Platform Privacy Policy

Lucio Platform Privacy Policy

1. Purpose of this Privacy Policy

Lucio is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our web application located at www.dashboard.lucioai.com (“Platform”) and in connection with our Lucio products and services (the "Products"). In addition, this Privacy Policy tells you about your privacy rights and how the law protects you. This website and our Products are not intended for children and we do not knowingly collect data relating to children. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

2. Controller and Contact Details

Zenlegal Technology Private Limited (collectively referred to as "Lucio," "we," "us" or "our" in this Privacy Policy) is the controller of Personal Data submitted in accordance with this Privacy Policy and is responsible for that Personal Data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO at privacy@lucioai.com.

3. Types Of Data We Collect

We collect certain Personal Data and Anonymous Data from you when you engage with us, as described below:

"Personal Data" means data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. "Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons.

Lucio adheres to a data minimisation principle and only collects Personal Data that is necessary to provide our services to you.

3.1. Personal Data You Provide to Us

You are granted a limited, non-exclusive, non-transferable, and revocable license to access and use the platform solely for authorized business purposes.

• We collect Personal Data from you, such as your name, e-mail and office addresses, professional title, and professional or employment-related information, when you download or install our Products, or create an account to log in to our Platform, engage with us through email or online chat applications, or sign-up for our newsletter or other marketing material.

• When you order Products on our website or via email, we will collect all information necessary to complete the transaction, including your name, payment instrument information, billing information and shipping information.

• We also retain information on your behalf, such as files and queries that you store using your account on our Platform.

• If you provide us feedback or contact us via the Platform, e-mail or chat applications, we will collect your name and e-mail address (identifiers), as well as any other content included in the e-mail or message, in order to send you a reply, and any information that you submit to us. When you participate in one of our surveys, we may collect additional profile information.

• We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

• Any other Personal Data that is necessary to provide our services and that you provide your consent for, or which is mandated by applicable law.

3.2. Personal Data Collected Via Technology

To make our website and Products more useful to you, our servers (which may be hosted by a third party service provider) may collect Personal Data from you, including browser type, IP address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session and domain name. We also gather information regarding the date and time of your visit to our Platform and the tools on our Platform that you used (user logs). Like most technology companies, we automatically gather this data and store it in log files each time you access your account on our Platform. We use Cookies only for necessary purposes such as to give you access, to keep you logged in our Platform.

3.3. Personal and/or Anonymous Data Collected By Third Parties

• We may receive Personal and/or Anonymous Data about you from other sources, such as single sign-on services provided by Google or Microsoft Azure. Those Third Party Companies may supply us with Personal Data, such as your email address, in order to help us establish the account.

• Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect Personal Data or Anonymous Data from you.

• We have no control over, do not review, and cannot be responsible for, outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites. You may determine whether or not we are responsible for the content of a website by reviewing the URL and confirming the ownership of the applicable domain by means of a service such as DNSstuff.com.

3.4. Personal Data That We Collect From You About Others

If you decide to invite a third party to join our Platform, we will collect your and the third party's names and e-mail addresses (identifiers) in order to send an e-mail and follow up with the third party. You or the third party may contact us at privacy@lucioai.com to request the removal of this information from our database.     

4. Use Of Your Data

4.1. General Use

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the ways set out in the table below where we also detail the legal bases we rely on to do so:

4.2. Creation of Anonymous Data

We may create Anonymous Data records from Personal Data by excluding information (such as your name and IP address) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Products and improve site navigation, and for marketing and analytics. We reserve the right to use and disclose Anonymous Data to Third Party Companies in our discretion.

4.3. Feedback

If you provide feedback on any of our Products or our website, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Data. We will collect any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.

5. Disclosure Of Your Personal Data

5.1. Disclosure to Affiliates

We may share some or all of your Personal Data with other companies under our common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires us or our assets, that company will possess the Personal Data collected by it and us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy. We may also disclose your Personal Data to third parties in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.       

