Privacy policy

Last updated March 2024

This Privacy Policy governs the processing of your personal data by In Good Company BV (hereinafter: “LUCY”, “we”, “us”, “our”) whenever you:

• visit our website (www.getlucy.ai) (“Website”) and use the services offered there;
• communicate with us via e-mail, telephone, and social media (hereinafter: “Social Media Channels”; e.g., Facebook, LinkedIn, etc.); or
• interact with us at fairs and events.

NOTE: If you want information on how we process personal data via cookies and social plug-ins on our Website, you are kindly referred to our Cookie Policy.

1. Your personal data are processed by In Good Company BV, Desguinlei 100, 2000 Antwerpen), Belgium, with corporate registration number 1006.626.408. You can contact us via e-mail at info@getlucy.ai.
2. Any notion starting with a capital shall be defined by explicit reference in this Privacy Policy. Where possible given the context, singular words shall be interpreted as also including the plural and vice versa.
3. Where reference is made to certain laws or regulations, such reference shall also include any change, replacement or annulment of said laws or regulations, including any related executive decisions.
4. LUCY reserves the right to modify, change or amend this Privacy Policy at its own discretion and from time to time. Such modification, change or amendment shall be communicated via the Website. If you do not accept the modifications, changes or amendments, you are to inform us by sending an e-mail to info@getlucy.ai. If we do not receive such an e-mail from you within three (3) business days after the changes to the Privacy Policy have been announced in a visible manner on our Website, you will be deemed to have unambiguously accepted all such changes.

1. Whenever you use our Website and Social Media Channels, we may collect:
   • technical information associated with the device you use, such as your IP address, browser type, geographical location, and operating system.
2. When you use our services, fill out the contact form on our Website, or contact us via e-mail, telephone, fax, or Social Media Channels, we may collect:
   • the basic identity information you provide us with, such as name, company name, company type, e-mail address, postal address, telephone number, the company you work for, your function;
   • account information, such as username and password;
   • the content of your communication and the technical details of the communication itself (with whom you correspond at our end, date and time, etc.);
   • your preferences regarding receiving our e-mail communications, such as newsletters, promotions, advertisements, etc.
   • publicly available information of your profile on Social Media Channels;
   • financial information, such as;
   • any other personal data you choose to provide to us.
3. Whenever you leave us your business card or interact with us at fairs and events at which we are present, we may collect:
   • the basic identity information you provide us with, such as name, e-mail address, postal address, telephone number, the company you work for, your function (i.e. when such information is provided by you or shown on your business card);
   • your image.
4. LUCY will in principle never ask you for sensitive personal data. However, the invoices you upload to LUCY may contain sensitive personal data. For the purposes of this provision, sensitive personal data must be interpreted as:
   • data revealing racial or ethnic origin;
   • political opinions;
   • religious or philosophical beliefs;
   • trade union membership;
   • genetic or biometric data;
   • data concerning health; or
   • data concerning a natural person's sex life or sexual orientation.

1. LUCY processes your personal data to provide you in a personalized and efficient way with the Services – including payment initiation services and account information services – you request via the Website, e-mail, telephone, Social Media Channels and fairs and events, and for overall customer management.
2. We will also process your personal data you submit to us for evidence purposes, so that we may defend ourselves in possible ensuing legal or other proceedings.
3. LUCY processes your personal data to perform statistical analyses so that we may improve our Website, our products and services or develop new products and services.
4. LUCY processes your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
   • Your personal data may be transferred upon LUCY’s own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your registration with or use of the Website, our Social Media Channels or other communication with us.
5. LUCY may process your personal data for informing any third party in the context of a possible merger with, acquisition from/by or demerger by that third party, even if that third party is located outside the EU.
6. LUCY may process your personal data for the preservation of the legitimate interests of LUCY, its partners or a third party if and when your registration with, or use of, the Website, Social Media Channels or other communication channels can be considered (a) a violation of any applicable terms of use or the intellectual property rights or any other right of a third party, (b) a threat to the security or integrity of the Website, (c) a danger to the Website or any of LUCY’s or its subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) in any way hateful, obscene, discriminating, racist, slanderous, spiteful, hurtful or in some other way inappropriate or illegal.
7. LUCY processes your personal data mentioned under clauses 2.1, 2.2 and 2.3 above for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of LUCY and selected partners. Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, LUCY will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communications channels if you have explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.

