Privacy Policy

1. Introduction

This Privacy Policy describes how the personal data of users of the Lerno platform, created by Lerno, LLC (ID: 405879429) (below "we" and/or "the Company"), is processed, including by means of the website https://lerno.ge/. It sets out the scope, purpose and grounds of that processing and presents your rights and the ways in which you can exercise them under applicable law.

2. About the Company

2.1.Full name: Lerno, LLC (ID: 405879429)

2.2.Place of registration: Tbilisi, Georgia

2.3.Contact email: luka@lerno.ge

3. What data we process

3.1. Identifying and contact data

3.1.1.First and last name (in Georgian and in English)

3.1.2.Email address

3.1.3.Profile photo, if you registered with a Google account

3.1.4.National ID number, required from every user at registration (see 3.5)

3.1.5.Phone number, optional

3.2. Learning progress data

3.2.1.Which course you have access to and when you started it

3.2.2.Progress as a percentage and the list of components you have completed

3.2.3.Total time spent on the course and the time spent on each individual lesson the first time through

3.2.4.Which questions you revealed the answer to without answering them yourself

3.2.5.The skills you have gained and the certificates issued to you

3.2.6.Courses and lessons you have saved for later

3.3. Device and session data

3.3.1.A unique device identifier, generated in your browser

3.3.2.A description of your browser and device (the user agent)

3.3.3.When the device was registered and when it was last active

This data serves to limit the number of devices linked to a single account (see the Terms of Service, clause 8.3).

3.4. Payment data

3.4.1.The amount, currency and date of the payment

3.4.2.The payment method (card or invoice) and the payment status

3.4.3.The order and payment identifiers assigned by the payment provider

The Company does not receive or store your card number, expiry date or CVV. That data is provided directly to the payment provider.

3.5. A note specifically about the national ID number

We ask every user for their national ID number at registration. The purpose is fraud prevention and the trustworthiness of the certificate: a certificate has to belong to a specific person and the same person should not be counted as several different learners. Basis: the Company's legitimate interest.

Only a Company administrator has access to the national ID number. Neither other users nor the organization that provided access to a course can see it. The user cannot change it themselves; a correction is made by contacting the Company.

4. Why we process this data

4.1.To identify you and manage your account

4.2.To grant access to a course and record learning progress

4.3.To issue a certificate and confirm its authenticity

4.4.To take payment and record the purchase

4.5.To provide technical support and fix faults

4.6.For platform security and to prevent unlawful account sharing and fraud

4.7.To improve the quality of the service

4.8.To meet obligations imposed by law

4.9.Where you have given separate consent, for direct marketing (see 4.1)

4.10. Direct marketing

Where you have given separate, voluntary consent, we will send you information by email about news, new courses, updates and offers. For this purpose we process only your name and your email address.

4.10.1.Consent is voluntary. Without it you can still use the Platform and take a course in full.

4.10.2.Consent is recorded separately and is not part of accepting the Terms of Service.

4.10.3.You can withdraw consent at any time, free of charge and without giving a reason: every email will carry an unsubscribe link. You can also write to us at luka@lerno.ge.

4.10.4.Withdrawing consent has no effect on your access to a course.

5. The legal basis for processing

Your personal data is processed by the Company only where an appropriate basis exists. One basis, or several at the same time, may apply:

5.1.your voluntary consent to processing for one or several specific purposes;

5.2.processing is necessary to perform an obligation under a transaction concluded with you, or to conclude a transaction at your request;

5.3.processing is provided for by law;

5.4.processing is required for the Company to perform duties imposed on it by law;

5.5.processing is necessary to protect a significant legitimate interest of the Company or of a third party, unless there is an overriding interest in protecting the rights of the data subject;

5.6.processing is necessary to consider your application and to provide the service.

6. Who your data is shared with

6.1. Google (Firebase)

The Platform is built entirely on Google infrastructure: authentication, database, file storage and hosting. In addition, if you choose to sign in with a Google account, Google also acts as your identity provider for us and supplies your name, email address and profile photo.

6.2. Anthropic (the AI Assistant)

An AI Assistant is available on the Platform. When you put a question to it, the Company sends Anthropic PBC (United States):

6.2.1.the text of the lesson you are on and the name of the course

6.2.2.the questions you have typed and the most recent turns of the current conversation

Your name, email address, national ID number and account identifier are not sent to Anthropic. The Company does not store the conversation history.

This is a transfer of data outside Georgia. That is precisely why we advise you not to enter personal information in your exchanges with the AI Assistant.

6.3. Flitt (payments)

Card payments are processed by the payment provider Flitt. You provide your card details to them directly and they are not passed on to Lerno. We receive only the outcome of the payment, the amount, the currency and the provider's identifiers.

