Privacy Policy

Thank you for using Lucidity!

Please read this Privacy Policy carefully. It explains how we collect and use information. It applies to the personal information collected when you use our Website or access our Service. We do update this Privacy Policy to reflect changes in our practices and the law, so check the date above to see when the Privacy Policy was last changed.

If you disagree with anything in this Privacy Policy or any changes to it then you should stop using the Website and/or Service and contact us.

If you have any questions or concerns, contact us on hello@getlucidity.com.

Definitions:

Lucidity (Get Lucidity Limited, company no. 11846628) (“Lucidity,” “we,” or “us”) is an online strategy platform (the “App”) that allows you to create, manage and communicate your strategy. We may offer this App via https://getlucidity.com (our “Website”) and any other website or application owned, operated or controlled by us. These will be referred to collectively as the “Service”.

As a user of the Website, customer or prospective customer of the Service or a representative of an entity that’s a customer of the Service, you’re a “Customer” according to this Privacy Policy.

Our Standard Terms of Use (URL) (“Terms,”) define the terms and conditions under which Customers are allowed to use the Service in accordance with the Terms, and how we’ll treat your account while you’re a Customer. This Privacy Policy forms part of the Terms.

What we collect & why

We will never sell your data to third parties. We collect it to provide and improve the Website and Service.

Account Information:
When you register to use the Service as either a new Customer or an invited or prospective Customer you are required to provide some personal information including name, email address and a password. If you are an owner of an account this may include payment information.

Strategy Content:
During the course of using the Service content will be created by you or associated Customers. This information is owned by you and remains private. We may anonymise the content for benchmarking but will not provide access to it to third parties.

Marketing:
Personal information may be used to provide free of charge marketing material if you have opted in to receive marketing information. You can change your marketing preferences at any time.

Maintenance:
Personal information may be used if we need to inform you of system maintenance that may impact access to the Service.

Usage Information:
We collect information when you access the Service including your IP address, device information and usage on the Website. Information is used to improve and develop our Website and Service.

Referral Codes:
If you have been introduced to us by one of our authorised partners (“Lucidity Partner”) using their referral code, we will need to record that code with your details in our system for administrative purposes. When you subscribe via a Lucidity Partner, we may also use this information to send a verification email to you and the relevant Lucidity Partner to confirm your referral and validate the referral code. Any communication that you choose to have with the Lucidity Partner shall be subject to their privacy policy.

Cookies>Cookies and Tracking:

We may use various technology to collect information such as cookies. This data will be aggregated information to:

• Make the Website and Service more useful to you
• Estimate our audience and usage patterns
• Store information about preferences
• Speed up searches and usage of the Website and Service
• Recognise when you are using the Website and Service
• Improve and maintain the Website and Service.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Website and Service. See http://www.allaboutcookies.org for more information on how to delete cookies.

We use one or more web analytics service provides to help us understand how Customers use the Website and Service.

Hierarchy Access:
Customers within the same Company can see Strategy Content, which may include some personal information.

Payment Information:
We use Stripe as our third party payment processor to help us provide the Service, this provider will have access to your personal information only to provide payment processing facilities for the Service on our behalf.

Data Storage:
Your data used in our Service is normally stored and processed within the European Economic Area (“EEA”). Your data is only transferred, processed or stored outside of the EEA as specified in this Privacy Policy. Our servers may be hosted by third parties. Your personal information may be transferred to, and stored at, a destination outside the EEA if processed by third parties and staff operating outside the EEA who work for us or for one of our suppliers as necessary for operating the Website and Service. If any processing of your personal information is to take place outside of the EEA in a third country or international organisation which does not ensure an adequate level of data protection, we may only transfer your Information if appropriate safeguards have been implemented and on the condition that enforceable data subject rights and effective legal remedies for data subjects are available. The safeguards may be by way of EU Model Contract Clauses, binding corporate rules, approved code of conduct or approved certification mechanism.

Retention Policy:
We will endeavour not to keep your personal information for longer than necessary in order to facilitate your use of the Website and Service. We will delete any information from a Customer account 90 days from the termination of the account except we may retain certain information to prevent identity theft, legal disputes and misconduct, even if deletion has been requested.

