Privacy Policy

This Privacy Policy explains how Lony Inc. (“Lony,” “we,” “us,” or “our”) collects, uses, stores, and shares your personal information when you use the Lony Platform (“Platform”). By using the Platform, you agree to the practices described in this Policy.

1. Information We Collect

1.1 Information You Provide

We collect information you provide directly, including:

  • Account registration data (name, email address, password, role type)
  • Profile information (biography, credentials, institutional affiliation)
  • Payment information (processed by authorized third-party payment processors; Lony does not store raw card data)
  • Creator-published content, course materials, and metadata
  • Communications with Lony support or institutional contacts

1.2 Learning Activity Data

As you use the Platform, we collect data about your learning activity, including:

  • Course progress, assessment results, and completion milestones
  • AI Companion interactions, hint usage, and learning mode preferences
  • Time-on-task, engagement signals, and pedagogical tree navigation paths
  • Peer interaction data within learning pods or collaborative modules
  • Proof of Learning (PoL) and Proof of Knowledge (PoK) evidence data

1.3 Credential and Blockchain Data

When credentials and achievements are issued, the following data is anchored to the blockchain:

  • Achievement identifiers, credential type, and issuance date
  • Cryptographic proof of learning linked to your account public key
  • Institutional or ministry issuer identifiers where applicable

Important: Blockchain Immutability

Blockchain records are immutable by design. Credential revocations are flagged on-chain, but the original issuance record cannot be deleted. Please review Section 9 (Your Privacy Rights) for important information about how this affects deletion requests.

1.4 Technical and Device Data

We automatically collect technical data including IP address, browser type, device identifiers, operating system, referring URLs, and session activity logs. This data is used for security, performance, and analytics purposes.

1.4.1 Processing of Behavioral and Engagement Signals

To support the Platform’s Emotion AI Engine — which enables real-time adaptation of content pacing, difficulty, and tone based on your estimated cognitive and emotional state — the Platform may analyze micro-behavioral interaction signals, including:

  • Scroll depth and speed through learning content
  • Fine cursor movement and pointer interaction patterns
  • Hesitation time and idle periods during exercises
  • Click frequency and interaction rhythm
  • Keystroke timing and input dynamics (where applicable)
  • Video rewind and skip behavior

These signals are used solely to infer indicators of engagement states such as focus, confusion, boredom, or stress — for the purpose of adapting your learning experience in real time. They are not used to infer health conditions, build advertising profiles, or shared with third parties for any purpose outside of Platform delivery.

To minimize data transmission, the Platform is designed to process behavioral signals as close to your device as technically feasible. Where local processing is available, only summarized indicators of your estimated focus level and emotional engagement state — not raw interaction events — are transmitted to Lony’s servers.

Where required by applicable law — including in jurisdictions where behavioral or emotion-inferred data is classified as sensitive personal information — Lony will obtain your explicit consent before activating Emotion AI features. You may withdraw this consent at any time through Platform settings without affecting your access to core learning features.

2. How We Use Your Information

We use the information we collect to:

  • Deliver and personalize the learning experience through AI Companion systems
  • Issue, verify, and maintain blockchain-anchored credentials and achievements
  • Process transactions, reward distributions, and creator revenue shares
  • Provide institutional dashboards, analytics, and governance control surfaces
  • Operate and improve the Platform’s infrastructure, security, and AI systems
  • Communicate with you about your account, updates, and Platform changes
  • Fulfill legal and regulatory obligations
  • Support ministry-level reporting, equity analytics, and national oversight tools (for Ministry deployments only, subject to Deployment Agreement)

3. Legal Basis for Processing (GDPR / International Users)

For users in the European Economic Area, United Kingdom, and other jurisdictions with similar requirements, our legal basis for processing personal data includes:

  • Contractual necessity — to provide the services you have signed up for
  • Legitimate interests — platform security, fraud prevention, and product improvement
  • Consent — for optional data uses such as marketing communications and analytics-sharing with institutions
  • Legal obligation — to comply with applicable laws and regulations

Where we rely on legitimate interests, we have assessed that such interests are not overridden by your rights and interests. You may object to processing based on legitimate interests at any time by contacting [email protected].