6.4. The organization that provided access to the course

If your employer or another organization provided your access to a course, an authorized person at that organization can see on the Platform:

6.4.1.your first name, last name and email address

6.4.2.your progress as a percentage on each course

6.4.3.the time you have spent on the course

6.4.4.whether the course is complete and when it was completed

6.4.5.the skills gained from completed courses

This information covers only those courses to which the organization provided access. The organization cannot see your national ID number.

6.5. Law enforcement and state bodies

In the cases provided for by law, data may be passed to law enforcement authorities or to another authorized state institution.

7. What becomes public

7.1. Certificate verification

Every certificate has a unique code. Anyone who knows that code, including someone without a Lerno account, can see your first and last name, the name of the course and the completion date. Without the code a certificate cannot be found and no list can be obtained.

This is deliberate: the point of a certificate is precisely that an employer can check it is genuine.

7.2. Course reviews

If you leave a review of a course, your first and last name are shown publicly on the course page alongside the text of your review and the star rating. Your profile photo is not published. Leaving a review is voluntary.

8. Cookies and browser storage

The first five are necessary for the Platform to work or to remember your settings and require no consent. The last entry stores your answer itself, so it is necessary too.

Google Analytics is switched on only with your consent. Until you choose "Accept all cookies" the Google script is not loaded and no request is sent to Google at all: not merely no cookie written, but no connection made. If you choose "Accept only necessary", analytics is never switched on.

Analytics data is processed by Google LLC (United States). We see only aggregate statistics: how many visitors there were, where they came from and which pages they viewed. We do not share your name, email address or national ID number with Google.

You can change your decision at any time with the button below. Withdrawing consent is as easy as giving it.

Analytics and advertising cookies

Lerno has exactly one non-essential cookie: analytics. We use Google Analytics to see how many visitors we have, where they come from and which pages they view. We have no advertising tracking cookies: Meta Pixel and other such services are not integrated into the Platform, we do not follow what you do on other websites and we do not build an advertising profile of you.

That is why you are met with a cookie banner on your first visit, with two buttons. "Accept only necessary" means analytics is never switched on: the Google script is not loaded and no request is sent to Google. The other entries listed above are necessary for the Platform to function and require no consent.

You can change your answer at any time with the button below. Withdrawing consent is as easy as giving it.

If we add another non-essential cookie in the future, this page will be updated and the banner will change accordingly.

How to control cookies

You can delete or block cookies at any time in your browser settings. Note that if you block the session cookie you will not be able to sign in to the Platform. If you delete the others your chosen language and appearance will revert to their defaults.

9. How long we keep data

9.1.Account and learning data is kept for as long as your account is active

9.2.Account deletion happens immediately and cannot be undone

9.3.Deletion removes your profile, your learning progress data and your device and session records

9.4. What remains after your account is deleted

a) Certificates already issued. A certificate attests to something that actually happened: you completed the course. The certificate record therefore remains and checking it by its unique code keeps working after your account is deleted. The check still shows your first and last name, the name of the course and the completion date.

Basis: the legitimate interest of the Company and of third parties in being able to trust a certificate that has been issued. An employer who has already been given the code must be able to remain confident that the certificate is genuine. This is an exception to the right to erasure and it is stated openly for that reason: if you delete your account, your name is not removed from the certificate.

b) Accounting and tax records, namely the purchase amount, the date and the payment identifiers. These are kept for the period established by law. This is not a choice, it is a statutory obligation.

10. Security

The Company takes appropriate security measures to protect the data under its control against unauthorized access, unlawful use and disclosure, destruction and accidental loss.

11. Your rights

You have the right to:

11.1.be told whether your data is being processed, on what basis and for what purpose, where we obtained it, how long we keep it and who we share it with

11.2.access your data and receive a copy of it free of charge

11.3.request that incorrect, inaccurate or incomplete data be corrected, updated or completed

11.4.request that processing be stopped and that data be erased or destroyed

11.5.request that data be blocked in the cases provided for by law

11.6.receive the data you provided in a machine-readable format, or request its transfer to another controller

11.7.not be subject to a decision taken solely by automated means that has a significant effect on you

11.8.withdraw a consent you have given at any time, without giving any reason

11.9.withdraw a consent given for direct marketing at any time and free of charge

To exercise these rights, write to us at luka@lerno.ge. Before acting on a request we will identify you, so as to be sure the information reaches the right person.

12. The right to complain

If the rights established by the Georgian legislation on personal data protection are breached, you have the right to apply to the Personal Data Protection Service or to a court.

13. Changes to this Policy

The Company reserves the right to update this Policy where necessary. If substantive changes are made, you will be notified.