Legal

Privacy Policy

Effective date: [EFFECTIVE_DATE] · Last updated: [EFFECTIVE_DATE]

Draft for review. This document is a working draft with [bracketed placeholders] to be completed and reviewed by qualified legal counsel before publication or reliance — including the subprocessor commitments, which depend on the data-processing agreements still being finalized.

This Privacy Policy explains how [LEGAL_ENTITY_NAME] ("LuciusOS", "we", "us") collects, uses, discloses, and safeguards information in connection with the LuciusOS service (the "Service"). We act as a data processor on behalf of our customers for the workspace data they bring into the Service, and as a data controller for account and billing information.

1. Who we are

The data controller / operator is [LEGAL_ENTITY_NAME], [REGISTERED_ADDRESS]. For any privacy question or to exercise your rights, contact us at privacy@luciusos.ai.

2. Data we process

Connected source data. With your explicit authorization, the Service reads from sources you connect (for example email and file storage). Connectors are read-only — we never write back to or send from your connected accounts.
Workspace data. The records you and your team create or that are derived from connected sources (clients, roles, people, decisions, tasks, and the memory and citations built from them).
Account data. Names, work email addresses, and authentication metadata for the people who use the Service.
Operational logs. Security and reliability logs that reference identifiers, never the private content of your evidence.

We do not extract, infer, or use protected attributes (such as age, gender, nationality, or their proxies), and we do not produce candidate scores, rankings, or automated rejections.

3. How we use data

To provide the Service: building your permissioned company memory, answering questions with cited evidence, and surfacing agent-proposed actions for your approval.
To secure, maintain, and improve the Service.
To comply with legal obligations.

Access to your data is governed by a permission layer (the "Evidence Firewall"): no content reaches an AI model without a permissioned, minimum-necessary evidence set, and private data is never exposed in group answers, reports, or to administrators.

4. AI and subprocessors

To deliver the Service we rely on the following subprocessors under contract. We share only the minimum data necessary and require that customer data is not used to train third-party models.

Anthropic — large language model inference (under a data-processing agreement with zero-retention terms where available).
Voyage AI — text embeddings [or replacement provider, pending DPA confirmation].
Google — where you connect Google sources (Gmail / Drive), read-only access under Google's API user-data policies.
Google Cloud Platform — hosting, database, and storage infrastructure.

An up-to-date subprocessor list is available on request at privacy@luciusos.ai.

5. Retention & deletion

We retain data only as long as needed to provide the Service. Removing a source or record starts a reversible soft-delete with a 30-day grace window, after which the data — including derived memory, embeddings, and stored files — is permanently purged, leaving only non-content audit records. You may request erasure of a person's data at any time.

6. Security

Secrets are encrypted at rest via a key-management service; data is encrypted in transit; access is org-scoped and least-privilege. We maintain audit trails of meaningful actions and encrypted backups with a documented restore procedure.

7. Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, or port your personal data, and to object to certain processing. For individuals in Türkiye these rights arise under the KVKK (Law No. 6698); for individuals in the EU/EEA and UK, under the GDPR / UK GDPR. To exercise any right, contact privacy@luciusos.ai. Where we process data on behalf of a customer, we will refer your request to that customer as the controller.

8. International transfers

Where data is transferred across borders, we rely on appropriate safeguards (such as Standard Contractual Clauses) as required by applicable law.

9. Changes

We may update this policy; material changes will be posted here with an updated effective date.

10. Contact

[LEGAL_ENTITY_NAME] · [REGISTERED_ADDRESS] · privacy@luciusos.ai · Governing law: [GOVERNING_LAW / JURISDICTION].