Privacy Policy

Luceria is the data controller for the personal data described in this policy. That means we decide what data is collected and why, and we are legally responsible for it under UK and EU data-protection law.

Controller details

If anything in this policy is unclear, email [contact Luceria](/contact) and we will explain it.

Under the Data (Use and Access) Act 2025 (DUAA) — and reflecting the data-protection complaints duty that comes into force on 19 June 2026 — you have the right to complain directly to us about how we handle your personal data, and we have a duty to deal with that complaint properly.

This is a separate route from ordinary product support. Use it specifically for privacy and data-protection concerns (for example: you think we have your data wrong, kept it too long, shared it when we shouldn't have, or didn't honour one of your rights).

How to make a data-protection complaint

• By email: [contact Luceria](/contact) with the subject line "Data protection complaint".

What we promise

• We will acknowledge your complaint within 30 days of receiving it.
• We will give your complaint a reference so its status can be tracked.
• We will investigate and respond without undue delay, and tell you the outcome and what (if anything) we have done.

Complaining to us first does not remove your right to complain to the Information Commissioner's Office (ICO) or your local data-protection authority — see [Complaints to a regulator](#regulator-complaints).

Below is a full inventory of the data categories Luceria handles. For each one we set out the purpose, the UK GDPR Article 6 legal basis, and the retention period. Where the legal basis is legitimate interests, we have considered a balancing test to make sure our interests don't override your rights — see the note under the table.

Note on legitimate interests. Where we rely on legitimate interests (rows 4, 7, 9, 10, 13), we have weighed our interest (running a safe, working, improvable service and preventing abuse) against your rights and freedoms, and we use the least intrusive data possible (for example, analytics carry no content and rate-limiting data is transient). You can object to legitimate-interests processing — see [Your rights](#your-rights).

Some of the things you can type or upload into Luceria are free text — for example a resume, a cover letter, a reflection, a Coach message, or text pasted into the scam checker. Free text can incidentally contain sensitive information.

Special-category data (UK/EU GDPR Article 9) includes data revealing your health, race or ethnicity, religion or beliefs, political opinions, trade-union membership, sex life or sexual orientation, and genetic/biometric data. Criminal-offence data (Article 10) includes information about offences, allegations, or related proceedings.

Luceria does not ask you for sensitive data and is not designed to collect it. To protect yourself:

• Please do not upload sensitive personal data you don't need to. A good resume or application rarely needs your health history, religion, political views, or details of any criminal record.

Where you voluntarily include such information, Luceria processes it only so far as necessary to provide the specific service you asked for (for example, generating help from the resume you chose to upload). We do not seek it out, profile you on it, or use it for any other purpose.

Nothing in this section gives Luceria a broad right to process sensitive data — it does not. If you would like sensitive content removed, contact [contact Luceria](/contact) or delete it yourself in the app.

Several Luceria features use AI to help you (Resume Studio, AI Coach, Mock Interview, Interview Prep, the scam/risk checker, the Fit/suitability check, and Luceria Lens).

• Where the AI runs. When you use an AI feature, the relevant content is transmitted server-side only to an AI provider acting as our processor — it processes the data on our instructions to return a result, and it is never called from your browser. For most features that provider is Anthropic (Claude). One exception: free-tier workflow plan generation may be processed by OpenAI (GPT-4.1 nano) where that route is enabled; on the paid tiers, and whenever the OpenAI route is unavailable, it runs on Anthropic instead.

• Assistive only. Luceria's AI is assistive. It helps you draft, prepare, and assess — it does not make decisions about you. There is no solely-automated decision producing legal or similarly significant effects about you (UK GDPR Article 22). A human (you) stays in control of what you do with the output.
• Your judgement matters. AI can be wrong. Always review AI output before relying on it, and don't paste anything into Luceria you're not comfortable sending to a third-party AI provider under the terms above.

The transfers of data to Anthropic (US) and OpenAI (US) are covered in [International transfers](#international-transfers).

We use a small number of trusted service providers (sub-processors) to run Luceria. They process data on our behalf under contract, only for the purposes below. We do not sell your personal data. The only advertising-related sharing is the optional TikTok Pixel described below.

TikTok (only if you switch on Marketing cookies). TikTok is not our sub-processor: if you turn on the optional Marketing category, the TikTok Pixel sends TikTok the public Luceria pages you visit plus technical data (IP address, browser details, a TikTok cookie id), and TikTok uses it as an independent controller to measure our adverts and for its own advertising, under TikTok's privacy policy. Our lawful basis is your consent, which you can withdraw at any time via Cookie settings. It is off by default, never runs on your resume, application, account or sign-in pages, and the pixel never receives your resume, name, email address or anything you type. If you switch on Marketing, our server also tells TikTok when you create an account or start a paid subscription (with the amount and currency), identified only by a scrambled (SHA-256 hashed) copy of your email address and of your Luceria user id, plus your IP address and browser details where we have them. We never send your name, resume, job details or anything else about your career, and if Marketing is off we send nothing.

