Lucinetic’s Privacy Policy

This privacy policy explains the what, how, and why of the personally identifying Information we, Lucinetic, collect when you visit the website located at www.lucinetic.com (the “Site”) and when you use the Lucinetic software and services (“Services”) and includes Personal Information collected via email or other means. It also explains the specific ways we use and disclose that information. By using or accessing the Site or Services, you are accepting the practices described in this Privacy Policy, and you are consenting to our processing of your information as described below.

About Lucinetic

Lucinetic is an artificial intelligence (AI) -driven reference letter writing and management platform. Instead of manually writing reference letters and managing requests, writers can review pre-written letters and manage requests on a single platform.

Lucinetic’s algorithm incorporates text generated through open-source Natural Language Modeling software via a transformer language model, namely OpenAI’s GPT-3.

Definitions

Getting a few definitions out of the way should help you better understand this policy. When we say we, us, our or Lucinetic, we're referring to Lucinetic, a Delaware corporation. Lucinetic User refers to any individual that has entered into an agreement with Lucinetic to use the Lucinetic Services on its Site. Personal Information means all information relating to a person that identifies such person or could reasonably be used to identify such person, including but not limited to, as first and last name, home address, billing address, or other physical address, email address, telephone number, and education and education performance. Visitor refers to anyone accessing the Site.

Information Collected

Information Collected from Lucinetic Visitors

If you are a Visitor, Lucinetic collects information on your use of our Site, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, cookie information, and Internet Service Provider (“Usage Data”). Lucinetic’s purpose in collecting Usage Information is to better understand how Lucinetic’s Visitors use the Site. Lucinetic does not use the Usage Information to identify its Visitors and does not disclose the Usage Information other than under the circumstances described in this Privacy Policy.

As a Visitor, Lucinetic collects potentially personally-identifying information like Internet Protocol (or “IP”) addresses (“Potential PII”). Also, you may choose to interact with the Site that results in your providing Personal Information to Lucinetic, such as giving us your name, email address, user name, and password when signing up for a free trial of the Services.

We only collect Personal Information that is reasonable or necessary to accomplish the purpose of your interaction with Lucinetic as a Visitor. You may choose not to provide this information, but you need to understand that as a result, you may not be able to engage in certain activities on the Site. Any Personal Information provided by you as a Visitor to the Site will be used only as described in this Privacy Policy and Lucinetic’s Acceptable Use Policy.

Information Collected from Lucinetic’s Users

If you are a User of Lucinetic, when you signed up for the Services, you entered into an agreement with Lucinetic to accept Lucinetic’s terms of use of the Services, which includes the obligations in this Privacy Policy and our Acceptable Use Policy (“Agreement”). As part of your use of the Services, we collect the same information as that of a Visitor above and may ask you for additional information such as payment information, usage data in relation to the Services, and other information we deem relevant for the purpose of providing the Services. Lucinetic may use your information and data as agreed to in the Agreement and to:

Process transactions between you and Lucinetic.

Communicate with you about our Services, including sending you e-mail newsletters.

Let you know about changes to our policies and terms.

Provide support for the Lucinetic Services.

Enhance or improve user experience, our Site, or Lucinetic Services.

Monitor data to ensure that it complies with your contractual obligations to us.

Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Site or the Lucinetic Services.

With your prior consent, we may post your personal testimonials along with those of other satisfied customers on our Site in addition to other endorsements.

The information we collect from a User is disclosed only in accordance with the Agreement and this Privacy Policy and the Acceptable Use Policy.

Use of Your Personal Information

In the course of business, we may hire third-party individuals and organizations to help us make Lucinetic Services better. These third parties include our web host provider, other SaaS providers, such as an email hosting service, payment processors, or outside contractors we hire to perform maintenance or assist us in securing our website. We may also hire third parties to operate, maintain, repair, or otherwise improve or preserve our website or its underlying files or systems.

Lucinetic may disclose Personal Information and Potential PII only to those of its employees and third-party organizations that (1) need to know such information in order to process it on Lucinetic’s behalf or to provide services as described above and (2) have agreed not to disclose it to any other parties without Lucinetic’s consent. Some of those employees, contractors, and affiliated organizations may be located outside of your home country; by using the Site and/or the Service, you consent to the transfer of information to such individuals and organizations in order to accomplish these purposes.