Legal Basis of Processing:
We shall only be entitled to process your personal information as above to the extent that at least one of the following applies:

• You have given consent to the processing of your personal information for one or more specific purposes;
• Processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract;
• Processing is necessary for compliance with a legal obligation to which we are subject;
• Processing is necessary in order to protect your vital interests or those of another natural person;
• Processing is necessary for the performance of a task carried out in the public interest of in the exercise of official authority vested in the controller;

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests of your fundamental rights and freedoms which require protection of personal data. Our legitimate interests may include:

• The proper administration of our Website and Service;
• The performance of our contractual obligations;
• Monitoring and improving our Website and Service;
• Taking steps at your request;
• Communicating with users of our Website and Service;
• The protection and assertion of legal rights;
• The protection of our business against risks.

Disclosure of your information:

We may also disclose your personal information to third parties:

• When we subcontract the running of our Website and Service or any part of it to a third party or where we work with a third party service provider, provided that all subcontractors are bound by reasonable privacy policies compliant with applicable law.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal information in confidence to the prospective seller or buyer of such business or assets.
• If we or substantially all of our assets are transferred to or acquired by a third party, in which case all of your personal information will be one of the transferred assets on the equivalent terms and conditions as herein.
• If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions other agreements; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging personal information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Your Rights:

You have a number of rights as a data subject as summarised below:

• Access: You have the right to obtain confirmation as to whether or not personal data concerning you are being processed and, where that is the case, to access your personal information and details of how we process it, as long as this does not adversely affect the rights and freedoms of others. You may request a copy of your personal information undergoing processing, subject to evidence of your identity (normally a certified copy of your passport plus an original copy of a utility bill showing your current address). The first copy shall be provided without charge, but reasonable administration fees shall be charged for additional or subsequent copies.
• Recification: We will rectify any errors in the personal information we hold on request.
• Erasure: You may erase your personal information from our systems in the following situations:

1. The information is no longer necessary in relation to the purpose for which it was collected;
2. You withdraw your consent on which the processing is based and where there is no other legal ground for the processing;
3. You object to the processing and there are no overriding legitimate grounds for the processing;
4. The information has been unlawfully processed;
5. The information has to be erased for compliance with a legal obligation to which we are subject.

• Right to process restriction: You have the right to restrict our processing on specified grounds.
• Notification: Where you have asked us to rectify, erase or restrict processing of your information, we shall communicate the same to each recipient to whom your personal information has been disclosed, unless this proves impossible or involves disproportionate effort, in which case we shall let you know.
• Data portability: You have the right in specific circumstances where processing is based on consent to receive your Information in a structured, commonly used and machine-readable format and have the right to transmit the personal information to another controller without hindrance, provided that our processing is carried out by automated means.
• Right to object: In certain circumstances you have the right to object to our processing of your personal information, including in relation to profiling, direct marketing or scientific or historical research purposes.

You can exercise these right by contacting us at hello@getlucidity.com and/or by following our online account procedures. We shall respond to your requests without undue delay and in any event within one month unless we need to extend such period by up to two further months in specific circumstances.

Please note that if you delete or restrict your account or required personal information, this may prevent you from making full use of our Website and/or Service.

Security:

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or Service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, including people who work for us.
The transmission of your personal information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or from our Website or Service; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.

Complaints

We hope we can help you to resolve any query or concern you have over the use of your personal information, but you do also have the right to complain to your local regulatory authority if you think a data breach has occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at www.ico.gov.uk.

Data Breaches

In the event of data theft or an identified risk, we may suspend access to our servers, emails and online systems and take other urgent steps at our discretion to protection the personal information we hold. If we think that personal data has been compromised, we will report the issue to the Information Commissioner and follow all required procedure. We will notify you without delay if we believe a data breach is likely to result in a risk to your rights and freedoms.

Help:

If you need any help or assistance in relation to the use of our Website or Service, please contact at hello@getlucidity.com and we will do our best to get back to you promptly.

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