We may also disclose data where we are legally required to (for example, a valid court order), or to protect the rights, safety, and security of our users and the service.

Primary residency is the EU. Your core data (account, profile, content, risk checks, uploaded documents) is stored with Supabase (EU, Ireland) and served via Vercel (London, UK) — both within the UK/EU. Data at rest stays in the EU; request handling runs in the UK, which the EU recognises as providing an adequate level of protection (EU–UK adequacy).

Transfers outside the UK/EU. The main transfers are to Anthropic in the United States for AI inference and, for free-tier workflow plan generation where enabled, to OpenAI in the United States. Where we transfer personal data outside the UK or EEA, we rely on an appropriate safeguard so your data keeps an equivalent level of protection.

• Anthropic (US):
• OpenAI (US):
• Other providers processing outside the UK/EEA: covered by the safeguards listed in the [sub-processor table](#sub-processors).

You can ask us for more detail about the safeguards in place by emailing [contact Luceria](/contact).

Under UK GDPR (and EU GDPR where it applies to you), you have the following rights over your personal data. We will respond to a valid request within one month (extendable by up to two further months for complex requests — we'll tell you if so).

Export note. The in-app JSON export includes your profile and onboarding entries, workflows and step state, tracker/application data, tasks, artefacts, documents, risk checks, reflections, assistant actions, email imports, search preferences, usage/metering records, consent history, product events, and the Luceria Link content and interactions you created. Private document files are supplied through signed download links that expire after 10 minutes, so download those files promptly for a permanent copy. Certain security, fraud, billing, and moderation records may require a verified access request and individual review because they can be subject to legal retention duties or contain another person's data; email [contact Luceria](/contact) for those records.

Using your rights is free in most cases, and we won't penalise you for it.

You can delete your account at any time from Settings → Delete account (you type "DELETE" to confirm). This triggers an immediate cascade that removes your data across roughly 19 tables.

Deleted immediately on account deletion:

• Your authentication record, profile, and onboarding data.
• Your content: workflows, applications/tracker, tasks, artefacts, resume documents, cover letters, risk checks, fit checks, reflections, and Coach/chat history.
• Luceria Link posts and comments — hard-deleted (not just hidden).
• Usage counters tied to your account.

Retained for a limited time or for legal reasons:

• Backups: copies of data may persist temporarily in encrypted backups until those backups rotate out on their normal cycle.
• Payment, invoice, and tax records: retained for the statutory accounting period we are legally required to keep them.
• Legal / security / fraud-prevention records: a minimal set of records may be retained where needed to comply with the law, resolve disputes, or prevent abuse/fraud.
• Consent record: kept as needed to evidence the terms you agreed to.

For users under 18. If you are under 18 and want your public Luceria Link posts or profile removed quickly, you don't have to delete your whole account — email [contact Luceria](/contact) (subject "Under-18 removal") or use the in-app delete/report tools, and we will prioritise the request and remove the public content promptly.

Access to your data by Luceria staff is limited to what is necessary and controlled.

• Staff may access account or content data only where genuinely needed — for example to provide support you asked for, investigate a safety report, debug a fault, or meet a legal obligation.
• Access is role-based and restricted; not everyone can see everything.
• Database access uses Postgres Row-Level Security, and administrative access is limited.

We do not read your private workflows, documents, or messages for product development without a lawful basis and, where required, your consent.

In short, for younger users: Luceria is for ages 16 and over. We try to collect as little about you as possible, we keep your privacy settings switched to high by default, we do not profile you or send you targeted marketing, and we ask you not to upload sensitive information you don't need to. You can export or delete your data yourself in Settings, and if you're under 18 we'll remove public posts especially quickly.

Because many of our users are 16–18 school-leavers, we treat children's-data obligations (including the ICO Children's Code / Age Appropriate Design Code) as applying throughout the product:

• High-privacy defaults for under-18s.
• No profiling and no targeted marketing to minors without a documented assessment showing it's in their interests.
• Proportionate age assurance — we ask you to confirm you are 16+ and record your date of birth as part of consent (migration 0017).
• A clear warning not to upload sensitive data (see [Sensitive data](#special-category-data)).
• Data minimisation — we only collect what the feature needs.

EU users. The minimum digital-consent age varies by EU country (13–16). Before any active EU marketing or EU-targeted processing that relies on a child's consent, the relevant per-country age must be checked.

We provide the following voluntarily in a California-style format for transparency. This does not mean we are admitting we are covered by, or subject to, the CCPA/CPRA or any other US state privacy law.