3.1 Automated Decision-Making

Lony’s AI Companion systems make automated decisions about your learning path, content sequencing, and assessment approach. These decisions are designed to optimize your learning outcomes and are not legally binding determinations. Under GDPR Article 22, where automated processing produces significant effects, you have the right to:

  • Request human review of any AI-driven decision;
  • Express your point of view regarding such decisions; and
  • Obtain an explanation of the logic involved.

To exercise these rights, contact [email protected] or use the explanation feature in Platform settings.

3.2 Data Controller and Processor Roles

The allocation of data controller and processor responsibilities under applicable privacy law depends on the deployment context:

  • Direct Users (individual learners and creators): Lony acts as the data controller for personal data you provide and that we collect through your use of the Platform. We determine the purposes and means of processing your personal data and are responsible for compliance with applicable privacy law.
  • Institutional Deployments: Where an institution or ministry deploys the Platform for its learners or employees, the institution acts as an independent data controller for data it collects and submits to the Platform, and Lony acts as a data processor on its behalf for such data. The terms governing that processing relationship are set out in a Data Processing Agreement (DPA), which forms part of the applicable Deployment Agreement.
  • Ministry Deployments: In national or sovereign deployments, the relevant ministry or government entity is the data controller for data collected under its deployment mandate. Lony processes such data as a data processor in accordance with the Deployment Agreement and applicable law.

Where Lony acts as a data processor, it processes personal data only on documented instructions from the controller, does not process data for its own purposes, and implements appropriate technical and organizational measures as required by the applicable DPA. Institutional and ministry customers may request Lony’s standard Data Processing Agreement (DPA) at [email protected]; a DPA will also be provided as part of the formal onboarding process for all institutional and ministry deployments.

4. How We Share Your Information

4.1 Within the Ecosystem

Certain data is shared within the Lony ecosystem to enable its core functions:

  • Credential and achievement data may be visible to institutions or ministries that issued or co-issued your credentials
  • Creator content and reputation data is visible to learners on the marketplace
  • Institutional administrators have access to aggregate and individual learner analytics within their deployment

4.2 Service Providers and Subprocessors

We share data with trusted third-party service providers (subprocessors) who process data on our behalf, including cloud infrastructure providers, payment processors, blockchain infrastructure operators, and analytics vendors. All providers are bound by data processing agreements and may not use your data for their own purposes.

A current list of our subprocessors is available upon request at [email protected]. We will notify institutional customers of any intended changes to our subprocessor list (additions or replacements) at least 30 days in advance, providing an opportunity to object before the change takes effect.

4.3 Legal Disclosures

We may disclose your information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Lony, our users, or the public. Where legally permitted, we will notify you of such disclosures.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of all or substantially all assets, your personal information may be transferred to the acquiring entity. We will notify you of any such transfer and the acquiring entity’s privacy practices before your data is transferred, and you will have the opportunity to close your account.

4.5 No Sale of Personal Data

Lony does not sell your personal data to third parties. We do not allow advertisers to target you based on your learning activity or personal profile.

4.6 No Cross-Platform Tracking

Lony does not track your activity across third-party websites, applications, or services for advertising or profiling purposes. We do not participate in real-time bidding networks, data broker ecosystems, or any advertising technology that links your Lony activity to your behavior on other platforms. Analytics data collected on the Platform is used solely to improve the Platform and your learning experience, and is subject to the data processing agreements described in Section 4.2.

5. Data Retention

We retain your data for as long as your account is active or as needed to provide services. Specific retention periods:

  • Account data: Retained for the duration of your account plus 3 years after closure
  • Learning activity data: Retained for 5 years to support credential verification
  • Blockchain credential records: Permanent (by design of the blockchain infrastructure)
  • Payment transaction logs: Retained for 7 years for financial compliance
  • Technical logs: Retained for 90 days unless required for active security investigations

Upon account closure, we will anonymize or delete personal data that is no longer needed for legal or operational purposes, subject to the retention periods above. Data that cannot be deleted due to blockchain immutability is described in Section 9.

