Privacy Policy
SULIKOMAS – Business English Lessons
Effective as of: April 18, 2026
Last revised: April 18, 2026
1. Introduction
Suliko Arjevaniidze („Controller“ or „we“, „us“, „our“), a sole trader operating under an individual activity certificate pursuant to Lithuanian law, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.sulikomas.com (the „Site“), book online Business English lessons, or otherwise engage with our services.
We operate in full compliance with the General Data Protection Regulation (EU) 2016/679 („GDPR“) and the Lithuanian Law on Legal Protection of Personal Data. As the data controller, we determine the purposes and means of processing your personal data.
2. Controller Details
Suliko Arjevanidze
Pakruojo g. 8-8, LT-92269 Klaipėda, Klaipėda County, Lithuania
Email: privacy@sulikomas.com
Website: www.sulikomas.com
We self-manage GDPR compliance and do not have a Data Protection Officer. For complaints, contact the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija, ADA) at www.ada.lt or ada@ada.lt.
3. What Personal Data We Collect
3.1 Identity and Contact Data
Full name, Email address, Phone number (including WhatsApp), Company name, Job title, Company VAT number (for invoicing)
3.2 Booking and Course Data
Preferred timezone, Self-assessed English level, Lesson preferences and special requests, Rescheduling requests
3.3 Assessment and Progress Data
Spoken English level assessment (e.g., A2/B1 ratings for accuracy, fluency, vocabulary), Professional strengths (e.g., discussing HR, corporate culture), Areas for improvement (e.g., grammar, linking words), Sample speech corrections, Personalized 5-hour course plans with topics like workplace culture, comparatives, employee retention
3.4 Lesson Delivery Data
Class notes (vocabulary, pronunciation tips, grammar suggestions), Lesson materials and plans, Lesson history and scheduling, Payment history, Course preferences and feedback
3.5 Technical Data
Device type, Pages visited and time spent, Last login timestamp, IP address (for security only)
3.6 Payment Data
Transaction confirmations and invoice details
⚠️ Important notes
We do not collect or store bank/card details – all payments are processed securely by Revolut UAB via embedded gateway.
We never collect special category data (e.g., health, religion, political opinions).
Geographical location data is used only for anonymous traffic analytics and not stored or linked to individuals.
No video recordings are stored unless specifically requested by you (expire within 30 days, misuse may result in termination of your course. Visit terms).
Live transcripts are deleted immediately after generating class notes.
4. How and Why We Use Your Data
4.1 Purposes and Legal Bases
We only process personal data where we have a lawful basis under GDPR Article 6. Here's each purpose explained:
- Booking, scheduling, delivering lessons via Google Meet
Uses: All data categories above
Legal basis: Contract performance (Art. 6(1)(b))
- Sending automated notifications (session confirmations, materials, rescheduling, renewals, no-shows)
Uses: Contact data, booking data
Legal basis: Contract performance + Legitimate interests (Art. 6(1)(b)/(f))
Our interest: Service delivery and keeping you engaged
- Generating assessments, class notes, progress reports, yearly recaps
Uses: Assessment data, lesson data
Legal basis: Contract performance (Art. 6(1)(b))
- Processing payments, issuing invoices
Uses: Payment data, contact data
Legal basis: Contract performance + Legal obligation (Art. 6(1)(b)/(c))
- Website analytics and improvement
Uses: Technical data
Legal basis: Legitimate interests (Art. 6(1)(f))
Our interest: Improving site functionality (balanced against your privacy rights)
- Security and fraud prevention
Uses: Technical data, payment data
Legal basis: Legitimate interests (Art. 6(1)(f))
Our interest: Protecting our legitimate business interests
- Promotional emails (maximum 1 email to publicly available professional contacts from LinkedIn/company sites)
Uses: Contact data
Legal basis: Legitimate interests (Art. 6(1)(f))
Our interest: Business development (strictly limited scope with clear opt-out)
4.2 Legitimate Interests Assessment
For legitimate interests processing:
Necessity: Essential for business operations.
