with verified partners operating in the EU, which provide us with technical infrastructure and data storage (processors under the GDPR): Buddy Pro (the ALMI platform), the cloud service provider AWS – Frankfurt region (Germany), and the vector database provider Pinecone – Ireland. These partners are contractually bound to confidentiality and to maintaining appropriate technical and organizational measures.

Communication takes place via the Telegram application, which is a separate controller with respect to its own services; its processing outside our control is governed by the terms and privacy policy of the company that operates Telegram.

V. Transferring Your Data Outside of the European Union

Some of the service providers we use may process personal data outside the European Union / European Economic Area. In such cases, we ensure that appropriate safeguards are in place as required by the GDPR.

Likewise, for Lydka SAIL and Lydka BOAT, personal data is processed exclusively within the European Union (AWS – Frankfurt, Pinecone – Ireland).

VI. How Long Do We Keep Hold of Your Information?

We see language learning as a lifelong, or at least many-year, process. Our video courses, online programs, e-books and other educational products therefore aim to keep our clients and fans motivated in learning a language over the long term. For this reason, we send clients and fans occasional emails that help them apply our recommended methods in practice and keep up their determination to learn on their own. We also ask for feedback on our products. Every email we send contains an unsubscribe link in its footer. In view of the above, we will keep information about you for fifteen (15) years, for each individual purpose of processing.

After the retention period expires, we ensure that your personal data is erased or anonymized, fully in accordance with the GDPR and the Act.

Retention period for Lydka SAIL and Lydka BOAT
Personal data processed within Lydka SAIL and Lydka BOAT is stored with our contractual partners (Buddy Pro, AWS, Pinecone) within the European Union. As the controller, we do not have access to the content of clients’ conversations, nor the ability to determine independently how long it is retained. The retention period is governed by the settings and technical processes of our partners, who guarantee compliance with the GDPR and apply appropriate data protection measures.

VII. What Are Your Rights?

As a data subject, you have the following rights under the GDPR. You can exercise these rights at any time by contacting us using the contact details in Article I.

a) Right of access
You have the right to obtain confirmation from us as to whether we process personal data concerning you and, if so, to request a copy of the personal information we hold about you, together with basic information about the processing.

b) Right to rectification
You have the right to ask for the information we hold about you to be rectified without undue delay if it is inaccurate, or completed if it is incomplete.

c) Right to erasure
You have the right to ask for your personal data to be erased without undue delay only if:

the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
you withdraw consent on which the processing is based, and there is no other legal basis for the processing;
you exercise your right to object and there are no overriding legitimate grounds for the processing;
the personal data has been unlawfully processed;
the personal data needs to be erased to comply with a legal obligation under the law of the European Union or of the Member State to which we are subject;
the personal data has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

We will then assess whether, in your case, there are exceptions under which your data need not be erased even if one of the above conditions is met (e.g., where it is necessary for the establishment, exercise or defence of legal claims).

d) Right to restriction of processing
You have the right to ask for the processing of your personal data to be restricted (i.e., we will only store your data and not process it in any other way) if:

you contest the accuracy of the personal data;
the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
we no longer need your personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims;
you exercise your right to object (pending verification of whether there are legitimate grounds for processing).

We will then assess whether, in your case, there are exceptions under which your personal data may be processed in ways other than merely storing it.

e) Right to object
You have the right to object to the processing of your personal data where the legal basis for the processing is:
i) the performance of a task carried out in the public interest or in the exercise of official authority, or
ii) our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular where the data subject is a child.

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

We may continue processing your personal data only if we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or grounds for the establishment, exercise or defence of legal claims.

f) Right to data portability
If the processing of your personal data is carried out by automated means and is based on your consent or on the performance of a contract, you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another controller.

g) Right to withdraw consent
Where processing of your personal data is based on consent, you can withdraw that consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

h) Right to lodge a complaint with a supervisory authority
If you believe that your rights have been infringed in the processing of your personal data, or that the Act or the GDPR has been breached, you may file a motion to initiate proceedings with the Office for Personal Data Protection of the Slovak Republic. A template of the motion is published on the Office’s website, www.dataprotection.gov.sk.

VIII. Are You Obliged to Provide Us With Your Personal Data?

Providing your personal data is voluntary; however, some of your personal data is required for the proper performance of the contract (i.e., for the proper and timely provision of goods and services). If it is not provided, we will not be able to properly perform our obligations related to the delivery of goods or services.

IX. Do We Obtain Your Personal Data From Other Sources?

No. All personal data we process comes directly from the fans of Language mentoring themselves, who express interest in the information and advice on language learning that we offer.

X. How Is Your Data Stored and Kept Secure?

At Language mentoring s.r.o. we take your safety and security very seriously. To protect your personal data as much as possible, we have adopted the following technical and organizational measures:

We have prepared internal documentation on the processing and protection of personal data, which is fully compliant with the GDPR and the Act.
All persons who, on our authorization, have access to your personal data have been instructed and process your personal data on our instructions, which comply with the GDPR and the Act.
We regularly retrain the persons who process your personal data on our authorization.
We regularly monitor legal regulations in the area of personal data protection.
We select our partners with regard to guarantees of their reliability and professional care in processing our clients’ personal data, and we bind them to confidentiality and to adopting appropriate technical and organizational measures so that the processing of personal data meets the requirements of the GDPR and the Act.
All websites and applications on which your personal data is stored are protected by password and encryption.

Security of Lydka SAIL and Lydka BOAT
Data transmission between your device, the Telegram application and our platform is encrypted; data is also encrypted when stored on our partners’ servers. Storage and processing take place in the EU (AWS – Frankfurt; Pinecone – Ireland).
Due to the technical limits of current AI solutions, end-to-end encryption is not possible. Nevertheless, access by technical staff to the content of conversations is expressly prohibited by contract, and technical barriers are in place that significantly restrict such access.
Conversations with ALMI are not used to train artificial intelligence models beyond providing the service to you.
The level of security is comparable to professional online services (email, cloud storage, account management), and our contractual partners continuously improve protection according to best practices.

XI. Automated Decision-Making and Profiling

We do not make any decisions based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affect you.

ALMI, the AI language mentor in Lydka SAIL and Lydka BOAT, uses elements of automated processing (generating responses and personalized recommendations for language learning). ALMI’s outputs are recommendations that support your language learning; they do not constitute decisions with legal or similarly significant effects.

XII. Cookies

Detailed information about the cookies we use on this website can be found in our separate Cookie Policy.

XIII. Third-Party Links and Changes to This Policy

Our website may include links to third-party websites, products and services. These websites have their own privacy policies, which are independent of ours, and we are not responsible for their content or activities. Nevertheless, we strive to maintain a high level of security, so if you suspect any improper conduct by such third parties, please let us know using the contact details in Article I. Thank you.

If we change this policy, we will publish the updated version on this page.

This policy is valid from 9 May 2018 and was last updated on 20 October 2026.

Lýdia Hric Machová