6. Data Security

Lony implements industry-standard security practices to protect your information:

  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
  • Role-based access controls limiting internal data access to authorized personnel
  • Regular security audits and penetration testing
  • Incident response procedures with user and regulatory notification protocols
  • Sovereign deployment options (cloud, hybrid, or on-premise) for institutional and ministry customers

In the event of a material security incident affecting your personal data, we will notify affected users within 72 hours of becoming aware of the breach (where required by applicable law) and will report to relevant regulatory authorities as required. Notification will include a description of the incident, the data affected, and steps we are taking to mitigate harm.

To report a suspected security vulnerability or data breach, contact our dedicated security response channel at [email protected]. For urgent incidents, please include “URGENT — Security Incident” in the subject line. Lony’s incident response team will acknowledge receipt within 24 hours and initiate investigation procedures.

7. AI Systems and Explainability

Lony’s AI Companion and recommendation systems make personalized decisions about your learning path, content delivery, and assessment approach. These systems are designed with explainability as a core principle:

  • AI decisions are logged and auditable by institutional administrators
  • Learners may request explanations of AI-driven recommendations through the Platform settings
  • Institutions and ministries may configure AI behavioral policies within their governance control surfaces
  • Lony does not use AI systems to make legally consequential decisions about individuals without human oversight

We do not use your personal data to train third-party AI models. AI systems operate on your data solely to deliver your learning experience.

7.1 AI System Boundaries

Lony’s AI systems operate within predefined pedagogical and policy constraints established by Lony and, where applicable, by the deploying institution or ministry. Specifically:

  • AI systems do not autonomously modify platform governance rules, credential issuance policies, or user permission structures;
  • changes to AI behavioral parameters at the institutional or ministry level require deliberate configuration by an authorized administrator through designated governance control surfaces;
  • AI systems cannot override decisions made by human administrators, institutional governance controls, or Deployment Agreement terms; and
  • all AI interventions in a learner’s experience are logged, auditable, and subject to review by authorized institutional administrators.

This boundary architecture ensures that AI enhances the learning experience within defined policy limits — it does not set, expand, or rewrite those limits autonomously.

Lony’s Emotion AI Engine infers engagement states (such as focus, confusion, boredom, or stress) from behavioral interaction signals as described in Section 1.4.1. The following clarifications apply to the nature of this processing:

  • Emotion inference is not biometric processing. The Platform does not use facial recognition, iris scanning, fingerprinting, voiceprint analysis, or any other biometric identifier to identify or authenticate users. Behavioral interaction signals (e.g., scroll speed, pointer movement, click rhythm) are not biometric data as defined under GDPR Article 9, BIPA, or equivalent legislation.
  • Emotion inference does not constitute health data processing. The Platform does not diagnose, treat, or record medical or mental health conditions. Inferred engagement states are pedagogical indicators used solely to adapt content delivery and are not stored or used as health information.
  • No facial or physical surveillance. The Platform does not access your device camera, microphone, or any physical sensor except where you explicitly activate an optional feature and grant the relevant permission.

Notwithstanding the above, Lony recognizes that the regulatory classification of emotion-inferred data may evolve. We monitor applicable legal developments and will update our practices and disclosures accordingly. Where any jurisdiction classifies the behavioral signals we collect as sensitive personal information, we will apply the consent and data minimization obligations required by that jurisdiction.

8. Children’s Privacy

The Platform is not directed to children under the age of 13. If an institution deploys Lony in an environment with minors, the institution is responsible for obtaining appropriate parental or guardian consent in accordance with applicable laws (including COPPA in the United States and equivalent regulations internationally).

Lony provides institutional privacy controls and data minimization tools specifically designed for minors’ data in educational settings. We collect only the minimum data necessary for minors using these features.

9. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal data:

  • Access: Request a copy of the personal data we hold about you
  • Correction: Request correction of inaccurate or incomplete data
  • Deletion: Request deletion of your personal data, subject to legal retention requirements
  • Portability: Request your data in a structured, machine-readable format (e.g., JSON or CSV)
  • Objection: Object to certain types of data processing, including profiling and direct marketing
  • Restriction: Request that we restrict processing of your data pending resolution of a dispute
  • Withdrawal of Consent: Withdraw consent for optional data uses at any time without affecting prior processing

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days (or sooner where required by law). To protect your personal data, we may request additional information to verify your identity before fulfilling any request. We will not use this information for any purpose other than identity verification.

