PRIVACY POLICY

Last updated January 26, 2026

This Privacy Notice for Lunexa Learning LLC (doing business as Lunexa) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

  • Visit our website at https://www.lunexa.co or any website of ours that links to this Privacy Notice
  • Use Lunexa. Lunexa is a subscription-based, AI-powered professional development platform. Users describe the skills or topics they wish to learn, and our artificial intelligence system generates a complete, personalized course tailored to their goals. Each generated course includes structured learning modules, written lessons, knowledge-check quizzes, hands-on coding laboratories, a capstone project, and a comprehensive final examination.

Certification is earned—not given. Users must demonstrate mastery by achieving a passing score of 80% or higher on the final examination to receive a verifiable digital certificate. Certificates include a unique verification URL that third parties (such as employers or institutions) may use to confirm authenticity.

Lunexa is not an accredited educational institution, and our certifications do not constitute academic degrees, professional licenses, or government-recognized credentials. All course content is generated entirely by artificial intelligence; there are no human instructors, tutors, or content reviewers. Lunexa is not a marketplace—users cannot create, sell, or exchange courses with one another. There is no pre-existing course catalog; every course is generated on-demand based on user input.

Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@lunexa.co.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for.

  • What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
  • Do we process any sensitive personal information? We do not process sensitive personal information.
  • Do we collect any information from third parties? We do not collect any information from third parties.
  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
  • In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties.
  • How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
  • What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
  • How do you exercise your rights? The easiest way to exercise your rights is by contacting us at privacy@lunexa.co. We will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  9. HOW LONG DO WE KEEP YOUR INFORMATION?
  10. HOW DO WE KEEP YOUR INFORMATION SAFE?
  11. DO WE COLLECT INFORMATION FROM MINORS?
  12. WHAT ARE YOUR PRIVACY RIGHTS?
  13. CONTROLS FOR DO-NOT-TRACK FEATURES
  14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  15. ARTIFICIAL INTELLIGENCE PROCESSING
  16. DIGITAL CERTIFICATES AND PUBLIC VERIFICATION
  17. LEARNING DATA AND AUTOMATED DECISION-MAKING
  18. THIRD-PARTY SERVICE PROVIDERS (SUBPROCESSORS)
  19. DATA RETENTION AND DELETION
  20. AGE REQUIREMENT (18+)
  21. INTERNATIONAL TRANSFERS (U.S. BASED)
  22. STATE-SPECIFIC (CALIFORNIA/CCPA)
  23. SECURITY AND BREACH NOTIFICATION
  24. CHANGES TO THIS POLICY
  25. DO WE MAKE UPDATES TO THIS NOTICE?
  26. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  27. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • email addresses
  • contact or authentication data
  • billing addresses
  • learning activity data (including lesson completion status, quiz and examination scores, time spent on learning materials, code submitted to laboratories, course generation prompts, and assessment responses)
  • engagement metrics (including consecutive login streaks, last active date, and daily usage patterns for gamification features)
  • AI usage analytics (including API tokens consumed, operation types, costs, and timestamps for internal analytics and cost management)

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/privacy.

We do not store or have access to your payment card information. All payment processing is handled directly by Stripe, a PCI-DSS Level 1 certified payment processor. We only receive and store a transaction identifier, subscription status, and billing address for order fulfillment and tax purposes.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Google account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect approximate location data based on your IP address for fraud prevention, security, and compliance purposes. We do not collect precise GPS location data.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them. This includes tracking engagement metrics such as login streaks and platform usage patterns.
  • To manage AI infrastructure costs. We log AI usage data (tokens consumed, operation types, costs) to monitor and manage our infrastructure expenses. This data is aggregated and used for internal analytics only.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
  • To process user submissions with AI for grading and feedback. Lunexa sends user-generated content (quiz answers, code submissions, exercise responses) to third-party AI providers for automated grading and course generation.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following service providers.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we share personal information with are:

