Privacy Policy

Last updated: September 28, 2026

1. GENERAL PROVISIONS
This Privacy Policy (“Policy”) explains how 5D Regeneration Holding LLC collects, receives, uses, stores, transfers, and protects the personal data of website users, Customers, students, parents, and legal guardians of minors, as well as other individuals who interact with our services.

This Policy applies when you:

visit our website;
use the website’s features;
fill out online forms;
submit an application;
place an order;
purchase a digital educational product;
access the educational platform;
take an educational program;
contact customer support;
purchase a separate personalized educational service;
provide materials as part of such a separate service;
complete the identification process for specific programs;
interact with our advertisements;
subscribe to marketing communications;
otherwise interact with 5D Regeneration Holding LLC.
Reviewing this Policy does not in itself constitute consent in cases where applicable law requires separate, explicit consent.

If a particular processing activity is based on consent, such consent is requested separately and is provided through an active action by the user.

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

 
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:
[email protected]

Phone:
+995577403474

Website:
hondorchyn.com

5D Regeneration Holding LLC defines the main purposes and means of processing personal data in connection with the website, digital educational products, and other services described in this Policy.

Certain third-party providers may independently determine the purposes and means of specific processing operations in accordance with their own terms and conditions, privacy policies, and applicable laws.

 
3. NATURE OF OUR PRODUCTS AND SERVICES
The primary business of 5D Regeneration Holding LLC involves providing digital wellness educational products, including videos, text, images, assignments, and other educational materials, accessible through an educational platform or other digital resources.

These products focus on topics such as body awareness, mindful movement, attention to sensations, relaxation, breathing patterns, visual aesthetics, and overall wellbeing within the framework of the author’s educational model.

Separately, the Company may offer personalized educational feedback, individualized educational support, and other human-delivered educational services.

These services include:

are not automatically considered part of the digital Course;
are processed separately if they are offered to a specific customer;
may have separate terms and conditions;
may require the processing of additional personal data;
may require separate consent for certain types of processing.
Unless otherwise expressly stated, our digital products and educational services:

are for informational and educational purposes only;
do not constitute medical care;
do not constitute a medical diagnosis;
do not constitute treatment;
do not constitute medical therapy;
do not constitute medical rehabilitation;
do not constitute an individualized medical prescription;
do not replace professional medical or dental care.
 
4. WHAT PERSONAL DATA MAY WE PROCESS
Depending on the nature of our interaction, we may process:

Identification and Contact Information
first name;
last name;
email address;
phone number;
Telegram username;
WhatsApp or other messaging app details;
country of residence;
citizenship, if objectively necessary;
age;
date of birth;
tax residency, if objectively necessary.
Order and Product Usage Information
selected Course or Plan;
order details;
payment amount and currency;
payment method;
transaction ID;
information about installment payments;
information about returns;
details regarding digital access provided;
date of registration on the Platform;
details regarding Course usage and progress, if such features are provided by the Platform in use;
support request history.
Electronic Communication
the content of emails;
messages on Telegram or other channels used;
support service inquiries;
other messages sent by the user to the Company.
Data Related to Specific Personalized Educational Services
Only if the relevant specific service has been ordered or requested may we process:

questionnaire responses;
assignments;
photos;
videos;
voice messages;
text descriptions;
user-submitted materials;
annotated copies of submitted materials;
information about educational feedback provided.
Identification data for individual programs
In the cases provided for in this Policy:

passport number or other document number;
country of issue;
expiration date;
photo or scan of the document;
electronic signature;
date and time of signing;
information about the identification process.
Technical Data
IP address;
device type;
browser;
operating system;
approximate location;
pages viewed;
date and time of visit;
referral source;
cookie identifiers;
advertising identifiers;
form submission details;
form or order ID;
electronic acceptance details;
details regarding the granting or withdrawal of consent.
We strive to process only data that is objectively necessary and proportionate to the relevant purpose.

 
5. PAYMENTS
Payments may be made through third-party banks, payment systems, acquirers, payment providers, or other lawful payment intermediaries.

When using a third-party payment provider, some personal and payment information may be provided directly to that provider.

5D Regeneration Holding LLC does not typically receive or store the full credit card number, CVV/CVC, or other complete card authentication details if the transaction is processed through an external payment interface.

We may receive information from the payment provider that is necessary for:

confirmation of a successful payment;
order identification;
accounting;
refunds;
fraud prevention;
dispute or chargeback resolution;
confirmation of payment.
Such information may include:

payer’s name;
email;
country;
amount;
currency;
transaction date;
transaction ID;
payment status;
limited information about the payment instrument;
other information provided by the relevant payment provider.
 