9.1 Technical Limitations to Deletion (Blockchain Records)

While you may exercise your right to deletion by requesting the removal of your personal profile from Lony’s centralized databases (including account records, learning activity logs, and profile data), you acknowledge that cryptographic hashes and achievement identifiers anchored to the blockchain are permanent and cannot be removed from the ledger.

Exercising your deletion right with respect to blockchain records will result in de-identification: Lony will sever the link between your personal identity and your blockchain public key, such that the on-chain record can no longer be attributed to you. The transaction record itself will remain on the immutable ledger in anonymized form. De-identification will be completed within 30 days of your verified deletion request.

If you wish to understand exactly which data is stored on-chain versus in Lony’s centralized databases before submitting a deletion request, you may first submit an Access request at [email protected].

10. California Privacy Rights (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with specific rights:

  • Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
  • Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions.
  • Right to Correct: You may request correction of inaccurate personal information.
  • Right to Opt-Out of Sale or Sharing: Lony does not sell or share personal information for cross-context behavioral advertising.
  • Right to Limit Use of Sensitive Personal Information: You may request that we limit our use of sensitive personal information to purposes permitted under CCPA/CPRA.
  • Right to Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA/CPRA rights.

To submit a verifiable consumer request, contact us at [email protected] with the subject line “CCPA/CPRA Request.” We will verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf by providing written authorization together with your request.

11. International Data Transfers

Lony operates globally and may transfer your data to countries outside your jurisdiction. For transfers from the European Economic Area and United Kingdom, we rely on Standard Contractual Clauses (SCCs), adequacy decisions, and other approved mechanisms to ensure your data receives equivalent protection. Ministry and institutional customers may negotiate data residency requirements in their Deployment Agreements.

In sovereign deployments, all data may be stored and processed exclusively within the jurisdiction specified in the Deployment Agreement, with no transfer to Lony’s default infrastructure regions unless explicitly authorized by the contracting authority.

A list of the countries to which we transfer data and the applicable safeguards is available upon request at [email protected].

12. Cookies and Tracking Technologies

We use cookies and similar technologies to maintain session state, analyze Platform usage, and deliver a personalized experience. Our cookies fall into the following categories, together with their legal basis for processing under applicable law:

  • Strictly Necessary Cookies: Required for the Platform to function (e.g., session authentication, security tokens). Legal basis: contractual necessity and legitimate interests. These cannot be disabled.
  • Functional Cookies: Enable enhanced features such as remembered preferences and language settings. Legal basis: legitimate interests (where not materially privacy-invasive) or consent where required by applicable law.
  • Analytics Cookies: Used to understand Platform usage patterns and improve the user experience. Analytics data is pseudonymized and not shared with advertisers. Legal basis: consent. In jurisdictions requiring opt-in consent for analytics cookies (including the EU and UK under ePrivacy rules), we will obtain your explicit consent before setting these cookies.

We do not use third-party advertising or tracking cookies. You may withdraw or update your cookie consent at any time through our in-Platform cookie consent manager or your browser settings. Withdrawing consent for non-essential cookies will not affect your ability to use core Platform features. Disabling functional cookies may affect your personalization preferences.

13. Data Protection Officer

For users in jurisdictions requiring a Data Protection Officer (DPO), Lony’s DPO can be contacted at:

Data Protection Officer, Lony Inc.
Email: [email protected]
Subject line: “DPO Inquiry”

You also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not handled your personal data in accordance with applicable law.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, legal requirements, or Platform features. We will notify you of material changes via email or in-Platform notification at least 30 days before the change takes effect. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy. If you do not accept the updated Policy, you must cease using the Platform and may close your account.

The effective date displayed at the top of this document reflects the date of the most recent revision. Prior versions of this Privacy Policy are available upon request by contacting [email protected].

15. Contact Us

If you have questions about this Privacy Policy or your personal data, please contact us at:

Lony Inc.
Privacy Inquiries: [email protected]
Security Incidents: [email protected]
General Support: [email protected]
Legal Inquiries: [email protected]