  • Authentication: Clerk (user identity management)
  • AI Processing: OpenAI (course generation, grading, learning assistance)
  • Payment Processing: Stripe (financial transactions)
  • Analytics: PostHog (product analytics and user behavior)
  • Error Monitoring: Sentry (application error tracking)
  • Hosting & Infrastructure: Cloud hosting, database, and caching providers

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We use cookies and similar technologies for site functionality, security, and analytics. These include session cookies to maintain your login state and analytics cookies used by our service providers (PostHog, Sentry) to help us understand how our Services are used and to identify errors. This data is processed by our analytics providers and is not shared with third-party advertising networks.

You can control cookies through your browser settings, though disabling cookies may affect site functionality.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions: AI-powered course generation, automated assessment grading, and personalized learning content creation.

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.

How to Opt Out

AI processing is integral to providing our Services. If you do not wish to have your data processed by AI systems, you may close your account by contacting us using the contact information provided.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Google account). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will typically include your name and email address.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States, and our Services are primarily directed toward users in the United States and the Americas. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we share your personal information, in the United States and potentially other countries.

Our third-party service providers maintain their own data protection practices as described in their respective privacy policies. We do not specifically target users in the European Economic Area, United Kingdom, or other jurisdictions outside the Americas.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

Upon account termination, we retain your personal and learning data for thirty (30) days to facilitate account recovery. Following this period, data is deleted from our active systems, except: (1) financial transaction records, which may be retained for up to seven (7) years to comply with tax and accounting obligations, and (2) certificate verification data, which remains accessible to preserve the integrity of issued credentials unless you explicitly request deletion.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

11. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@lunexa.co.

12. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws. If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, managing email preferences in account settings, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account, or contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@lunexa.co.

13. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

14. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

The following table shows the categories of personal information we have collected in the past twelve (12) months:

CategoryExamplesCollected
A. IdentifiersContact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account nameYES
B. Personal information as defined in the California Customer Records statuteName, contact information, education, employment, employment history, and financial informationYES
C. Protected classification characteristics under state or federal lawGender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic dataNO
D. Commercial informationTransaction information, purchase history, financial details, and payment informationYES
E. Biometric informationFingerprints and voiceprintsNO
F. Internet or other similar network activityBrowsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisementsYES
G. Geolocation dataApproximate location based on IP addressYES
H. Audio, electronic, sensory, or similar informationImages and audio, video or call recordings created in connection with our business activitiesNO
I. Professional or employment-related informationBusiness contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with usNO
J. Education InformationStudent records and directory informationNO
K. Inferences drawn from collected personal informationInferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristicsNO
L. Sensitive personal InformationNO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us, plus 30 days after deletion for account recovery
  • Category B - As long as the user has an account with us, plus 30 days after deletion for account recovery
  • Category D - As long as the user has an account with us, plus up to 7 years for financial records as required by law
  • Category F - As long as the user has an account with us, plus 30 days after deletion for account recovery
  • Category G - As long as the user has an account with us, plus 30 days after deletion for account recovery

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We do not sell or share your personal information as those terms are defined under California law. We disclose personal information to service providers who process data on our behalf pursuant to written contracts, as described in Section 4.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending upon the state where you live, you may also have the following rights:

  • Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at privacy@lunexa.co, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@lunexa.co. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

15. ARTIFICIAL INTELLIGENCE PROCESSING

Our Services utilize third-party artificial intelligence ("AI") providers, including OpenAI, to power features such as course generation and assessment grading.

Data Submission: When you use AI-powered features, your inputs—including text prompts, course content, quiz answers, and assessment responses—may be transmitted to and processed by these third-party providers.

Content Guidelines: You should not submit content containing sensitive personal information, including medical or health conditions, government identification numbers, or financial account credentials. Course prompts and submissions are processed by third-party AI systems, and we cannot guarantee special protections for sensitive data submitted in violation of this policy.