6. ONLINE FORMS AND TALLY
We use Tally and may use other online form services.

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

first and last name;
email;
phone number;
country;
Telegram or other contact information;
selected product;
information about the Buyer and the Student;
answers to questions;
electronic confirmations and checkboxes;
electronic signature;
submission ID;
date and time of submission;
technical information.
For specific forms related to identification or a separately purchased personalized educational service, relevant documents or materials may be requested additionally.

Do not submit medical documents, diagnoses, test results, or other sensitive information through standard forms unless the form specifically requests such information and explains the purpose for which it is being collected.

 
7. EDUCATIONAL PLATFORM AND SENDPULSE
We may use SendPulse and other educational or communication platforms to deliver digital courses.

Technically, these services can process:

name;
email;
account information;
selected Course;
registration date;
information regarding access granted;
technical information regarding the use of the Platform;
information regarding the viewing of lessons or completion of assignments, if the relevant feature is used;
service messages.
This data is used to provide the purchased digital product, technical support, and to document the performance of the contract.

 
8. IDENTIFICATION OF PARTICIPANTS IN THE “5D REGENERATION METHOD EXPERT” COURSE
For actual students of the “5D Regeneration Method Expert” course, mandatory identification may be required before personal access is granted.

As part of the procedure, the following may be requested:

full name;
date of birth;
citizenship;
country of residence;
tax residency, when objectively necessary;
document number;
country of issuance;
validity period;
photograph or scan of the document;
email;
electronic signature;
date and time of the electronic transaction;
version of the accepted terms and conditions;
technical details confirming the electronic transaction.
The purposes of such processing may include:

verification of the Student’s identity;
verification of the personal nature of access;
prevention of unauthorized transfer of access;
documentation of electronic acceptance;
issuance of a certificate;
enforcement of legal, contractual, sanction-related, or payment-related restrictions;
fraud prevention;
protection of intellectual property;
dispute resolution.
For other Courses, a copy of the passport is generally not required.

 
9. IDENTIFICATION DOCUMENTS
Identification documents are used only for the specific purpose stated.

We do not use passport photos:

for advertising profiling;
for physical appearance analysis;
for emotion analysis;
for automatic health status determination;
for marketing audience segmentation.
As part of standard identification procedures, we do not create biometric templates or use automatic facial recognition.

If a specific processing technique is classified by law as the processing of biometric data or other special categories of data, such processing may be carried out only if there is an appropriate legal basis.

 
10. INDIVIDUALIZED EDUCATIONAL SERVICES
If a user separately purchases or requests personalized educational feedback, additional data may be required to provide it.

Depending on the specific service, the user may voluntarily provide:

photos;
videos;
answers to questions;
assignments;
text messages;
voice messages;
other materials explicitly provided for by the relevant format.
Such materials may be used for:

educational visual observation;
discussion of the provided materials;
provision of personalized educational feedback;
educational navigation through the relevant Program materials;
comparison of materials provided by the user at different times;
creation of an annotated copy of the material to be returned to the user as part of the relevant service.
Such processing is carried out only in connection with a separately selected personalized educational service and is not an automatic part of purchasing a digital Course.

 
11. PHOTOGRAPHS AND VISUAL MATERIALS
As part of a separately selected personalized educational service, we can create:

annotated copies of photographs;
images with simple visual markers;
images with arrows, lines, or text annotations;
visual comparisons of materials provided by the user.
These materials are used as educational guides for self-reflection and feedback.

They are not:

medical measurements;
diagnostic markings;
medical reports;
diagnosis of a disease;
determination of a medical norm or pathology;
medical diagnosis.
We do not use such photographs for automatic facial recognition, the creation of biometric templates, or the automated assessment of health status.

 
12. SPECIAL CATEGORIES OF PERSONAL DATA
Depending on the context, certain photos, videos, or user responses may directly or indirectly reveal information related to health or other special categories of personal data.

Such data is processed only:

for a specific stated purpose;
provided there is an appropriate legal basis;
in compliance with the additional requirements of applicable law.
If separate explicit consent is required for processing, it is requested separately from:

Acceptance of a Public Offer;
Review of this Policy;
Consent to Direct Marketing;
Consent to Public Use of Materials.
Consent is granted through an active action by the user.

 
13. PURPOSES OF PROCESSING
Personal data may be processed for the following purposes:

processing requests;
responding to inquiries;
concluding and executing contracts;
processing orders;
processing payments;
providing digital content;
providing personalized access;
managing the educational platform;
documenting the provision of access;
providing technical support;
providing separately purchased personalized educational services;
identifying participants in specific programs;
documenting electronic acceptance;
issuing certificates;
processing refunds;
resolving chargebacks and other payment disputes;
preventing fraud;
protecting personal access;
accounting and tax reporting;
complying with laws;
applying sanctions and payment restrictions;
protecting intellectual property;
defending legal claims;
ensuring information security;
maintaining necessary business records;
analyzing website usage;
improving the website and services;
advertising analytics where there is a valid basis;
direct marketing where there is a valid basis.

