Privacy Policy

PRIVACY POLICY Last updated: August 17, 2026

1. GENERAL PROVISIONS
This Privacy Policy, hereinafter referred to as the “Policy,” explains how 5D Regeneration Holding LLC collects, receives, uses, stores, transfers, and protects the personal data of website users, Customers, Students, and other individuals who interact with our services.

This policy applies when you:

— visit our website;

— use the features available on the website;

— fill out the forms;

— contact us;

— submit an application;

— place or pay for an order;

— purchase or use our services;

— Join the educational program;

— receive consultation or support;

— submit assignments, photos, videos, voice messages, or other materials;

— Complete the verification process for specific programs;

— contact customer support;

— interact with our ads;

— subscribe to marketing messages;

— interact with 5D Regeneration Holding LLC in any other way.

By continuing to use this website, you confirm that you have had the opportunity to review this Policy.

Simply reviewing this Policy does not in itself constitute separate consent in cases where applicable law requires specific, explicit, or written consent.

If you do not agree with this Policy, you may stop using the website and the related services.

Continuing to use this website does not in itself constitute consent to the use of optional analytics or advertising cookies.

For Google Analytics, Google Ads, Meta Pixel, and other optional analytics or advertising technologies, we request a separate user consent via a cookie banner or another applicable mechanism.

Users can opt out of non-essential cookies and continue to use the site's basic features.

 
2. DATA CONTROLLER
The data controller is:

5D Regeneration Holding LLC

Identification Number: 405873684

Registered address:

Georgia, Tbilisi, Vake District, Zakaria Paliashvili Street, Building 41, Entrance 1, Basement

Email for privacy inquiries:

[email protected]

Website:

hondorchyn.com

5D Regeneration Holding LLC defines the primary purposes and means of processing personal data in connection with the website and the services described in this Policy.

In certain cases, a third-party provider may independently determine the purposes of processing certain data in accordance with its own privacy policy and applicable law.

 
3. OUR SERVICES
We provide digital content, informational, educational, and consulting services through our original programs in the areas of self-care, body awareness, aesthetics, appearance, relaxation, posture, breathing exercises, flexibility, strength, and overall well-being.

Unless otherwise specified, our services:

— are informational and educational in nature;

— do not constitute medical advice;

— do not constitute a medical diagnosis;

— are not a form of medical treatment;

— do not constitute medical rehabilitation;

— are not a medical treatment plan;

— are not a substitute for consulting a qualified healthcare professional;

— do not constitute emergency medical or psychological care.

 
4. WHAT PERSONAL DATA MAY WE PROCESS
Depending on the nature of our interaction, we may process the following personal data:

— name;

— last name;

— email address;

— phone number;

— Telegram username;

— data from WhatsApp or another messaging app you use;

— country of residence;

— citizenship, if it is objectively necessary for a specific service;

— age;

— date of birth;

— information on tax residency, when such information is necessary for the application of contractual, payment, sanctions, or other legal restrictions;

— information about the selected Course, Plan, consultation, or other service;

— answers to questions on forms and questionnaires;

— information provided when placing an order;

— payment information;

— information about payment in installments;

— information about returns;

— a history of support requests;

— the content of emails and other messages;

— information about the access granted;

— information regarding completion of the course;

— information on consultations and support;

— assignments and the results of completing them;

— photos;

— video recordings;

— voice messages;

— other materials provided by the user;

— passport number or other identification document, if required by a specific program;

— the country that issued the document;

— the document's validity period;

— a photograph or scan of an identification document, if required by a specific identification procedure;

— electronic signature data and electronic acknowledgment of the terms and conditions;

— the date and time the electronic confirmation was provided;

— information regarding the identification process;

— IP address;

— device type;

— browser type and version;

— an operating system;

— approximate location;

— pages viewed;

— the date and time of the visit;

— duration of the visit;

— information about navigation and clicks;

— cookie identifiers;

— advertising identifiers;

— source of the referral to the website;

— information about the submission of the form;

— technical information related to electronic acceptance or signatures;

— information regarding the granting or revocation of consents;

— information about cookie preferences;

— other information that is objectively necessary for the specific stated purpose.

