1. Who we are and what this Policy covers
1.1 The website at https://www.seeker.law (the “Website”) is operated by Lucio Inc., a company incorporated in Delaware, United States, with its registered office at 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex (“Lucio”, “we”, “us” or “our”). Lucio is the Data controller of the personal information described in this Policy.
1.2 This Policy covers information we collect when you visit the Website, see or click our ads, book a call with us, or receive our marketing. It does not cover the Seeker application at https://seeker.lucioai.com. If you sign up for Seeker, the Seeker Privacy Policy applies to your use of the application.
1.3 Our Website Cookie Policy forms part of this Policy.
2. Information we collect
2.1 Information you give us. When you book a call or otherwise contact us, we collect your email address and any other details you choose to give, such as your name, firm, role, location, phone number and the reason for your enquiry. We also keep a record of your marketing choices and consents.
2.2 Information collected automatically. When you visit the Website, we and our partners collect device and usage information, including IP address, approximate location, browser and device type, pages viewed, time spent, links clicked, the page or ad that referred you, and campaign identifiers attached to ad links. We collect this through cookies, pixels and similar technologies, as described in our Website Cookie Policy.
2.3 Information from advertising partners. Google and LinkedIn give us reports on how our ads perform. These are generally aggregated. Where you interact with a lead form on those platforms, we receive the details you submit through it.
2.4 Information from your later use of Seeker. If you sign up for Seeker after visiting the Website or clicking one of our ads, we may connect your Website activity with your Seeker account to understand which campaigns brought you to us.
3. How we use your information
3.1 We use personal information to:
respond to your enquiry and schedule and hold the call you requested;
send you information about Seeker and other Lucio products, where you have agreed to receive it;
show you our ads on other websites and platforms, and measure how well our ads and campaigns perform (see Section 4);
understand how visitors use the Website and improve it;
keep the Website secure and prevent misuse; and
comply with law and enforce our Website Terms of Use.
3.2 We rely on your consent for marketing emails, advertising cookies and sharing your email address with advertising partners. We rely on our legitimate interests (or, in India, a legitimate use permitted by law) to respond to your enquiry, secure the Website and keep basic records, and on legal obligations where they apply.
4. Advertising and audience targeting
4.1 Ads and remarketing. We advertise Seeker on Google and LinkedIn. With your consent where the law requires it, we and these partners use cookies and pixels on the Website to record your visit, show you our ads after you leave the Website, and measure whether our ads lead to visits, call bookings or sign-ups. These partners may combine this information with information they already hold about you, under their own privacy policies.
4.2 Email matching. If you give us your email address and agree to it, we may share it with Google and LinkedIn in hashed (scrambled) form so that they can match it to your account on their platforms. We use this to show you relevant Seeker ads, to stop showing you ads once you have signed up, to reach professionals with similar profiles, and to measure our campaigns. These partners use the information only to provide advertising services to us and delete unmatched data under their terms.
4.3 Your choices. You can refuse or withdraw consent at any time through Cookie Settings on the Website, by using the unsubscribe link in any marketing email, or by writing to privacy@lucioai.com. You can also manage ads at https://myadcenter.google.com and in your LinkedIn advertising settings, and opt out of interest-based advertising at https://optout.aboutads.info. Users in the United States can also use the rights in Section 9.3.
5. How we share information
5.1 We do not sell your personal information for money. We share it only with:
Service providers that run the Website and our marketing for us, such as website hosting, scheduling, email delivery, customer relationship management and analytics providers, who may use it only to provide services to us;
Advertising partners (Google and LinkedIn), as described in Section 4;
Lucio group companies, including Zenlegal Technology Private Limited to respond to you and market our products;
Authorities and others where required by law or to protect the rights, safety or property of Lucio or others; and
A buyer or investor in connection with a merger, acquisition, financing or sale of assets, subject to this Policy.
6. Where we process information
6.1 We process information in the United States and India, and our service providers and advertising partners may process it in other countries. If you visit from India, your information may be transferred outside India, subject to any restrictions notified by the Government of India.
6.2 If you visit the Website from the European Economic Area, the United Kingdom or Switzerland, we set only strictly necessary cookies unless you opt in.
7. How long we keep information
7.1 We keep enquiry and marketing information for 24 months after our last interaction with you, or until you ask us to delete it or withdraw your consent, whichever is earlier. We then delete it within 30 days, unless we must keep it longer by law.
7.2 We keep a record of your opt-outs and consents for as long as needed to respect them and prove we did. Cookie retention is set out in the Website Cookie Policy.
8. Security
8.1 We use technical and organisational measures designed to protect personal information, including encryption in transit and access controls. No system is completely secure. If a personal data breach affects you, we will notify you and the relevant authorities as required by law.
9. Your rights and choices
9.1 All visitors. You can ask us to access, correct or delete your information, opt out of marketing at any time, and change your cookie choices in Cookie Settings. We will not discriminate against you for exercising your rights.
9.2 Visitors in India. Under the Digital Personal Data Protection Act, 2023 and the rules under it, you have the right to obtain a summary of the personal information we process about you and who it has been shared with; to correct, complete, update or erase it; to withdraw your consent at any time, as easily as you gave it; to nominate another person to exercise your rights; and to have your grievances addressed by our Grievance Officer and, if you are not satisfied, to complain to the Data Protection Board of India.
9.3 Visitors in the United States. Depending on your state of residence, you may have the right to know, access, correct, delete and port your personal information, to opt out of the “sale” or “sharing” of personal information and of targeted advertising, and to appeal our decision on your request. Our advertising cookies and email matching described in Section 4 may be considered a “sale” or “sharing” or targeted advertising under these laws. You can opt out using the “Do Not Sell or Share My Personal Information” link on the Website. We honour Global Privacy Control signals as a valid opt-out for the browser that sends them. You may use an authorised agent, and we will verify your identity before acting on a request. To appeal a decision, write to privacy@lucioai.com with the subject “Privacy Appeal”.
9.4 Categories of personal information (United States).
Name, email address, phone number, IP address, cookie and device IDs
Service providers; advertising partners (hashed email, cookie and device IDs)
Firm, role, practice details you give us
Service providers
Pages viewed, referrals, ad clicks and campaign identifiers
Service providers; advertising partners
Location derived from IP address
Service providers; advertising partners
We do not collect sensitive personal information through the Website. Sources, purposes and retention are described in Sections 2, 3 and 7.
10. Children
10.1 The Website is for professionals and is not intended for anyone under 18. We do not knowingly collect personal information from anyone under 18.
11. Contact us
11.1 Data Protection Officer: privacy@lucioai.com
11.2 Grievance Officer: privacy@lucioai.com. We will respond to grievances within the timelines required by applicable law.
11.3 Postal address: Lucio Inc., 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, United States.
12. Changes to this Policy
12.1 We may update this Policy from time to time and will post the updated version with a new “Last updated” date. Where a change materially affects how we use information we already hold, we will notify you where we can and, where the law requires, ask for your consent.