• Categories we collect: identifiers (email, name); account/profile information; user content you create; commercial information (subscription/payment metadata via Stripe); internet/network activity (privacy-conscious analytics, transient IP for rate-limiting); and inferences only insofar as needed to tailor help. See [What data we collect](#data-we-collect) for detail.
• Categories we "disclose": we share data with the service providers listed in the [sub-processor table](#sub-processors), strictly to run the service.
• Sale / sharing: we do not sell your personal information. If — and only if — you switch on the optional Marketing cookies, the TikTok Pixel shares the public pages you visit with TikTok, which may count as "sharing" for cross-context behavioural advertising under California law. It is off by default; you can switch it off at any time via Cookie settings, and we honour the Global Privacy Control signal as an opt-out (the pixel never loads when your browser sends it).
• Sensitive personal information: we do not seek it; see [Sensitive data](#special-category-data).
• Your choices: Californians (and other users) can access, delete, and correct their data using the in-app Settings tools or by emailing [contact Luceria](/contact), and we will not discriminate against you for exercising these choices.

We use only a small set of cookies and similar technologies — mainly strictly-necessary ones for signing in and security, plus privacy-conscious analytics and, only if you switch on Marketing, the TikTok Pixel to measure our TikTok ads. We do not use Google Analytics, any other advertising cookies or tracking pixels, fingerprinting, link decoration, or tag managers.

For the full list (including sb-* auth/session cookies, the luc_prc scam-check quota cookie, functional luceria:* device-local storage, Vercel Analytics, Vercel Speed Insights, and Stripe-set cookies on checkout pages), please see our separate [Cookie Policy](/cookies), which also covers how PECR (the UK cookie rules) applies and how you can manage your choices.

We take proportionate steps to keep your data secure, including:

• Encryption in transit (TLS) between you, Luceria, and our providers.
• Postgres Row-Level Security on user tables, so data rows are scoped to your user ID.
• Role-based, limited administrative access.
• EU hosting for primary data.
• No storage of full card numbers (payments handled by Stripe).
• Rate-limiting (Upstash) to protect against abuse, especially the public scam checker.

No system can be guaranteed 100% secure, but we work to protect your data and to keep these measures under review.

If a personal-data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware of it, where we are required to do so.

If the breach is likely to result in a high risk to you, we will also notify you without undue delay and tell you what happened, what we're doing about it, and what you can do to protect yourself.

We'd like the chance to put things right, so please [complain to us first](#complaints-route). But you always have the right to complain to a data-protection regulator.

In the UK — the Information Commissioner's Office (ICO):

• Website: ico.org.uk
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

In the EU/EEA: you may complain to your local data-protection authority (DPA).

When you use the [Luceria contact form](/contact), we process the contact details you provide, your chosen topic, subject and message so we can route and respond to your enquiry. Please do not include passwords, full payment-card numbers, resumes or unnecessary sensitive information.

Our legal basis is contract where the enquiry concerns a service or account you use, steps at your request before a contract for a sales or pilot enquiry, and legitimate interests for feedback, service administration, abuse prevention and security reports. Technical identifiers used for rate-limiting are kept only for the short anti-abuse window. Enquiry records are kept only for as long as reasonably needed to respond, manage any follow-up and meet applicable legal, security or accounting obligations.

The form is delivered through Luceria and the message is forwarded through our transactional email provider, Resend, to the monitored support workflow. We do not publish the receiving mailbox as a separate public identity. Your rights in [Your rights](#your-rights) apply to this information.

Free CV / resume check (homepage). The file you choose is read and checked in your own browser. It is not uploaded to Luceria, not stored and not sent to any AI provider. If you have accepted analytics cookies, we record only that a check ran and its coarse outcome (for example the file type) — never the file name, its text or anything in it.

Career-coach directory. Coaches listed in the directory are independent — they are not Luceria staff or processors. When you continue to a coach's booking page, you leave Luceria and the coach (or their booking provider) handles availability, payment, rescheduling and the session under their own terms and privacy notice. Luceria does not add your name, email, resume or any account detail to that link, and does not share your resume or applications with coaches. To keep the service working and secure, we record a metadata-only event that you continued to a listed coach's booking page (the coach and service identifiers — see row 7, Product events); this is not a record of a booking.

If you apply to be listed as a coach, we process the details you submit — your public profile details, services and booking links, your professional contact email, website and experience summary, and your consent to publication — to review your application and, if approved, publish the public parts of it. Our legal basis is steps at your request before a contract and legitimate interests in operating a reviewed directory. Your contact email, experience summary and our review notes are never published. Public profile details are shown only once an operator has reviewed and published them, and you can ask us to change or remove your listing at any time.

We'll update this policy when something material changes. The current version and last-updated date are shown at the top of this page and are recorded with account consent where required.

If a change meaningfully affects how we handle your data, we'll tell you — for example by email or an in-app notice — and, where appropriate, ask you to re-accept the updated terms.