We strive to collect and process only the data that is necessary and proportionate to the relevant purpose.

 
5. DATA SUBMITTED THROUGH TALLY AND OTHER ELECTRONIC FORMS
We use Tally and may use other technical services to host and process electronic forms.

Depending on the purpose of a particular form, it may be used to collect:

— name;

— last name;

— email;

— phone number;

— Telegram or another contact;

— country of residence;

— date of birth;

— the selected service;

— answers to questions;

— text messages;

— photos;

— uploaded files;

— information from an identification document, if such a form is specifically intended for identification purposes;

— a photograph or scan of such a document;

— electronic signature;

— active checkboxes;

— information regarding the acceptance of special terms and conditions;

— information regarding the consent provided;

— date and time of dispatch;

— other technical information related to submitting the form.

5D Regeneration Holding LLC determines the purposes for which the data collected through our forms is processed.

The relevant form provider processes the data as a technical service provider within the scope of the contractual and legal requirements applicable to it.

Do not submit medical records, diagnoses, or other sensitive information through standard forms unless the form specifically requests that information and explains the purpose for which it is being requested.

For the “5D Regeneration Method Expert” course, the special registration form requires the submission of certain identification information, a photograph or scan of an identification document, and an electronic signature.

Such information must be submitted only through the form or other channel that we have specifically designated for the relevant procedure.

 
6. IDENTIFICATION OF PARTICIPANTS IN THE “5D REGENERATION METHOD EXPERT” COURSE
Each actual student enrolled in the “5D Regeneration Method Expert” course must undergo mandatory identification before being granted personal access.

This identification is carried out regardless of whether:

— Does the student pay for the course themselves?;

— Is the course being paid for by another individual?;

— Is the course being paid for by a legal entity?

The purpose of identification is to verify the identity of the specific individual who is granted personal access and who accepts the Course’s special terms and conditions.

As part of the identification process, we may request:

— full first and last name as stated on the document;

— date of birth;

— citizenship;

— country of permanent residence;

— information on tax residency, when such information is objectively necessary;

— the number of a valid passport or other previously agreed-upon official identification document;

— the country that issued the document;

— the document's validity period;

— a photograph or scan of the page of the document containing the owner’s basic identification information and photograph;

— a current email address;

— an electronic signature;

— the date and time of signing;

— information regarding the version of the adopted special terms and conditions;

— technical information necessary to verify the electronic transaction and the expression of intent;

— the result of the identity verification process.

This data is processed for the following purposes:

— identification of the actual student;

— confirmation of who is granted personal access;

— preventing the transfer of access to another person;

— confirmation of the relationship between a specific Student and the special contractual terms accepted by that Student;

— documenting electronic acceptance and electronic signatures;

— issuance of a certificate of completion of the author’s program, if applicable;

— the application of contractual, sanctions-related, payment-related, and other lawful restrictions;

— preventing fraud and other abuses;

— protection of the contractual rights of 5D Regeneration Holding LLC;

— protection of the intellectual property of the Contractor and the relevant rights holder;

— to establish the facts and protect rights in the event of a dispute regarding a participant’s identity, the access granted to them, their acceptance of the terms and conditions, or their use of the Training Materials.

Providing the information required for identification—including a photo or scan of an ID document and an electronic signature—is a mandatory requirement for gaining access to the “5D Regeneration Method Expert” course.

If the actual Student refuses to provide the information objectively necessary for such identification, access to the “5D Regeneration Method Expert” course will not be granted.

For other courses, as a general rule, you are not required to provide a photo or a scan of your passport.

The legal basis for processing the relevant ordinary personal data may be the need to enter into and perform a contractual relationship with the actual Student, to take actions at the Student’s request, to comply with legal obligations, and/or to protect the vital legitimate interests of 5D Regeneration Holding LLC or the relevant Rights Holder to the extent permitted by law.

If a particular method of processing specific data falls into a category for which applicable law requires a specific legal basis, written consent, or additional safeguards, such processing shall be carried out only if those requirements are met.

 
7. IDENTIFICATION DOCUMENTS AND PHOTOGRAPHS
We use identification documents solely for the stated purposes of identification and the protection of rights.