1. The processing of your personal data for the purpose described in clause 3.1 is necessary for the performance of our contract with you.
2. When you provide any of the sensitive personal data as referenced in provision 2.4, you agree with the processing of that personal data. The processing ground for this is the explicit consent of the data subject. When this processing relates to a minor below the age of 13 years, consent must be provided by the holder of parental responsibility of that minor.
3. The processing of your personal data for the purposes outlined in clause 3.4 is necessary to allow LUCY to comply with its legal obligations.
4. The processing of your personal data for the purposes outlined in clauses 3.1, 3.2, 3.3, 3.5, and 3.6 is necessary for the purpose of the legitimate interests of LUCY, which are:
   • being able to appropriately respond to your requests for information and other requests;
   • allowing us to defend ourselves in legal proceedings;
   • continuous improvements to LUCY’s Website, Social Media Channels, products and services to ensure that you have the best experience possible;
   • keeping our Website, Social Media Channels, products and services safe from misuse and illegal activity;
   • safeguarding our commercial and business interests and needs in light of changing market conditions;
   • marketing and promotion of our products, services, brands and overall successful commercialization of our products and services.
5. For processing your personal data for the purposes outlined in clause 3.7, LUCY as the responsible party asks for your consent. By consenting to our processing of your personal data for sending you communications, promotions, offerings, newsletters, and other advertisements via e-mail or other person-to-person electronic communications channels, you agree that we are allowed to process your personal data for this purpose in the manner and under the conditions outlined in this Privacy Policy.

1. LUCY does not send your personal data in an identifiable manner to any third party without your explicit permission to do so. You understand, however, that if you use our Social Media Channels, your personal data is also processed by the social media providers. You can find more information on how these social media providers process your personal data in their respective privacy policies.
2. LUCY relies on third party processors to provide you the Website as well as to process your personal data on our behalf. These third party processors are only allowed to process your personal data on behalf of LUCY upon explicit written instruction of LUCY. LUCY warrants that all third party processors are selected with due care and are obliged to observe the safety and integrity of your personal data.

1. LUCY does its utmost to process only those personal data which are necessary to achieve the purposes listed under the purpose for processing.
2. Your personal data are only processed for as long as needed to achieve the purposes which are described above or up until such time where you withdraw your consent for processing them. Note that withdrawal of consent may imply that you can no longer use the whole or part of the Website. LUCY will de-identify your personal data when they are no longer necessary for the purposes outlined in the purpose for processing, unless there is:
   • an overriding interest of LUCY or any other third party in keeping your personal data identifiable;
   • a legal or regulatory obligation or a judicial or administrative order that prevents LUCY from de-identifying them.
3. LUCY will take the appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss, tampering or destruction. Access by personnel of LUCY or its third party processors will only be on a need-to-know basis and subject to strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations only, which can never be guaranteed.

1. You have the right to request access to all personal data processed by LUCY pertaining to you. LUCY reserves the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to LUCY.
2. You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If a request for correction is submitted, such request shall be accompanied by proof of the flawed nature of the data for which correction is asked.
3. You have the right to withdraw your earlier given consent under clause 4.5 for processing your personal data.
4. You have the right to request that personal data pertaining to you will be deleted if they are no longer required in light of the purposes which are outlined above or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by LUCY against:
   • overriding interests of LUCY or any other third party;
   • legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
   Instead of deletion, you can also ask that LUCY limits the processing of your personal data if and when (a) you contest the accuracy of that data, (b) the processing is illegitimate or (c) the data are no longer needed for the purposes which are outlined above, but you need them to defend yourself in judicial proceedings.
5. You have the right to oppose the processing of personal data if you are able to prove that there are serious and justified reasons connected with his particular circumstances that warrant such opposition. However, if the intended processing qualifies as direct marketing, you have the right to oppose such processing free of charge and without justification.
6. You have the right to receive from us in a structured, commonly used and machine-readable format all personal data you have provided to us.
7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an e-mail to info@getlucy.ai for all data subject rights matters. An e-mail requesting to exercise a right shall not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should clearly state and specify which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. LUCY will promptly inform you of having received this request. If the request proves valid, LUCY shall notify it as soon as reasonably possible and at the latest thirty (30) days after having received the request. If you have any complaint regarding the processing of your personal data by LUCY, you may always contact LUCY via the e-mail address mentioned in the first paragraph of this clause. If you remain unsatisfied with LUCY’s response, you are free to file a complaint with the competent data protection authority, i.e., the Belgian data protection authority. For more information, visit http://www.privacycommission.be.