Balancing test: Minimal data, clear opt-out options, no sensitive information.
Your rights: You can object anytime (see Section 7).
Automated decision-making: None. All recommendations are based on professional teacher assessment. AI tools (Perplexity Pro) receive only anonymized data.
5. Cookies and Similar Technologies
Our Site uses cookies managed by Wix.com. You see a cookie banner on first visit to manage preferences.
Essential cookies – Purpose: Site functionality, forms, security, payments. Provider: Wix. Duration: Session/Persistent. Legal basis: Legitimate interests.
Analytics cookies – Purpose: Traffic analysis, device data, page views. Provider: Wix. Duration: Up to 1 year. Legal basis: Legitimate interests (opt-out available).
Functional cookies – Purpose: Wix Chat widget, CMS storage. Provider: Wix. Duration: Persistent. Legal basis: Contract performance.
Marketing cookies – None currently active. Would require opt-in consent if added.
Non-essential cookies require opt-in consent. You can withdraw consent anytime via cookie settings. See Wix Cookie Policy for technical details.
6. Third Parties and International Transfers
We share data only with trusted processors under data processing agreements (DPAs):
- Wix.com – Purpose: Hosting, CMS, forms, chat, automated emails. Location: Ireland (EEA). Safeguards: Wix DPA.
- Revolut UAB – Purpose: Payment processing. Location: Lithuania (EEA). Safeguards: Revolut terms.
- Google Workspace – Purpose: Calendar invites (rescheduling only). Location: EEA/US. Safeguards: EU Standard Contractual Clauses (SCCs).
No data sales or sharing with advertisers. All transfers outside EEA use SCCs or adequacy decisions.
7. Data Retention Periods
- Lesson bookings, assessments, class notes – Retained until account termination (your request or inactivity per Terms) + 3 months anonymized period, then permanently deleted. Reason: Contract completion.
- Invoices, payment records – Retained for 10 years. Reason: Lithuanian tax/accounting law.
- Technical data – Retained per Wix defaults (up to 1 year). Reason: Service improvement.
- Marketing contacts – Retained until you opt-out or 2 years of inactivity. Reason: Legitimate interests.
After retention, data is permanently deleted or irreversibly anonymized. You can request access to retained invoices.
8. Your GDPR Rights
You have the following rights under GDPR Chapter III:
Access your data
Rectification of inaccurate data
Erasure („right to be forgotten“)
Restriction of processing
Data portability (structured format)
Object to processing (especially marketing)
Withdraw consent (no effect on prior processing)
8.1 How to Exercise Your Rights
Email privacy@sulikomas.com with:
Your full name
Specific request
Proof of identity (if requested)
Response time: 1 month (extendable by 2 months for complex cases). No fee unless requests are excessive. We verify identity before disclosure.
Complaints: Contact ADA (www.ada.lt) if unsatisfied with our response.
9. Security Measures
We implement appropriate technical and organizational measures:
Encryption: Special Wix CMS datasets for personal data
Access controls: Limited staff access only
Secure payments: Revolut embedded gateway
Regular backups: Wix infrastructure
No known breaches to date
10. Automated Emails
We send automated notifications for:
Payment confirmations
Session additions/cancellations/rescheduling
Class materials availability
Course renewals
To opt-out: Reply to any email or contact english@sulikomas.com.
11. Children’s Privacy
Our services are adults/professionals only (age 18+). We do not knowingly collect children’s data.
12. Changes to This Policy
We may update this policy. Changes appear on the Site with „Last Updated“ date. Continued use constitutes acceptance.
13. Contact Us
Suliko Arjevaniidze
Pakruojo g. 8-8, LT-92269 Klaipėda, Lithuania
Email: privacy@sulikomas.com
Phone: +370 623 41173 (WhatsApp)
For questions or appeals, contact: english@sulikomas.com
Most recent Privacy Policy is available at sulikomas.com/privacy