We do not use the photo included in a passport or other document:

— for advertising profiling;

— to analyze physical appearance;

— for analyzing emotions;

— for automatically assessing health status;

— to create marketing audiences;

— for purposes other than those related to the stated identification procedure.

We do not create biometric templates or use automatic facial recognition systems as part of the standard identification procedure for participants in the “5D Regeneration Method Expert” course.

If a specific use of an image, document, or other identifying information is classified as the processing of biometric data under applicable law, such processing shall be carried out only if there is a legal basis, necessity, proportionality, and appropriate additional safeguards.

 
8. PHOTOS, VIDEOS, VOICE MESSAGES, AND OTHER MATERIALS
As part of certain Courses or services, a Student may provide:

— photos;

— video;

— voice messages;

— questionnaires;

— assignments;

— text responses;

— other materials.

Depending on the specific service, these materials may be used for:

— providing consultation;

— an educational visual analysis;

— providing educational feedback;

— assignment checks;

— discussions regarding the Program’s progress;

— a response to the inquiry;

— the provision of support;

— establishing an individual baseline and tracking progress within the framework of the relevant program.

We do not publish photos, videos, reviews, visual comparisons, success stories, or other identifying materials related to the Student in advertisements without separate, applicable consent.

We do not use such visual materials for automatic facial recognition or to create a biometric template unless there is an appropriate legal and organizational procedure in place for such independent processing.

 
9. HEALTH DATA AND OTHER SPECIAL CATEGORIES OF DATA
Certain information, photos, or responses provided in connection with our services may directly or indirectly reveal information about a person’s physical or mental health.

Such data is processed only if there is a specific stated purpose and an applicable legal basis.

Depending on the circumstances, this may require separate written or electronic consent.

If separate consent is required, it:

— is requested separately from the general acceptance of the Public Offer;

— relates to a specific purpose of processing;

— is provided through active action;

— is not considered to have been provided solely as a result of visiting the website;

— is not considered to have been provided solely as a result of the adoption of this Policy.

We do not create medical records for students, nor do we use such information to provide medical diagnoses or treatment.

Do not provide medical records, medical test results, or diagnoses unless they are specifically requested for a particular legitimate purpose.

 
10. PURPOSES OF PERSONAL DATA PROCESSING
We may process personal data for the following purposes:

— processing applications;

— answers to questions;

— entering into contracts;

— processing orders;

— payment processing;

— arranging payment in installments;

— the provision of digital content;

— setting up personal access;

— the provision of educational services;

— providing consultations;

— the provision of support;

— checking assignments;

— providing educational feedback;

— identifying the actual participants in specific programs;

— confirmation that access is for personal use;

— documenting the acceptance of special contractual terms;

— documentation of electronic signatures and electronic acceptance;

— issuing certificates;

— preventing the transfer of access;

— preventing fraud and abuse;

— customer support;

— technical support;

— processing return requests;

— performing accounting duties;

— compliance with tax obligations;

— fulfilling other legal obligations;

— the imposition of contractual, sanctions-related, or payment restrictions;

— website security;

— account security;

— ensuring information security;

— intellectual property protection;

— protection of contractual rights;

— the assertion, consideration, or defense of legal claims;

— dispute resolution;

— maintaining the necessary business records;

— analysis of website usage;

— to improve our website and our services;

— measuring the effectiveness of advertising when users have the necessary choice;

— conducting advertising campaigns;

— remarketing, provided the necessary consent or other legal basis exists;

— sending marketing messages when separate consent has been obtained;

— the pursuit of other compatible and lawful purposes, about which the data subject is duly informed.

 
11. LEGAL BASIS FOR PROCESSING
Depending on the specific situation, we may process personal data based on:

— the data subject's consent;

— the necessity of entering into and performing the contract;

— the need to enter into and perform a specific contractual relationship with the actual Student, if the Purchaser and the Student are different individuals;

— actions taken at the request of the data subject prior to the conclusion of a contract;

— the need to review the individual’s application or request and provide the individual with the appropriate service;

— fulfilling the duties established by law;

— the need to protect the vital legitimate interests of 5D Regeneration Holding LLC or a third party, provided that the rights and freedoms of the data subject do not take precedence;

— ensuring the security of the website and information systems;

— preventing fraud and abuse;

— protection of personal access;

— intellectual property protection;

— protection of rights in the event of a dispute;

— other grounds provided for by applicable law.

