Created: September 20, 2024

Revised: December 24, 2025 (to incorporate additional products)

Revised: January 28, 2025 (to incorporate UK GDPR compliance review)

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 Products, which include the Lucio Studio Desktop App, the Lucio Word Add-in, and our web application as hosted on www.lucioai.com (“Platform”) In addition, this Privacy Policy tells you about your privacy rights and how the law protects you. 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.

“Products” include the Platform and any software add-ons, extensions, or plug-ins designed to integrate with third-party applications (including Microsoft Word), whether accessed via browser or installed locally, which include the Lucio Word Add-In and the Lucio Studio Desktop App. “Services” means any services that we provide to customers, including support services.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.

This version was last updated on the date at the beginning of it. It may change and, if it does, those changes will be posted on the website. You may be required to read and acknowledge the changes to continue your use of the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

2. Controller and Contact Details.

Zenlegal Technology Private Limited, a private limited company under the Companies Act, 2013, with its registered office at 235, Binnamangala, 13th Cross road, Indiranagar 2nd stage, Bengaluru - 560038  (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. The DPO is based in India.

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 relating to an identified or identifiable natural person.

"Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individuals. .

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.

1. We collect Personal Data from you, such as your name, business e-mail and 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 Products, engage with us through email or online chat applications, or sign-up for our newsletter or other marketing material (Contact Data and Profile Data).

   
   

2. 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.(Profile, Financial and Usage Data).

   
   

3. Identifier Data: name, surname, gender, country of birth.

   
   

4. We also retain information on your behalf, such as files and queries that you store using your account on our Products (Usage Data).

   
   

5. If you provide us feedback or contact us via the Products, 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.(Usage Data)

   
   

6. 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).

   Marketing Data: information which we collect and store as a result of you being added to our mailing databases.

   Device Data: the type of device you use (Device), a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), network information, your mobile operating system, screen type and resolution, the type of web browser you use, the time zone setting.

   
   

7. 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. (Technical Data) 

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 Products and the tools on our Products 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 Products.

We use Cookies only for necessary purposes such as to give you access, to keep you logged in our Products.

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

1. 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.

   
   

2. 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.

   
   

3. 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 Products, 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:

• Consent. Where you have freely consented before the processing in a specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by sending us a message at privacy@lucioai.com. or using our cookie banner (see Your legal rights below).

• Performance of a contract. Where we need to process your personal data to perform a contract with you or where you ask us to take steps before we enter into a contract with you. Where we rely on performance of a contract and you do not provide the necessary information, we will be unable to perform your contract.

• Legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Legal obligation. Where we need to use your personal data to comply with a legal or regulatory obligation. Where we rely on legal obligation and you do not provide the necessary information, we may be unable to fulfil a right you have or comply with our obligations to you, or we may need to take additional steps, such as informing law enforcement or a public authority or applying for a court order.

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: (a) provide you with the Products and services that we offer you through our Products; (b) collect and process payments; (c) conduct quality assurance testing; (d) facilitate creation and maintenance of accounts; (e) collect and analyze usage data; (f) provide technical support;  (g) provide specific business services, such as integration with other software applications; (h) provide professional advice (such as lawyers, auditors and insurers); or (i) tax authorities, regulators, law enforcement agencies or other third parties based in any jurisdiction where necessary to exercise our rights or comply with a legal obligation).

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 (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) 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 or 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). 

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:

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

2. Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

3. 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.

4. 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 erasure request  for specific legal reasons which will be notified to you, if applicable, at the time of your request.

5. 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.

6. 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.

7. 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.

8. 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. 

You also have the right to lodge a complaint with a data protection regulator  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 applicable 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. International Transfers 

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.