Lucendo -
Privacy Policy

Last updated: September 2025

This Privacy Policy applies to personal data processed through the Lucendo™ Leadership App (‘App’) and the Lucendo™ website (www.getlucendo.com) (‘Website’).

Q: How does LUCENDO protect my personal data?
LUCENDO stores personal data securely on servers hosted by reputable cloud providers (currently AWS). We apply appropriate technical and organizational safeguards, including encryption and role-based access controls where applicable, to protect personal data against unauthorized access, disclosure, or misuse, in line with GDPR and other applicable requirements.

Q: What legal standards does LUCENDO follow?
LUCENDO complies with the European Union’s General Data Protection Regulation (GDPR) and, where applicable, relevant U.S. data privacy laws such as the California Consumer Privacy Act (CCPA). We follow recognized industry standards for privacy, security, and responsible AI use.

Q: Does Lucendo process data of children?
No. Lucendo is not intended for children under 16 in the EU/EEA or under 13 in the United States. We do not knowingly collect personal data from minors below these ages.

Q: What types of data does LUCENDO collect?
LUCENDO App may collect the following categories of data:
- Registration and profile data (e.g., name, email, role, team size, years of experience)
- Assessment/behavioral data (your responses to leadership questions)
- 360° feedback data (optional)
- Uploaded job descriptions or goals (optional, for job-fit analysis)Usage data (e.g., timestamps, in-app interactions)

Q: What data is collected when I use the Website?
When you visit our Website, our servers may automatically log minimal technical information (such as your IP address, browser type, and access times). This is required to ensure the security and proper functioning of the Website. We do not use this information to build profiles or track you across sites.

Q: How is my data used?
Your data is processed for the following purposes
- Generate leadership assessment results and insights
- Personalize your development recommendations
- Benchmark against anonymized peer groups (aggregate form only)
- Support platform functionality, diagnostics, and improvement
- Support role fit and performance analysis features you choose to use

Q: Who can access my data?
Your assessment results are accessible only to you, unless you choose to share them outside the App. In rare cases, authorized technical administrators may access limited data strictly for maintenance, troubleshooting, or security purposes, under confidentiality obligations.

Q: What happens if there is a data breach?
If Lucendo becomes aware of a personal data breach that may affect your rights, we will act without undue delay. In line with GDPR and CCPA requirements, we will:
- Notify affected users directly, where required
- Notify the relevant supervisory authority, where required by law
- Take immediate steps to contain, investigate, and remediate the incident

Q: Can I request deletion of my data?
Yes. You can delete your account and request Lucendo to delete or anonymize your personal data at any time. If you delete your account, LUCENDO will delete or anonymize your personal data within 30 days, in accordance with GDPR Article 17 (“Right to be Forgotten”). Leadership reports and feedback documents will also be removed or anonymized. Data used for benchmarking or product improvement will be retained only in aggregated, non-identifiable form. Any data retained for legal reasons (e.g., billing records) will be kept securely and not used to identify users. Lucendo does not retain or restore report content after deletion.

Q: Does LUCENDO use cookies or tracking?
LUCENDO uses essential cookies and comparable technologies (such as SDKs) to operate the platform securely and improve the user experience. We do not use advertising cookies, cross-site profiling, or invasive tracking. For Website visitors, only essential cookies are used to ensure secure operation and analytics limited to site performance. We do not use tracking for marketing or profiling.

Q: Who can I contact about data privacy concerns?
For privacy-related inquiries, please contact us at: privacy@getlucendo.com

For general inquiries, contact: info@getlucendo.com

For EU users, you have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you believe your rights under applicable data protection law have been infringed. A list of authorities can be found at https://edpb.europa.eu/about-edpb/board/members_en.

We regularly review and update our data protection practices to ensure ongoing compliance with applicable laws and industry standards. For more details, see Section 9 of our Terms and Conditions.

This Privacy Policy is governed by the laws of the State of Delaware, United States. For users in the EU, mandatory consumer and data protection rights apply additionally.