14. LEGAL BASES FOR PROCESSING
Depending on the specific situation, personal data may be processed on the basis of:

consent;
the necessity to enter into or perform a contract;
actions taken at the user’s request prior to entering into a contract;
compliance with legal obligations;
the legitimate interests of the Company or a third party within the limits provided by law;
fraud prevention;
ensuring security;
protection of contractual and intellectual property rights;
asserting or defending legal claims;
other grounds provided for by applicable law.
Special categories of personal data are processed only if there is a separate legal basis for doing so.

 
15. COOKIES AND SIMILAR TECHNOLOGIES
We may use:

cookies;
pixels;
tags;
scripts;
local storage;
other similar technologies.
Essential technologies
Used for:

website functionality;
security;
form functionality;
saving user settings;
displaying the selected language version;
performing functions specifically requested by the user.
Non-essential technologies
May be used for:

analytics;
ad conversion tracking;
remarketing;
ad performance analysis.
If applicable laws require consent, these technologies are enabled only after the user has given their consent.

 
16. GOOGLE ANALYTICS
With the user’s consent, we may use Google Analytics.

Google may receive:

IP address;
device information;
browser data;
approximate location;
pages visited;
referral source;
duration of visit;
cookie identifiers;
other technical analytics data.

17. GOOGLE ADS
Subject to the appropriate legal basis, we may use Google Ads to:

ad placement;
conversion tracking;
ad optimization;
audience targeting;
remarketing.
We do not intend to share the following information through Google Ads:

identifying information;
copies of documents;
personal educational photos;
health information;
sensitive user responses.

18. META PIXEL
With the appropriate consent, we may use Meta Pixel to:

advertising performance measurement;
conversion analysis;
creating ad audiences;
remarketing;
advertising campaign optimization.
We do not intend to transmit special categories of personal data or identity documents via Meta Pixel.

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

Weglot is technically capable of processing:

URL of the page visited;
selected language;
language settings;
IP address;
browser and device information;
page content to be translated;
other technical information necessary for the service to function.

20. LINKTREE AND OTHER EXTERNAL SERVICES
We may use Linktree and other third-party platforms to post links to our resources.

After switching to a third-party platform, the user interacts directly with the relevant service, which may process data in accordance with its own privacy policy.

 
21. DIRECT MARKETING
Advertising and marketing messages are sent only when there is an appropriate legal basis and, where required, separate consent.

Messages can be sent via:

Email:
; SMS:
; Telegram:
; WhatsApp:
; or another channel selected by the user.
The user may opt out of direct marketing at any time.

This opt-out does not affect necessary service messages related to:

order;
payment;
granting access;
security;
technical support;
changes to the terms;
performance of the contract.

22. PUBLIC AND MARKETING USE OF PHOTOGRAPHS
Purchasing a course, acquiring a separate personalized educational service, or providing a photograph does not imply automatic consent to the public use of the material.

Photographs, videos, testimonials, visual comparisons, success stories, and other identifying materials may be used publicly or for marketing purposes only with separate, voluntary consent, when such consent is required.

Such consent:

is not a condition for purchasing a digital product;
is not a condition for receiving a specific educational service;
is provided separately;
cannot be selected in advance;
may be revoked in accordance with the procedure provided by law.

23. RECIPIENTS OF PERSONAL DATA
To the extent necessary for the relevant function, personal data may be made available to:

SendPulse;
Tally;
Telegram;
educational platform providers;
hosting providers;
cloud services;
email providers;
banks;
payment systems;
acquirers;
other payment providers;
Google;
Meta;
Weglot;
Linktree;
IT service providers;
technical contractors;
accountants;
auditors;
lawyers;
government agencies in cases provided for by law;
other recipients where there is an appropriate legal basis.
Employees and contractors are granted access only to the data that is objectively necessary for the performance of their respective functions.

 
24. TELEGRAM AND SENDPULSE FOR CERTAIN INDIVIDUAL SERVICES
If a separately purchased individual educational service is provided via Telegram, messages and files uploaded by the user are technically processed by Telegram’s infrastructure.

If the relevant Telegram bot or communication process operates through SendPulse or another technical provider, that provider may also technically process the data to the extent necessary.

The user is informed of the channel being used before any sensitive material is transmitted, when required.

 
25. INTERNATIONAL DATA TRANSFER
The use of international platforms and technical services may result in data being processed outside of Georgia.

This can occur, in particular, when using:

SendPulse;
Telegram;
Tally;
Google;
Meta;
Weglot;
Linktree;
international payment providers;
other international cloud services.
International transfers are carried out subject to the existence of an appropriate mechanism or legal basis provided for by applicable law.

