Site and CA Privacy and Cookie Policies

Last updated:  September 12, 2022

PRIVACY POLICY

This Privacy Policy (the “Policy”) describes how your personal information is collected, used, and shared when you visit or use (as applicable) from the 77X, LLC. (“77X”) website at [Luk.AI] and any subdomains, subscription platform, or services offered by 77X through all of these (collectively, the “Site”), unless otherwise specified. Throughout the Site, this Policy and the Terms and Conditions  (the “Terms”), “we”, “us” and “our” refer to 77X. This policy is incorporated into the Terms that govern your use of the Site. Any capitalized terms not defined in this Privacy Policy will have the definitions provided in the Terms. By using the Site, you consent to the practices described in this Policy. Please note that this Policy does not apply to: 

  • information collected by us offline or through any other means, including on any other website that we operate or any third party (including our affiliates and subsidiaries); or 

  • information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

 

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

 

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. 

 

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

  • “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

 

We also collect certain information about you when you register with us.  This information includes your name and email address. We refer to this information as “Order Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

By using the Site, creating an account, or providing us with Personal Information you are giving us your consent to collecting and using your Personal Information for all of the purposes described in this Policy.  

 

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use, store, and process the Personal Information that we collect to provide and improve our Site and services, and to offer a secure, safe, and trusted experience.  For example, we may use your Personal Information:

  • to create an account on, login to, or interact with the Site;

  • to protect against or deter fraudulent, illegal, or harmful conduct;

  • to provide you with information and other services that you may request from us;

  • to provide you with notice about your account;

  • to notify you about changes to our Site or any products or services we offer;

  • to improve and optimize the Site and our services; 

  • to respond to correspondence we receive from you, and providing customer service;

  • to resolve disputes;

  • in any other way that we may describe at the time we provide the information (for instance, in connection with a contest or promotion); and

  • as necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.  

 

We may use your Personal Information to contact you about goods or services offered by 77X.  If you do not want us to use your information in this way, please do not provide your data. Where you have given your consent, we may also share your Personal Data with trusted third parties, and they may use it to contact you about goods and services that may be of interest to you.

 

DATA RETENTION

We will keep your Personal Information only for as long as necessary to provide you with the Services, maintain our legitimate business operations, and/or exercise, defend or establish our rights. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For further information about how long we retain your Personal Information, please contact us at contact@luk.ai.

 

DISCLOSING YOUR PERSONAL INFORMATION

Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a "hash." We will treat de-identified information as non-personal to the fullest extent permitted by applicable law.

We may share your Personal Information with third parties to help us use your Personal Information, as described above. We currently use the following third party services for the following purposes:

 

Provider: Mailchimp                    

Purpose:  Email collection and remarketing                   

Privacy Policy: https://mailchimp.com/legal/ 

                         

Provider: Google Analytics

Purpose:  User analytics 

Purpose:  https://policies.google.com/privacy?hl=en 

 

We may disclose Personal Information that we collect or you provide, as well as information that you provide to us about third parties, as described in this Policy:

  • to our subsidiaries and affiliates;

  • to service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, including:

    • cloud storage providers;

    • marketing services vendors;

    • security vendors;

    • compliance vendors;

    • analytics vendors;

  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of 77X’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred;

  • to third parties who are not affiliated companies to market their products or services to you if you have not opted out of these disclosures.  We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.  For more information, see Your Choices About How We Use and Disclose Your Information below;

  • to fulfill the purpose for which you provide it; 

  • for any other purpose disclosed by us when you provide the information; and

  • with your consent.

 

Please note that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us.

We may also disclose your Personal Information:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

  • to enforce or apply our Terms and other agreements we may have with you; and

  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 77X, LLC, our customers, or others.  This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

THIRD PARTY WEBSITES

Our Site may contain links to third-party websites.  Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Site’s Terms and another entity may collect Personal Information from you.  We do not control, review of have any responsibility for the third-party websites, their content or their use of any Personal Information they may collect from you. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third-parties or their products, content or websites.