If the processing is based on our legitimate interests, such interests may include, depending on the situation:

— identifying the actual participant in the special program;

— preventing unauthorized transfer of access;

— fraud prevention;

— ensuring information security;

— intellectual property protection;

— documenting the assumption of contractual obligations;

— protection against unlawful claims;

— asserting or defending legal claims.

Consent is used as a legal basis only in cases where it is, in fact, an appropriate basis.

If providing specific data is a prerequisite for accessing a particular service, we will inform you of this before or at the time the data is collected, and we will also explain the consequences of refusing to provide the required data.

 
12. GOOGLE ANALYTICS
With the user's consent, we may use Google Analytics to analyze website traffic and usage.

Google Analytics may collect:

— IP address;

— information about the device;

— browser information;

— approximate location;

— pages visited;

— transition source;

— duration of the visit;

— user activity on the website;

— cookie identifiers;

— other technical and analytical information.

Google Analytics is used to analyze and improve the website and its performance.

If a user rejects optional analytics cookies, Google Analytics should not be activated in the section that requires the relevant consent.

 
13. GOOGLE ADS
With the user’s consent, we may use Google Ads to:

— placing advertisements;

— measuring advertising conversions;

— analyzing the effectiveness of advertising campaigns;

— creating advertising audiences;

— remarketing;

— ad optimization.

Depending on the settings, Google Ads may receive:

— IP address;

— cookie identifiers;

— browser data;

— these devices;

— information about the pages visited;

— data on interactions with ads;

— data regarding the occurrence of a specific event on the website.

We do not intend to share the following through Google Ads:

— passport information;

— copies of identification documents;

— photos for consultations or visual analysis;

— medical information;

— detailed responses from sensitive questionnaires;

— other special categories of data.

If non-essential advertising cookies are rejected, the corresponding advertising technologies must not be activated in the areas that require consent.

 
14. META PIXEL
With the user's consent, we may use Meta Pixel.

Meta Pixel can receive:

— information about page views;

— information about interactions with buttons or links;

— information regarding registration or purchase;

— IP address;

— these devices;

— browser data;

— cookies and advertising identifiers;

— transition source.

Meta Pixel is used for:

— measuring the effectiveness of advertising;

— conversion analysis;

— building advertising audiences;

— remarketing;

— optimizing advertising campaigns.

We do not intend to transmit the following via the Meta Pixel:

— passport information;

— copies of documents;

— photos for consultations;

— health information;

— detailed responses to sensitive questionnaires;

— other special categories of personal data.

 
15. WEGLOT
We use Weglot to provide different language versions of the website.

Depending on the technical implementation, Weglot can process:

— the URL of the page visited;

— selected language;

— language settings;

— IP address;

— browser and device specifications;

— the original and translated content of the page;

— other technical information necessary for the translation.

If a technology is objectively necessary to provide the language version specifically selected by the user, it may be used as an essential or functional technology.

 
16. LINKTREE
We can use Linktree to post links to:

— our website;

— social media;

— electronic forms;

— food;

— educational materials;

— other online resources.

After switching to Linktree, the user begins interacting with a separate third-party platform.

Linktree may collect information on its own in accordance with its privacy policy, including:

— IP address;

— browser data;

— these devices;

— approximate location;

— information about transfers;

— click data;

— analytical data.

We do not determine all of Linktree’s data processing purposes on our own, and we recommend that you review Linktree’s own privacy policy.

 
17. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small files or other pieces of information that are stored on or read from a user’s device.

We can use:

— cookie;

— pixels;

— tags;

— scripts;

— local storage;

— other similar technologies.

Such technologies can be classified as follows:

Required Technologies

They can be used for:

— website operations;

— ensuring safety;

— saving user settings;

— works in the requested formats;

— displaying the selected language version;

— performing the function specifically requested by the user.

Optional Analytics and Advertising Technologies

These may include:

— Google Analytics;

— Google Ads;

— Meta Pixel;

— advertising remarketing;

— optional behavioral analytics.

