LEGAL
Privacy Policy
What personal data Lunxa processes, why, on what legal basis, for how long, and your rights.
- Version:
- 0.9-draft
- Last updated:
- November 7, 2026
1. Controller
[Registered legal entity name — to be completed], [Registered address — to be completed], is the controller for personal data processed to run lunxa.com and Lunxa accounts. Privacy contact: privacy@lunxa.com. [Data Protection Officer: to be completed if appointed.]
For content customers store in their workspaces, the customer is the controller and Lunxa acts as processor under our Data Processing Agreement.
2. Data we process
- Account information: name, email, password hash, company and intended use (optional), timezone, preferences.
- Workspace data: memberships and roles; projects, tasks, comments, documents and files you create.
- AI interaction data: prompts, responses, selected context, feedback, and usage metadata (tokens, cost, latency).
- Usage information: first-party product events (e.g. "project created", daily active), and page views only if you consent to analytics.
- Payment metadata: plan, subscription status, invoices and billing contact. Card details are handled by our payment provider and never reach us.
- Support correspondence: tickets, messages and contact-form submissions.
- Technical and security logs: sign-in events, a keyed hash of your IP address, user agent, request identifiers and audit logs.
- Marketing preferences: whether you opted in to product announcements.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Creating and operating your account; providing the Services; collaboration | Contract |
| AI features you use | Contract |
| Payments, invoicing, tax records | Contract; legal obligation |
| Security, fraud prevention, abuse limits, audit logs | Legitimate interests |
| Service and security communications | Contract; legitimate interests |
| Support | Contract; legitimate interests |
| Product analytics from first-party events | Legitimate interests |
| Website analytics cookies | Consent |
| Product announcements and marketing email | Consent |
| Responding to legal requests; retaining records | Legal obligation |
4. AI providers
When you use Lunxa AI, your request and the minimum relevant workspace context you are authorised to access are sent to the configured AI provider(s) — currently Anthropic PBC and/or OpenAI, depending on configuration — solely to generate a response. [Provider retention and model-training terms must be confirmed against the contracts in place and summarised here before publication.] Lunxa does not use your content to train its own models.
5. Recipients
We share data with service providers acting on our behalf: hosting and database (Railway), object storage, email delivery (Resend), payment processing (Stripe), and AI providers. See the Subprocessors page for the current list. We don't sell personal data.
6. International transfers
Some providers process data outside the EEA. Where they do, we rely on adequacy decisions or Standard Contractual Clauses with supplementary measures. [Transfer assessments to be completed.]
7. Retention
- Account data: while your account exists; deleted 14 days after you request deletion.
- Workspace content: until deleted by you; trashed documents are purged after 30 days.
- AI conversations: until you delete them or your account; usage metadata kept up to 24 months for billing and capacity planning.
- Security and sign-in logs: 12 months. Audit logs: up to 7 years.
- Support records: 3 years after the ticket closes.
- Payment records and invoices: as required by tax law (typically 7 years).
- Marketing records: until you withdraw consent, plus proof of consent.
- Backups: rolling retention of up to 30 days.
8. Security
Encryption in transit (TLS), Argon2id password hashing, optional TOTP two-factor authentication, encrypted storage of secrets, strict workspace isolation enforced server-side, private file storage with short-lived links, rate limiting, and append-only audit logging.
9. Your rights
You can request access, correction, deletion, restriction, objection, data portability and withdrawal of consent. Lunxa does not make decisions with legal or similarly significant effects based solely on automated processing. Use Settings → Privacy (export and deletion) or email privacy@lunxa.com. We respond within one month.
10. Complaints
You can complain to your local data protection supervisory authority. [Lead supervisory authority to be confirmed.]
11. Cookies
See our Cookie Policy. You can change your choices at any time using "Cookie preferences" in the footer.
12. Children
Lunxa is not intended for children under 16 and we don't knowingly collect their data.
13. Changes
We'll update the effective date and notify you of material changes.
14. Contact
privacy@lunxa.com — [Registered legal entity name — to be completed], [Registered address — to be completed].