Privacy Policy

Last updated: 23 August 2026

Learn Lutadix is the dedicated capability development, professional learning and knowledge-transfer division of Lutadix. Learn Lutadix is operated by Lutadix OÜ, a private limited company registered in the Republic of Estonia. Learn Lutadix is a division and brand, not a separate legal entity.

This policy explains how Lutadix OÜ (“Lutadix”, “we”, “us” or “our”) processes personal data collected through learn.lutadix.com and in connection with the professional learning and knowledge-transfer services offered under the Learn Lutadix brand. Lutadix OÜ is the controller of that personal data, unless a specific engagement establishes a different arrangement (for example, where we act as a processor for a client organization).

1. Controller and Contact Details

Lutadix OÜ
Registry code: 50318965
Registered office: Tallinn, Estonia
Registered address: Tartu mnt 67/1-13b, Kesklinna linnaosa, Tallinn, Harju maakond 10115, Estonia
Corporate email: info@lutadix.com
Learn Lutadix enquiries: contact@learn.lutadix.com

Estonia is the legal jurisdiction of Lutadix OÜ. Learn Lutadix serves organizations internationally.

2. Personal Data We Collect

We collect only what you choose to provide and the limited technical information necessary to operate the website securely.

• Enquiry data submitted through our forms: name, organization, country, business email address, telephone country code and telephone number, the training requirement selected, and the content of your message.
• Correspondence: emails and other communications exchanged with our team, including any professional role or programme details you choose to share.
• Limited technical data: the browser user-agent string recorded with a form submission, and standard server and security logs generated by our hosting infrastructure.

We do not request or collect passport data, national identification numbers, payment-card data, educational records, examination results, certificates, or special categories of personal data through this website. The website does not currently offer public account registration, online payment, or a newsletter subscription.

3. Corporate Contacts and Participants

Most personal data we receive relates to corporate contacts — individuals who contact us on behalf of an organization about learning or capability-development requirements.

Where a programme is subsequently agreed, a client organization may provide us with limited administrative details of participants (such as name, business email and role) so that sessions can be organized and delivered. This happens only in the context of an actual engagement; participant data is not routinely received from every client, and none is collected through this website.

4. Purposes and Legal Bases

• Responding to enquiries and preparing programme information or proposals — enquiry data and correspondence. Legal basis: steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR); where you write on behalf of an organization, our legitimate interest in responding to business enquiries addressed to us (Art. 6(1)(f) GDPR).
• Organizing and delivering agreed learning programmes and administering participation — corporate contact and participant administration data. Legal basis: performance of a contract with the client organization, or our legitimate interest in performing that contract in relation to individuals who are not themselves a party to it (Art. 6(1)(b) and 6(1)(f) GDPR).
• Maintaining the security, availability and integrity of the website and our systems — technical and log data. Legal basis: our legitimate interest in preventing abuse and securing our services (Art. 6(1)(f) GDPR).
• Meeting accounting, tax and other legal obligations — contractual and business records. Legal basis: compliance with a legal obligation (Art. 6(1)(c) GDPR).

5. Marketing Communications

Learn Lutadix does not currently operate a newsletter or send unsolicited promotional campaigns from this website. Replying to your enquiry and sending the programme information you requested is not marketing. If we introduce marketing communications in future, they will be sent only where consent is required and obtained, and every message will include a means to withdraw consent, which you may also do at any time by contacting us.

6. Recipients and Processors

We do not sell personal data. We share it only where necessary, with providers acting on our instructions under written data-processing terms, and with professional advisers or authorities where legally required. Current categories of recipients are:

• website hosting and application infrastructure providers;
• our managed database provider, where form submissions are stored;
• our email relay and business email providers, used to deliver and receive enquiry correspondence;
• professional advisers (for example legal or accounting), where relevant.

Where a specific programme requires a subject-matter expert or delivery partner, only the information necessary for that programme is shared, and only for that engagement.

7. International Delivery and International Transfers

Learn Lutadix works with organizations internationally. Delivering a programme internationally does not by itself mean personal data is transferred outside the European Economic Area (EEA). Where a service provider or a client engagement does involve a transfer of personal data outside the EEA, we rely on an adequacy decision of the European Commission or on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, together with any additional measures required in the circumstances. You may request further information about the safeguards applied to a specific transfer.

8. Retention

We keep personal data only as long as necessary for the purpose for which it was collected:

• enquiries that do not lead to an engagement: retained while the opportunity remains active and for a limited follow-up period thereafter, then deleted;
• client and programme records: retained for the duration of the relationship and for the period necessary to establish, exercise or defend legal claims;
• accounting and other records subject to statutory retention: retained for the period required by applicable Estonian and EU law;
• technical and security logs: retained for a short period appropriate to their security purpose.

9. Security

We apply appropriate technical and organizational measures to protect personal data, including encrypted transport (HTTPS), access controls limiting access to personnel who need it, database access restrictions, and use of reputable infrastructure providers. No method of transmission or storage can be guaranteed to be absolutely secure, and we make no such guarantee. We do not claim any certification, audit or standards accreditation.

10. Your Rights

Subject to the conditions and limitations in applicable law, you have the right to:

• request access to the personal data we hold about you;
• request rectification of inaccurate or incomplete data;
• request erasure of your data;
• request restriction of processing;
• object to processing based on our legitimate interests;
• receive your data in a portable format where the right applies;
• withdraw consent at any time where processing is based on consent, without affecting prior processing;
• lodge a complaint with a competent supervisory authority.

To exercise a right, contact info@lutadix.com or contact@learn.lutadix.com. We may need to verify your identity before responding. Where we act as a processor for a client organization, requests are referred to that organization.

11. Supervisory Authority

The Estonian supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), www.aki.ee/en. You may also lodge a complaint with the supervisory authority of your country of residence or place of work.

12. Cookies and Similar Technologies

learn.lutadix.com does not use advertising cookies, analytics cookies or third-party tracking scripts. Browser storage is used only where strictly necessary for the website to function — for example to keep a session active if you sign in to a restricted area. Because no non-essential technologies requiring consent are in use, no cookie consent banner is presented. If this changes, we will update this policy and introduce a consent mechanism where required.

13. Automated Decision-Making

We do not carry out automated decision-making producing legal or similarly significant effects, participant profiling, automated assessment, or AI-based selection of individuals.

14. Children

Learn Lutadix provides services to organizations and working professionals. The website is not directed at children, and we do not knowingly collect personal data from them. If programmes involving minors are introduced, this framework will be reviewed separately.

15. Changes to This Policy

We may update this Privacy Policy as our services, technologies, processing activities or applicable legal requirements change. The date at the top of this page indicates when it was last revised. Material changes will be reflected here before they take effect where practicable.