 
18. COOKIE CONSENT
A cookie banner may appear when a user visits the site for the first time.

The user can:

— accept optional cookies;

— Reject non-essential cookies.

Selecting "Accept" may activate the corresponding analytics and advertising technologies.

If you select “Decline,” optional analytics and advertising technologies that require consent must not be activated.

The necessary technologies can continue to operate regardless of this choice.

Opting out of non-essential cookies should not prevent the user from accessing the main content of the website.

Users can also delete or block cookies through their browser settings.

 
19. DIRECT MARKETING
We may send advertising and marketing messages only if there is an appropriate legal basis and, where required, the user’s separate consent.

Marketing messages can be sent via:

— email;

— SMS;

— Telegram;

— WhatsApp;

— other channels specified by the user.

Users may opt out of direct marketing at any time.

To do this, you can:

— click the unsubscribe link;

— reply to the relevant message;

— send an email to [email protected];

— Contact customer support.

Opting out of marketing messages does not affect your receipt of necessary service messages related to:

— payment;

— access;

— safety;

— consultations;

— changes to the order;

— performance of the contract;

— legally required notices.

 
20. SEPARATE CONSENT FOR THE MARKETING USE OF PHOTOGRAPHS AND OTHER MATERIALS
Photographs, videos, reviews, results stories, visual comparisons, or other materials that identify the Student are not used by us for marketing purposes solely based on the purchase of the Course or acceptance of this Policy.

If we want to use materials such as:

— in advertising;

— on the website;

— on social media;

— in advertisements;

— in presentations;

— in marketing publications;

— in other promotional materials,

We request separate, voluntary consent in cases where this is required by applicable law.

Such consent:

— is not a requirement for purchasing the Course;

— is not a requirement for receiving Support;

— is processed separately;

— cannot be marked in advance on behalf of the student;

— may be revoked in accordance with applicable law.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to its effective withdrawal.

 
21. TRANSFER OF DATA TO THIRD PARTIES
For the stated purposes, personal data may be transferred to or made available to the following categories of recipients:

— Tally;

— Google;

— Meta;

— Weglot;

— Linktree;

— hosting providers;

— cloud service providers;

— educational platforms;

— payment systems;

— banks;

— email service providers;

— messaging app providers;

— IT vendors;

— data storage services;

— accountants;

— auditors;

— lawyers;

— consultants;

— contractors;

— educational support specialists;

— technical specialists;

— to government agencies in cases provided for by law;

— to other recipients, if the transfer is objectively necessary and has an appropriate legal basis.

Vendors that process data on our behalf must use the data within the scope of the agreed-upon purposes and applicable obligations.

Some companies, including certain Google, Meta, and Linktree services, may independently determine specific purposes for processing data.

If an identity document is uploaded via an electronic form service, a cloud service, or another technical platform, the relevant provider may technically process and/or store that file to the extent necessary to provide the relevant service.

Such technical provision of access does not, in and of itself, imply that the provider is granted the right to use the document for incompatible, independent purposes.

 
22. INTERNATIONAL TRANSFER OF PERSONAL DATA
Some of the service providers we use may process personal data outside of Georgia.

Depending on the service used, data may be processed:

— in the European Economic Area;

— in the United Kingdom;

— in the U.S.;

— in Australia;

— in other countries where the relevant suppliers operate.

International transfers of personal data are carried out only if there is an appropriate legal framework and the necessary safeguards are in place.

Depending on the situation, such guarantees may include:

— data processing agreements;

— contractual guarantees;

— standard contract terms or other contractual mechanisms;

— transfer to a country with a recognized adequate level of protection;

— a specific legal basis provided for by law;

— the data subject’s consent, if it can be properly relied upon as a basis;

— other mechanisms provided for by law.

When transferring data internationally, we take reasonable measures to ensure the required level of data protection.

 
23. RETENTION PERIODS
We do not retain personal data indefinitely solely on the basis that an individual has ever interacted with us.

The shelf life is determined based on:

— the purposes of the processing;

— the nature of the data;

— the selected service;

— the term of the contractual relationship;

— the need to grant access;

— accounting requirements;

— tax claims;

— applicable statutes of limitations;

— the need to assert or defend claims;

— the need to resolve the dispute;

— information security requirements;

— consent status;

— legal requirements.