 

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

 

YOUR CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personal Information that you provide to us and that we collect.  We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  If you disable or refuse cookies, please note that some parts of this Site may then be inaccessible or not function properly.

  • Promotional Offers; Disclosure of Your Information for Third-Party Advertising. If you do not wish for us to use your Personal Information to promote our own or third parties' products or services or otherwise share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to contact@luk.ai. If we have sent you a promotional email, you can use the “Unsubscribe” link in the email to opt-out of such communications.

  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to contact@luk.ai .

 

You may also send us an email at contact@luk.ai to request access to, correct or delete any Personal Information that you have provided to us.  We may need to delete your user account if you request that we delete some particular Personal Information.  We may not accommodate a request to change or delete Personal information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.  

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights below for more information.

 

DATA SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.  All information you provide to us is stored on our secure servers behind firewalls and will be encrypted using SSL technology.  

Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site.  Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.

 

RIGHTS OF EUROPEAN UNION RESIDENTS 

If you are a European Union resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

Additionally, if you are a European Union resident we note that we are processing your information to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

 

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.  To learn more about your California privacy rights, click here.

 

MINORS
Our Site is intended for a general audience and not for use by anyone younger than the age of 13 in the United States (or under the applicable legal age outside of the United States). We do not knowingly collect personal information from children younger than the age of 13 (or under the applicable legal age outside of the United States), without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used your child’s personal information without your consent, please contact us; see Contact Us.

USERS OUTSIDE OF THE UNITED STATES

If you are a non-US user of the Site and/or Services, by visiting the Site or utilizing the Services and providing us with your Personal Information, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Policy.  In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the US, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your Personal Information, you consent to such a transfer.

 

CHANGES
We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.  It is our practice to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Site home page.  If we make material changes to how we treat Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Site home page.  The date the Policy was last revised is identified at the top of the page.  You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Policy to check for any changes.

CONTACT US
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at contact@luk.ai or by mail using the details provided below: For more information about how we use cookies, please see our Cookie Policy below.

77X LLC

Corporation Trust Centre, 1209 Orange Street, Wilmington, Delaware 19801 

 

CALIFORNIA RESIDENTS

YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS (“California Privacy Notice”) supplements 77X’s Privacy Policy (“Privacy Policy”), and any capitalized terms not defined in this California Privacy Notice will have the definitions provided in the Privacy Policy. 77X has adopted this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws.  It applies only to users of the Site who are California consumers, as defined in the CCPA.  Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice.  

Please note that 77X has not sold and does not sell your personal information, as those terms are defined in the CCPA.

 

Notice of information we collect
77X collects personal information through the Site.  All of the categories of personal information that we collect about you (as set out in the table below) come from the following sources:

  • You, including through your use of the Site

  • Your computer or other device, automatically, when you interact with the Site 

  • Third parties, such as service providers

In particular, within the last twelve (12) months our Site has collected and/or will collect the following categories of personal information from California consumers:

 

Category:

A. Identifiers, such as email address 

Collected:

Yes, such information is included in data provided by users of the Site.  

Purpose:

To create an account on, login to, or interact with the Site.

To protect against or deter fraudulent, illegal, or harmful conduct.

To provide you with information and other services that you may request from us.

To provide you with notice about your account.

To respond to correspondence we receive from you, and providing customer service. 

To protect against or deter fraudulent, illegal, or harmful conduct.

To promote 77X or a third party’s products or services.

 

Category:

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as contact information.

Collected:

Yes, such information is included in data provided by users of the Site.

Purpose:

To provide you with information and other services that you may request from us.

To provide you with notice about your account.

To respond to correspondence we receive from you, and providing customer service. To protect against or deter fraudulent, illegal, or harmful conduct.

To promote 77X or a third party’s products or services.

 

Category:

C. Protected Classification characteristics under California or federal law, such as age, citizenship, gender, marital status,  and veteran status.