 
26. RETENTION PERIODS
We do not retain personal data for longer than is objectively necessary for the relevant purpose, unless longer retention is required by law or based on an independent legal basis.

When determining the shelf life, the following factors are taken into account:

Purpose of processing;
Data category;
Data sensitivity;
Term of the contractual relationship;
Duration of access;
Accounting and tax requirements;
Statutes of limitations;
Need to protect legal claims;
Information security requirements.
Digital orders and access
Information regarding payments, orders, the provision of digital access, and electronic acceptance may be retained for the period necessary to fulfill the contract, maintain accounting records, resolve payment disputes, and protect legal rights.

Materials for Individual Personalized Educational Services
Photos, videos, annotated materials, and other materials obtained exclusively for an individual personalized educational service are retained only for the period necessary to provide the service and complete related operations, unless there is a separate legal basis for longer retention.

Identification documents: Expert
Copies of documents are not retained for longer than is objectively necessary.

Information regarding the fact that identification has been conducted may be stored separately for as long as necessary.

 
27. SECURITY
We take reasonable technical and organizational measures to protect personal data from:

unauthorized access;
loss;
unauthorized disclosure;
alteration;
destruction;
unauthorized copying;
other forms of unauthorized processing.
Measures may include:

access control;
password protection;
secure connections;
organizational policies;
restrictions on employee and contractor privileges;
backup;
security monitoring;
incident response procedures.
No electronic means of storage or transmission can guarantee absolute security.

 
28. RIGHTS OF THE DATA SUBJECT
Depending on applicable law, the data subject may have the right to:

find out whether we are processing their data;
obtain information about the purposes and legal basis for processing;
access their data;
obtain a copy of their data;
correct inaccurate data;
request erasure in cases provided for by law;
request restriction of processing;
object to certain types of processing;
withdraw consent;
opt out of direct marketing;
obtain information about recipients;
obtain information about international transfers;
file a complaint with the competent supervisory authority;
bring a legal action.
To exercise your rights:

[email protected]

Message Subject: Request for Personal Information

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

 
29. WITHDRAWAL OF CONSENT
If processing is based on consent, the user has the right to withdraw that consent in accordance with the procedures established by law.

Review:

does not affect the lawfulness of processing prior to withdrawal;
ceases further processing based solely on the relevant consent;
may make it impossible to continue a specific personalized service if it objectively requires the relevant data.
Withdrawal of marketing consent does not affect processing necessary for the performance of a contract or for another independent lawful purpose.

 
30. MINORS
Certain digital educational products may be intended for minors with the participation of a parent or other legal guardian.

When processing a child's data, the following are taken into account:

age;
purpose of processing;
sensitivity of data;
need for parental consent;
best interests of the child;
other mandatory requirements under applicable law.
If photographs or other sensitive materials of a minor are required for a specific personalized educational service, such processing is carried out only if there is a necessary legal basis and, where required, the consent of a parent or legal guardian.

Refusing to provide photos does not prevent you from purchasing the digital course itself, provided that the photos are not necessary for the delivery of the specific digital product you have purchased.

 
31. GDPR
If the General Data Protection Regulation (GDPR) applies to a specific processing activity, the data subject is granted additional rights and safeguards provided for under the GDPR.

These may include:

right of access;
right to rectification;
right to erasure;
right to restrict processing;
right to data portability;
right to object;
right to withdraw consent;
right to lodge a complaint with the relevant supervisory authority.
The applicability of the GDPR is determined by the specific circumstances of the relevant processing.

 
32. AUTOMATED DECISION-MAKING
As a general rule, we do not rely solely on automated decisions that produce legal or similarly significant effects for the user based on:

passport photos;
educational photos;
photos of minors;
health data.
If such processing is implemented in the future, the user will be provided with the necessary information and the safeguards required by law.

 
33. THIRD-PARTY WEBSITES
This website may contain links to third-party websites and services.

After clicking on an external link, the user interacts with the corresponding third-party service.

We do not control all of the independent actions of such third parties, and we recommend that you review their own privacy policies.

 
34. CHANGES TO THIS POLICY
We may update this Policy from time to time.

Possible causes include:

changes to products;
changes to the website;
activation or deactivation of technical services;
changes to processing methods;
changes in legislation;
changes to security requirements;
changes to identification processes;
changes to specific educational services.
The current version is published on the website, along with the date of the last update.

 
35. COMPLAINTS
For questions or complaints regarding the processing of personal data, please contact:

[email protected]

The user also has the right to file a complaint with the competent regulatory authority or court in accordance with applicable law.

 
36. 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]

Phone:
+995577403474

Website:
hondorchyn.com

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

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