Specifically:

— Application data is retained for the time necessary to process the applications and for a reasonable period thereafter;

— Customer and contractual data may be retained for the duration of the relevant relationship and the applicable statute of limitations;

— Payment and accounting documents are retained for the period required by law;

— Support service correspondence may be retained for the duration of the issue’s resolution and for a reasonable period thereafter;

— Information about consents may be stored to confirm the user's choice;

— Information regarding electronic acceptance and electronic signatures may be retained for the period necessary to confirm contractual relationships and protect rights;

— Analytical and advertising data is stored in accordance with the relevant settings and policies of the services used.

Data of Participants in the “Expert
” Program The personal information of students enrolled in the “Expert ” course may be retained for as long as is objectively necessary to:

— proof of the participant's identity;

— compliance with the specific terms and conditions of the Course;

— issuing and validating the certificate;

— protection of the personal nature of access;

— intellectual property protection;

— asserting or defending contractual claims;

— resolution of a potential dispute;

— compliance with mandatory legal requirements.

A photograph or scan of an identification document is not retained for longer than is objectively necessary for the specified purposes.

Once the document is no longer needed, the copy shall be deleted, destroyed, blocked, or otherwise processed in a manner prescribed by law, unless its continued retention is required on an independent legal basis.

Specific details confirming the identification process, such as:

— name;

— document number;

— country of issuance;

— date of identification;

— audit result;

— information regarding the signing of special terms and conditions,

may be stored separately from the document itself for the applicable period during which contractual and legal rights are protected.

Once the required retention period has expired, personal data is deleted, destroyed, blocked, or anonymized in accordance with applicable law.

 
24. PERSONAL DATA SECURITY
We take reasonable technical and organizational measures to protect personal data from:

— unauthorized access;

— accidental loss;

— unauthorized disclosure;

— unauthorized modification;

— destruction;

— copying;

— distribution;

— other forms of unlawful processing.

Measures may include:

— access control;

— password protection;

— use of secure data transmission;

— organizational confidentiality policies;

— restrictions on the authority of employees and contractors;

— backup;

— access control;

— safety monitoring;

— incident response;

— the use of contractual requirements for technical suppliers;

— other measures appropriate to the nature and risk of the specific processing.

No method of electronic transmission or storage can guarantee absolute security.

In the event of a personal data breach, we take measures in accordance with applicable law.

Enhanced Protection of Identification Documents
Access to passport information and copies of documents belonging to participants in the “5D Regeneration Method Expert” course is restricted to individuals who objectively require such access for:

— conducting identification;

— managing individual access;

— the performance of specific contractual obligations;

— compliance with legal requirements;

— information security;

— protection of contractual rights;

— intellectual property protection;

— resolution of legal disputes.

We take reasonable measures to prevent unauthorized:

— views;

— downloads;

— copying;

— shipments;

— distribution;

— any other use of such documents.

 
25. RIGHTS OF THE DATA SUBJECT
Subject to applicable law, the data subject may have the right to:

— to find out whether we are processing his or her personal data;

— to obtain information about the purposes of the processing;

— obtain information about the legal basis;

— access your data;

— obtain a copy of the data;

— request that inaccurate information be corrected;

— request an update to the data;

— to request the deletion of data in cases provided for by law;

— request that the data be blocked;

— to request that certain processing be stopped;

— withdraw consent if the processing is based on consent;

— to stop direct marketing;

— obtain information about recipients or categories of recipients;

— to obtain information about an international transfer;

— exercise other rights provided for by applicable law;

— file a complaint with the appropriate regulatory authority;

— file a lawsuit.

To exercise your rights, please contact us:

Email: [email protected]

Email Subject: Request Regarding Personal Data

To prevent the disclosure of information to an unauthorized person, we may request additional information to verify the applicant's identity.

Such confirmation is requested only to the extent objectively necessary for the relevant purpose.

Certain rights may be restricted in cases expressly provided for by applicable law, such as when certain data must be retained to comply with a legal obligation or to defend against legal claims.