Collected:

NO

 

Category:

E. Biometric information.

Collected:

NO 

 

Category:

F. Internet or other similar network activity.

Collected:

Yes, such information is automatically collected from users of the Site.

Such information may also be contained in data provided by users of the Site. 

Purpose:

To improve and optimize the Site and our services. 

To allow you to participate in interactive features on the Site.

Category:

G. Geolocation data, such as device location and IP location

Collected:

Yes, such information is automatically collected from users of the Site.

Purpose:

To improve and optimize the Site and our services. 

To allow you to participate in interactive features on the Site.

Category:

H. Audio, electronic, visual, thermal, olfactory, or similar information, such as images and audio, video or call recordings created in the course of our communications. 

Collected:

NO 

 

Category:

I. Professional or employment-related information, such as current or past job history.

Collected:

NO

 

Category:

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Collected:

NO

 

Category:

K. Inferences drawn from other personal information.

Collected:

NO

Your Rights Under the CCPA.

If you are a California consumer, you have the right to request that 77X disclose to you:

  1. the categories of personal information that we collected about you and the categories of sources from which we collected such information; 

  2. the specific pieces of personal information we collected about you; 

  3. the business or commercial purpose for collecting personal information about you; and 

  4. the categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or to whom we disclosed such information in the preceding 12 months. 

 

California consumers also have the right to request that we delete personal information we collected from you, subject to certain exceptions.  

 

To make such a request, contact us at contact@luk.ai and indicate in the subject line of your message that you are making a CCPA request.  You may be required to submit proof of your identity for these requests to be processed as a verifiable consumer request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf, subject to proof of identity and authorization.

We will respond to your request consistent with the CCPA, which does not apply to certain information, such as information made available from government records, certain data subject to the Fair Credit Reporting Act (FCRA), Gramm-Leach-Bliley Act (GLBA) and certain other laws.  Please note that we are only required to respond to two such requests per consumer each year.

You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA. 77X does not offer financial incentives or price or service differences to consumers in exchange for the retention or sale of a consumer’s personal information.

 

Changes to this California Privacy Notice.

77X may update its CCPA policies and practices from time to time. Any changes will be posted on this website at www.luk.ai/privacypolicy with an updated revision date.

 

COOKIE POLICY

Cookies – Cookies are small text files that are saved on your computer or mobile device when you visit 77X’s Sites. They enable the Sites to record and/or remember your actions and preferences. 77X places cookies on your device to ensure that the Site function properly, to track how you use our Site, to improve our Sites and your user experience, and to tailor our Sites to your interests. 77X/Luk.AI uses the following cookies on our Sites:

 

  • Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Website and use its features. These cookies will be placed on your device and used even if you do not consent to the use of cookies.

 

  • Performance Cookies: These cookies collect information about how you use the Sites (e.g. which pages you go to most often) to improve how the Sites work.

 

  • Functionality Cookies: These cookies allow the Sites to remember the choices that you make (e.g. the language you select or the region you are in) and provide enhanced, more personal features.

 

  • Targeting/Advertising Cookies: These cookies are used to deliver online advertisements on and off the Sites that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaigns. The cookies are used to remember that you have visited the Sites, and this information may be shared with advertisers and other organizations. 

 

The cookies used by 77X/Luk.AI are either first party or third party cookies. First party cookies are set by 77X/Luk.AI and share the same domain. We place a first party cookie on your device when you log into the Sites, for instance. Third party cookies are stored by third party providers and organizations with different domains.

 

We use both session cookies, which expire once you close your browser and persistent cookies, which stay on your device until you delete them or they expire.

 

Opt-out – 77X is committed to transparency and your privacy.  We provide the following links so that you can opt out of cookies provided by our first party ad serving vendor and many third-party advertising partners who may be engaging in online behavioral advertising: 

 

  • Third Party and Interest-Based/Online Behavioral Advertising Opt-out – Please visit this link to opt-out of cookies from over 50 major third-party behavioral advertising providers: http://www.aboutads.info/choices