Before using or sharing your information with non-agent third parties in ways not discussed here or previously authorized by you, we will provide you a Notice and an opportunity to control the further use or disclosure of your personal information.

If you are a registered user of the Service and have supplied your email address, Lucinetic may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Lucinetic and our products. If you send us a request (for example, via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Lucinetic takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of Personal Information and Potential PII.

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that are transferred or acquired by a third party. You acknowledge that such transfers may occur and that any acquirer of us or our assets may continue to use your Personal Information and Potential PII as set forth in this policy. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information and Potential IP, as well as any choices you may have regarding your Personal Information and Potential IP.

We will also provide an EU or Swiss individual with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.

To limit the use and disclosure of your personal information, please submit a written request to support@lucinetic.com.

Release of Your Information for Legal Purposes

We may access or release Personal Information about you when required to do so in order to comply with any applicable, laws, regulations, subpoena, or enforceable governmental or public authority request, including, to meet national security or law enforcement requirements. We may also access or release Personal Information when we have good faith to believe that such access or release is reasonably necessary to (i) enforce applicable terms of service, including investigation of potential violations, (ii) detect, prevent, or otherwise address fraud, security or technical issues, (iii) respond to user support requests, or (iv) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Right to Access, Edit, and Remove Your Information

You have a right to access the personal information we hold about you. Whenever you use our Site or Lucinetic Services, we strive to make sure that the Personal Information is correct. If that information is wrong, we give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

When updating your Personal Information, we may ask you to verify your identity before making any changes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).

Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. Because we protect information from accidental or malicious destruction, even after information is deleted from the Lucinetic Services, it may not be immediately deleted from Lucinetic’s servers.

To request removal of your Personal Information from our Site, Services, blog, or social media, contact us at support@lucinetic.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

Security Measures

We take measures to enhance the security of our Site and the Lucinetic Service. These measures include using SSL Certificates and two-factor authentication. It is important for you to protect against unauthorized access to your password and to your computer. No security measures are perfect and we cannot promise that the information about you will remain secure in all circumstances.

International Transfer

We store and process information about you on computers in the United States. Privacy laws local to our servers and computers will apply to information we store about you.

Do Not Track Signal

We treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track setting.

Children

Our site is intended for a general audience and we do not knowingly collect personal information from anyone under the age of 13.

How Lucinetic Collects Information

Cookies are small data files placed on your computer by the websites you visit and the emails you read and can be used to help recognize you when you return to a website, or when you visit other sites. We, or third party service providers, may use cookies to, among other things, measure activity, personalize your experience, remember your viewing preferences, or track your status or progress when accessing our site. For some of these purposes, our cookies may be tied to Personal Information and/or Potential PII. In particular, Lucinetic Services use first-party cookies to maintain a coherent scope for a user session across multiple pages on a single website. These cookies do not track the same user across unrelated domains and, as described above, attempts to infer identity across domains is strictly prohibited.

Local Storage is a standard facility provided by HTML5-compliant browsers used to retain data on your computer across visits to the same website. We use local storage as a temporary holding area for user events that were observed locally but, due to the timing of a page unload, were unable to be transmitted as part of the user session. Return visits to the same website read and transmit events previously stored in local storage to complete previously recorded sessions.

This information may in the aggregate identify a User, however, we will not identify a User as they browse the web if the User turns off cookies, as explained below.

Lucinetic does not and will not ever attempt to identify the same person across disparate, unrelated domains. It is a violation of our Acceptable Use Policy for our customers to attempt to build multi-site user profiles for the intent of selling or exchanging lists of users or demographic information.

List of data Sub processors

Amazon Web Services, Inc - USA

Google LLC - USA

EU-US Privacy Shield

Lucinetic complies with both the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework, as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland to the United States. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.

In compliance with the Privacy Shield Principles, Lucinetic commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Lucinetic at: support@lucinetic.com.

Lucinetic is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Changes

We may amend this Privacy Policy from time to time. When there are changes to this Privacy Policy, we will update this page. The date on the bottom will always indicate when we last made changes. If you are a visitor to this Site and disagree with the Privacy Policy, you should leave the Site and/or cancel your agreement with Lucinetic.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy when using Lucinetic, please send us a detailed message to support@lucinetic.com. We will make every effort to address your concerns.

Last Updated: September 2021