Assumption of Risk: AI-generated content is produced without human intervention. Lunexa does not warrant the accuracy, completeness, or reliability of any AI-generated output. You assume all risk for your reliance on such content.

16. DIGITAL CERTIFICATES AND PUBLIC VERIFICATION

Upon successful course completion, Lunexa may issue a Digital Certificate.

Public Access: Each certificate is assigned a unique, public verification URL. By using the certification feature, you acknowledge that anyone in possession of this link may view your name, course title, score, and completion date.

Visibility Controls: You may request the deactivation of a public link at any time by contacting privacy@lunexa.co, though this may prevent third parties (e.g., employers) from verifying your credentials.

17. LEARNING DATA AND AUTOMATED DECISION-MAKING

We collect "Learning Data," which includes lesson progress, quiz responses, exam answers, lab completions, and time-on-task.

Automated Scoring: Assessment scores are calculated through automated AI processing. Our certificates represent completion of AI-evaluated coursework and do not constitute accredited credentials or produce legal effects. If you believe an assessment was scored in error, you may contact us at privacy@lunexa.co to report the issue.

Purpose: This data is used to provide feedback, determine certificate eligibility, track your progress, and improve our educational services.

18. THIRD-PARTY SERVICE PROVIDERS (SUBPROCESSORS)

To provide our platform, we share data with trusted third-party service providers:

  • Authentication: Clerk (user identity management)
  • AI Processing: OpenAI (course generation, grading, learning assistance)
  • Payment Processing: Stripe (financial transactions)
  • Analytics: PostHog (product analytics)
  • Error Monitoring: Sentry (application error tracking)
  • Infrastructure: Cloud hosting, database, and caching providers

These providers process your data according to their respective privacy policies and data processing agreements. We do not sell your personal information to third parties.

19. DATA RETENTION AND DELETION

Retention Period: We retain your account and learning data for as long as your account is active.

Account Closure: Upon account termination, we retain your data for thirty (30) days to facilitate recovery. Following this period, data is deleted, except where retention is required by law (such as financial transaction records, which may be retained for up to seven years for tax and accounting purposes). AI usage logs are anonymized (disassociated from your account) rather than deleted, as they are used for aggregate cost analytics.

Certificate Persistence: Verification links for Digital Certificates remain active after account closure to preserve your professional record, unless you explicitly request deletion or the certificate is revoked pursuant to our Terms and Conditions.

20. AGE REQUIREMENT (18+)

The Services are intended strictly for users aged 18 and older. We do not knowingly collect data from individuals under 18. If we discover a user is under 18, we will terminate the account and delete associated data promptly.

21. INTERNATIONAL TRANSFERS (U.S. BASED)

Lunexa is operated in the United States and our Services are primarily directed toward users in the United States and the Americas. If you access the Services from outside the United States, your information will be transferred to the United States. Our third-party service providers maintain their own data protection practices as described in their respective privacy policies.

22. STATE-SPECIFIC (CALIFORNIA/CCPA)

If you are a California resident, you have the following rights:

  • Right to Know/Access: Request details on the categories of data collected.
  • Right to Delete: Request the deletion of your personal information.
  • Right to Correct: Request correction of inaccurate data.
  • Non-Discrimination: We will not penalize you for exercising these rights.

To exercise these rights, contact privacy@lunexa.co.

23. SECURITY AND BREACH NOTIFICATION

We implement industry-standard administrative, technical, and physical safeguards (including encryption in transit and at rest) to protect your data. However, no method of transmission over the internet is 100% secure.

In the event of a data breach, we will notify you and relevant regulatory authorities within the timeframes required by applicable law.

24. CHANGES TO THIS POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you via the email address associated with your account or through a prominent notice on our platform. Your continued use of the Services after such changes constitutes acceptance of the revised policy.

25. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

26. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at privacy@lunexa.co or contact us by post at:

Lunexa Learning LLC

7901 4th ST N STE 300

St. Petersburg, FL 33702

United States

27. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at privacy@lunexa.co.