1. Introduction and Purpose Built for Assurance.

Lukka, Inc. and its subsidiaries, affiliates and other members of its group companies (together, “We”, “Us”, “Our” or the “Company”) are committed to protecting the privacy of visitors to our websites and the individuals and entities who register to use our products and services from time to time (each, a “Lukka Product” and collectively, the “Lukka Products” or “our Products”). This policy shall apply collectively to the Company websites, lukka.tech, coinfirm.com and all subdomains of the foregoing and any other public websites within the lukka.tech and confirm.com domains (together, the “Lukka Sites” or “our Sites”).

In this policy, “You,” means the persons or entities to whom this policy applies, including, without limitation, a “Customer” of the Lukka Products, which is an individual or entity who has agreed to the terms of use that govern the Lukka Products or an individual or entity added as a user to an account who has agreed to the terms of use that govern the Lukka Products. You do not have to be a Customer for this policy to apply to you; this policy is applicable to any visitor to our Sites. Further, if any of the Lukka Products you are using links to this policy, it applies to you.

The Company you are contracting with is your Data Controller and is responsible for the collection, use, disclosure, retention, and protection of your Personal Data (as defined below) in accordance with this policy, applicable laws and regulations, and global privacy standards. The Company shares data internally with each other under a Data Processing Agreement. Lukka, Inc., a Delaware corporation, is the Data Controller of your Personal Data processed under this policy. Our registered office is at c/o Stellar Corporation Services LLC, 3500 SouthDuPont Highway, Dover, DE 19901 and our registered company number is 5492959.

Our Customers are solely responsible for establishing policies that ensure compliance with all applicable laws and regulations, agreements, or other obligations, with regards to the collection of Personal Data in connection with the use of our Products by individuals or entities with whom our Customers interact. If you are an individual who interacts with a Customer using our Products, then you will be directed to contact that Customer for assistance with any requests or questions relating to your Personal Data.

The security of your Personal Data is important to us. The Company has in place safeguards to protect the Personal Data stored with us. This policy describes how we may collect, use, disclose, process, and manage your Personal Data. We use commercially reasonable physical, electronic, and procedural measures to protect Personal Data in accordance with data protection legislative requirements. We will not use your Personal Data for purposes other than those purposes we have disclosed to you in this policy without your permission.

This policy applies to any individual’s Personal Data which is in our possession or under our control. By visiting, accessing, or using our Sites or our Products, you acknowledge that we use your Personal Data as set out in this policy. This policy does not apply to anonymized data as it cannot be used to identify you.

This policy will be updated from time to time and the most current version will always be available on our Site.

2. Personal Data
“Personal Data” is data that can be used to identify a natural person or which allows a natural person to be identified when combined with other information. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, email address, an identification number, location data, and online identifier or to one or more factors specific to his/her physical, physiological, genetic, mental, economic, cultural or social identity. It does not include data where your identity has been removed (“Anonymized Data”).

For the purposes of applicable data protection law, we are the Data Controller in relation to the processing of your Personal Data when provided by you to us. More commonly under contract with our customers, we are a processor of Personal Data following their instructions. This policy applies to any individual’s Personal Data which is in our possession or under our control. By visiting, accessing, or using our Sites or our Products, you acknowledge that we use your Personal Data as set out in this policy.

You may give us Personal Data by filling in forms on one of our Sites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use one of our Sites, subscribe to one of our Products, submit your CV to us, or any other communication with us. We may also process Personal Data in performance of a contract with a customer where they supply or provide Personal Data in their business interaction with us.

In order to provide you with the Products, we may ask you to provide us with certain details or Personal Data. The collection of Personal Data is limited to what is necessary to meet the Company’s objectives. Some examples of Personal Data that we may collect are:

Contact information: Your name and email address when you register or open an account, sign in, purchase, or otherwise receive access to a Lukka Product. We may also collect your phone number and the name or alias of any agents or end users you authorize to log into and utilize our Products in connection with your account.
Account information: The username and password used to access our Products.
Financial information: Your credit card information and tax-related information, such as previous tax returns, tax forms, and banking information may be shared with us or our third party payment processors.
Interaction and Feedback: Your interactions with our Products, your preferences regarding our Products (e.g., notification preferences), feedback regarding our Products, interactions, transactions and requests you make. We may also collect any other information you choose to include in communications with us or arising from your use of our Products (e.g., when sending a message, submitting information through our webform, or commenting on our social media accounts).
Other Information: Information from other companies or third parties when you connect a third party account or service with the Lukka Products or when we may use service providers to supplement the Personal Data you give us (e.g., validate your email address).
You have the right to refuse, deny, or withdraw consent on providing us with any of the Personal Data described above at any time (see also Section 12). However, we may not be able to offer our Products to you if we agree to such a request.

Should our Company develop or acquire additional Personal Data, outside of what was defined above, about its Customers for our use, we will update this policy to reflect such additional data.

3. Lawful Uses of Personal Data
We may use your Personal Data in order to perform our contract with you, provide you with access to our Products, process related payments, contact you and your agents about our Products, and for such other purposes permitted by law. Personal Data is used only for the intended purposes for which it was collected and only when implicit or explicit consent has been obtained, unless a law or regulation specifically requires otherwise.

In order to be responsive to you, to provide the Products to you, and to maintain our business relationship, as a matter of our legitimate interests, we may use your Personal Data to:

Administer our Products and Sites, and for internal operations, including; troubleshooting, data analysis, testing, research, statistical and survey purposes.
Improve our Products (e.g., analyze trends, administer and maintain our Products, or track usage of various features within our Products).
Maintain the safety and security of our Customers, our Site, our Products and our business.
Send you and your agents announcements relating to security, privacy or other administrative-related communications. Note that you may not opt out of these communications as they are not marketing oriented and therefore do not rely on consent.
Customize our Products to ensure they are presented in the most effective manner for you.
Conduct audits related to our interactions with you.
Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.
Conduct internal research for technological improvement and other internal operations.
Determine your suitability for a job position at the Company where you have applied for a job and, if applicable, to determine the terms of employment or engagement. If your application is progressed, Personal Data may be disclosed to third parties (such as educational institutions, present and past employers, credit reference agencies, insurance companies etc.) for reasons such as the verification of such information.
Contact you, and keep you informed of our Products, and about industry and sector specific information that might be of interest to you.
Deal with legal disputes involving you, or other employees, workers, contractors or customers.
Perform other one-time or short-term uses.
Create anonymized and aggregated data sets, which such Anonymized Data then ceases to be Personal Data.
If Personal Data that was previously collected is to be used for purposes not identified by our then current policy, we will update this policy to define the new purpose.

The Company’s methods of collecting Personal Data are reviewed by our management before they are implemented to confirm that Personal Data is obtained fairly, without intimidation or deception, and lawfully, adhering to all relevant rules of law, whether derived from statute or common law, relating to the collection of Personal Data.

If you are based in the European Economic Area (EEA), Switzerland, or the United Kingdom, use of Personal Data under relevant data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the grounds in respect of each use in this policy. We note the grounds we use to justify each use of your information in each heading below.