 
26. WITHDRAWAL OF CONSENT
If a specific processing activity is based on consent, the data subject has the right to withdraw such consent in accordance with the procedures provided for by applicable law.

Withdrawal of Consent:

— does not affect the lawfulness of processing carried out prior to the withdrawal;

— does not necessarily require the deletion of data if, following the withdrawal of consent, there is an independent legal basis for processing or storing the data.

If the processing of an Expert participant’s mandatory identification data is based not on consent but on another applicable legal basis, the withdrawal of marketing or other non-mandatory consent does not terminate such separate lawful processing.

 
27. GDPR
If the General Data Protection Regulation (GDPR) applies to a particular processing of personal data, the data subject may additionally have the rights provided for under the GDPR, including, depending on the circumstances:

— the right of access;

— the right to correction;

— the right to erasure;

— the right to restrict processing;

— the right to data portability;

— the right to object to certain processing;

— the right to withdraw consent;

— the right to file a complaint with the appropriate regulatory authority;

— other applicable rights.

The applicability of the GDPR is determined by the relevant legislation and the specific circumstances of the processing.

Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

 
28. MINORS
Some of our programs may be offered to minors with the participation of a parent or other legal guardian.

When processing a minor’s personal data, we take the following into account:

— the child's age;

— the nature of the data being processed;

— legal basis;

— the requirement for parental consent;

— the best interests of the minor;

— additional requirements under applicable law.

If the processing of a minor’s ordinary personal data is based specifically on the minor’s consent, the age requirements set forth by law apply.

For a minor under the age specified by law, consent in the cases provided for by law must be given by a parent or other legal representative.

Special categories of a minor’s personal data may be processed only if there is an appropriate legal basis and the necessary safeguards are in place.

If the applicable law requires the written consent of a parent or legal guardian for such processing, the processing will not be carried out without such consent.

We take reasonable steps to verify the relevant authority of a parent or legal guardian when necessary.

If we learn that a minor’s personal data was collected without the necessary legal basis, measures will be taken to cease or lawfully rectify the relevant processing.

 
29. AUTOMATED DECISION-MAKING
As a general rule, we do not rely solely on automated decision-making that results in legal or comparably significant consequences for the user based on a passport photo, visual materials provided by the Student, or medical information.

If, in the future, processing subject to special rules for automated decision-making is implemented, the user will be provided with the information and safeguards required by applicable law.

 
30. THIRD-PARTY WEBSITES AND SERVICES
The website may contain links to third-party websites and platforms.

When a user clicks on an external link, they begin interacting with the corresponding third-party service.

We do not control all independent data processing activities carried out by third parties and are not responsible for:

— content from a third-party website;

— its availability;

— its own security measures;

— the independent purposes for which the relevant third party processes the data.

Before using a third-party service, we recommend that you review its privacy policy.

 
31. CHANGES TO THIS POLICY
We may periodically update this Policy.

The reasons for these changes may include:

— changes to our services;

— changes to the website's structure;

— enabling or disabling technical services;

— changes in data processing methods;

— changes in legislation;

— changes in safety requirements;

— changes in identification processes;

— other objective circumstances.

The current version is published on the website, along with the update date.

Significant changes may also be communicated to the affected individuals in an accessible and reasonable manner.

 
32. COMPLAINTS
If you have any questions or concerns regarding the processing of personal data, you may first contact us directly:

[email protected]

You also have the right to file a complaint with the competent supervisory authority in Georgia or with a court in accordance with applicable law.

If the GDPR or other applicable foreign law applies to the relevant processing, the data subject may also have the right to lodge a complaint with the competent supervisory authority in the relevant jurisdiction.

 
33. CONTACT INFORMATION
5D Regeneration Holding LLC

Identification Number: 405873684

Registered address:

Georgia, Tbilisi, Vake District, Zakaria Paliashvili Street, Building 41, Entrance 1, Basement

Email:

[email protected]

Website:

hondorchyn.com

 
34. GOVERNING LAW
This Policy is governed by the laws of Georgia, including applicable data protection laws.

If the GDPR or other mandatory data protection laws apply to a specific processing activity, such processing is also carried out in accordance with the relevant mandatory requirements.