PRIVACY POLICY
Privacy Policy
Last updated: September 2026
1. DATA CONTROLLER
Psichologijos mokymų centras, UAB (registration code 305743263, VAT number LT100014333519) ("we", "us", "our") is the data controller responsible for your personal data.
Address:
Gojaus g. 1, Zibalai, Širvintų r., Lithuania
Email: hello@oriano.app
2. WHAT CATEGORIES OF PERSONAL DATA DO WE COLLECT?
We collect both data you voluntarily provide (for example, your email address or name) and data generated automatically when you use the Product (for example, your IP address or device information).
2.1 Data You Provide
You provide personal data when you:
- register or create an account;
- complete quizzes or questionnaires;
- purchase a subscription;
- contact Customer Support;
- respond to our emails;
- submit feedback;
- report a technical issue.
2.2 Automatically Collected Data
How you found us
We collect information about how you arrived at our Product, including referral websites, advertising campaigns, or marketing links.
Cookies and Similar Technologies
We use cookies, local storage, and similar technologies to improve your experience. For more information, please see our Cookie Policy.
Browser and Device Information
We automatically collect technical information including:
- IP address;
- browser type;
- operating system;
- device model;
- language;
- time zone;
- referring URLs;
- usage information.
Payment Information
Payments are processed by our third-party payment providers. We do not store your complete payment card details.
Personal Data We Process
| Category | Fields | Purpose | Legal Basis | Retention |
|---|---|---|---|---|
| Email address | Create your account, deliver quiz results, transactional emails | Consent (Art. 6(1)(a)) | Active account or 90 days for abandoned sessions | |
| Quiz answers | quiz_answers | Generate personalized recommendations | Explicit consent (Art. 9(2)(a)) | Active account or 90 days |
| Personalized result | result_segment | Tailor recommendations and content | Legitimate interest / Consent | Active account or 90 days |
| Payment identifiers | stripe_customer_id, payment_intent | Process payments, subscriptions and refunds | Contract (Art. 6(1)(b)) | 7 years |
| Order history | amount, currency, product, status | Accounting and purchase history | Contract + Legal obligation | 7 years |
| Progress data | completed lessons, progress status | Resume user progress and improve experience | Contract | Duration of account |
| Login security | email, IP address, login attempts | Fraud prevention and security | Legitimate interest | 30 days |
| Usage analytics | events, pages visited, metadata | Product improvement and analytics | Consent | Up to 2 years |
| Subscription access | subscription status, access level | Grant access to purchased content | Contract | Duration of account |
3. FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data for the following purposes.
3.1 Service Provision
To provide access to the ORIANO platform, digital content, subscriptions, and personalized recommendations.
3.2 Product Personalization
To generate personalized recommendations and improve your overall experience.
3.3 Research and Analytics
To understand how users interact with the Product and improve functionality.
3.4 Payment Processing
To process purchases, subscriptions, renewals, and refunds.
3.5 Fraud Prevention and Security
To detect unauthorized access, abuse, fraud, or other security incidents.
3.6 Communication
To send transactional emails, account notifications, customer support responses, and service-related communications.
3.7 Marketing
With your consent where required, we may send newsletters, promotional offers, product updates, and educational content.
3.8 Customer Support
To respond to questions, complaints, refund requests, and technical issues.
3.9 Advertising
To measure advertising performance and personalize marketing campaigns.
3.10 Legal Obligations
Where required by law, we may disclose information to governmental authorities or regulatory bodies.
4. DATA STORAGE AND TRANSFER
We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law.
Where necessary, your personal data may be transferred outside the European Economic Area using appropriate safeguards, including Standard Contractual Clauses or other legally recognized transfer mechanisms.
5. THIRD-PARTY DATA RECIPIENTS
We share personal data only with service providers that help us operate our Product. They process personal data solely on our behalf and according to our instructions.
| Service | Role | Data Shared | Location | Transfer Mechanism |
|---|---|---|---|---|
| Stripe | Payment processor | Payment identifiers, email, purchase information | USA | EU-US Data Privacy Framework / SCCs |
| Google Analytics / Google Ads | Analytics | Analytics identifiers, usage information | USA | EU-US Data Privacy Framework |
| Meta Pixel | Advertising | Hashed email, events | USA | EU-US Data Privacy Framework |
| ActiveCampaign | Email delivery | Email address, subscription status | USA | Standard Contractual Clauses |
| PostHog | Analytics | Session information, product events | EU | EU Data Residency |
| Supabase | Database hosting | User accounts, subscriptions, product data | Project region | Appropriate safeguards |
| Cloudflare | Security | Technical request information | Global | Standard safeguards |
We never sell your personal data.
6. YOUR RIGHTS
Subject to applicable law, you have the right to:
- access your personal data;
- correct inaccurate information;
- request deletion of your personal data;
- restrict processing;
- object to certain processing activities;
- withdraw consent at any time where processing is based on consent;
- receive your personal data in a structured, commonly used format;
- lodge a complaint with your local supervisory authority.
7. CONTACT INFORMATION
If you have any questions regarding this Privacy Policy or the processing of your personal data, please contact us:
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