5.2. Disclosure to Third Party Service Providers

Lucio does not and will not sell your Personal Data. Except as otherwise stated in this policy, we do not generally share the Personal Data that we collect with other entities. However, we may share your Personal Data -- including each category of Personal Data described above -- with third party service providers to:

  • collect and process payments

  •   conduct quality assurance testing

  •   Facilitate creation and maintenance of accounts

  • collect and analyze usage data

  •   provide technical support; or

  •  Provide specific business services, such as integration with other software applications. These third party service providers are required by written agreement not to retain, use, or disclose your Personal Data other than to provide the services requested by us.

5.3. Disclosure to Other Third Party Companies

We will not disclose your Personal Data to other Third Party Companies unless you have "opted-in" by following the instructions we provide to allow such disclosure, such as by registering for an event where we have notified you that we share attendee information with third-party sponsors of the event. If you have opted-in to receive e-mail communications from a Third Party Company and later wish to discontinue receipt of these e-mails, please contact the Third Party Company directly to update your preferences. The privacy policies of our Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of our Third Party Companies, you should read and understand their privacy policies.

5.4. Other Disclosures

We may disclose Personal Data if we believe in good faith that such disclosure is necessary to:

  • Comply with relevant laws or to respond to subpoenas or warrants served on us

  •   Protect us, or our users from harm

6. Your Choices Regarding Your Personal Data

We offer you choices regarding the collection, use, and sharing of your Personal Data. We will periodically send you free newsletters and e-mails that directly promote the use of our Platform or the purchase of our Products. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you notices of any updates to our Privacy Policy.

7. Your Legal Rights regarding your Personal Data

Under certain circumstances, you may have rights under applicable data protection laws in relation to your Personal Data. Where applicable, you may have the right to:

• Request information about how we collect, process, use and share your Personal Data (commonly known as a "right to know request").

• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.        

• Request erasure of your Personal Data (commonly known as a "request to be forgotten"). This enables you to ask us to delete or remove Personal Data. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply in full with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights

• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the above rights please contact privacy@lucioai.com. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights), and Lucio does not discriminate based on whether you choose to exercise your choice and rights. We will not, based on your exercise of rights, deny our Products to you, charge you different rates, provide a different level or quality of Products to you, or suggest that you may receive such different treatment. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or 7 excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. As part of the verification process, we match the information submitted as part of your request against information stored by us. In some instances, we will require additional information in order to verify your request. If an authorized third party makes a data subject request on your behalf, we will require sufficient written proof that you have designated them as your authorized agent. We try to respond to all legitimate requests within one month.

You also have the right to lodge a complaint with a data protection authority it you consider that the processing of your personal information infringes applicable law. If you have any questions, concerns or complaints regarding our compliance with this notice and applicable data protection laws, we encourage you to first contact our Data Protection Officer. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

8. Security Of Your Personal Data

Your data is secured by encryption during transit and at rest. Although we are committed to protecting your Personal Data, we cannot totally guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people, or leave your logged in device in an unsecured manner or location. We will notify you and any applicable regulator of a breach where required to do so as per the timelines prescribed as per applicable law.

9. Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Dispute Resolution

If you believe that we have not adhered to this Privacy Policy, please contact us by e-mail at privacy@lucioai.com.

11. Changes To This Privacy Policy

This Privacy Policy is subject to occasional revision, and if we make any substantial changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us or by prominently posting notice of the changes on our website. Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our site. These changes will be effective immediately for new users of our website and Products. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our website or Products, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

12. Transfers of Personal Data outside the EEA

Your personal information may be transferred and stored in countries outside the EEA that are subject to different standards of data protection. Lucio takes appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests, including through the use of standard contractual clauses. For more information about our DPF certifications please see our Data Processing Agreement. Additionally, Lucio uses a limited number of third-party service providers to assist us in providing our services to customers. These third parties may access, process, or store Personal Data in the course of providing their services. Lucio obtains contractual commitments from them to protect your Personal Data.