Lucy Privacy Policy


Collection of Personal Information

Your privacy is important to Lucy; maintaining your trust is paramount to us. This Privacy Statement (Statement) discloses the information collection and use practices for Lucy’s and our affiliates’ Web sites, from what type of information about our Web sites’ users is gathered and tracked, to how the information is used, shared or otherwise processed offline. It also describes how cookies, web beacons and other technologies may be used in our Software-as-a-Service (SaaS) offerings and software products.

This Statement applies to Lucy Web sites that link to this Statement.  Additionally, it does not apply to instances where we merely process data on behalf of clients for their benefit, such as when we act as a web hosting service provider.

Information on Lucy and GDPR.


By using the Services, you acknowledge that Lucy will use your information in the United States, EU and any other country where Lucy operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. Please read on to learn more about how we protect personal information that’s transferred outside of Europe.

We can speak only for ourselves; this policy does not apply to the practices of third parties that Lucy does not own or control or individuals that Lucy does not employ or manage. If you provide your information from the Site to others, different practices may apply to the use or disclosure of the information that you provide to them. Lucy does not control the privacy policies of third parties. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them.

Lucy operates a global service. The United States, European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, it is done solely for the purpose of operations and proving you access to the Site. To the extent that Lucy is deemed to transfer personal information outside of the EEA, we rely separately, alternatively, and independently on the following legal bases to transfer your information:


Necessary for the performance of the contract between Lucy and its members

Lucy provides a voluntary service; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Use, which set out the contract between Lucy and its members. As we operate in countries worldwide (including in the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we need to transfer your personal information to the US and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.  

Your Responsibilities

If you are using our Services, you may receive and determine what to do with certain personal information, such as when communicating with other users. This means you process personal information (for example, name, email address) and, to the extent you do so, under EU law, you are an independent controller of data relating to other users that you may have obtained through the Services.

You are responsible for protecting user personal information you receive or process and complying with all relevant legal requirements when you use the Services. This includes applicable data protection and privacy laws that govern the ways in which you can use a user’s information. For more information on the General Data Protection Regulation, see more resources at and

As a data controller, to the extent that you process user personal information outside of the Services, you may be required under applicable data protection and privacy laws to honor requests for data access, portability, correction, deletion, and objections to processing. Also, if you disclose personal information without the user’s proper consent, you are responsible for that unauthorized disclosure. This includes, for example, disclosures you make or unintentional data breaches.

If Lucy and you are found to be joint data controllers of personal information, and if Lucy is sued, fined, or otherwise incurs expenses because of something that you did as a joint data controller of user personal information, you agree to indemnify Lucy for the expenses it occurs in connection with your processing of user personal information.


Prohibition on Uploading Personal Identifiable Information (PII)

The definition of Personal Identifiable Information (PII) varies from state to state and country by country. Generally, PII consists of a first name or initial and last name in combination of one or more of the following: social security number; passport number; driver’s license number; state identification card number; address information; financial account number, credit or debit card number in combination with a security code or password; biometric data, such as fingerprints, retina scan and facial geometry. You are solely responsible for understanding what constitutes PII in your jurisdiction.

Uploading PII to Lucy is strictly prohibited. You understand and agree that any PII you upload constitutes a breach of your contractual obligations with Lucy.

We do not screen or otherwise validate any data you upload to our system. You agree to indemnify and defend Lucy and its officers, directors, agents and employees against any and all liabilities, losses, damages, costs, expenses, causes of actions, suits, judgments, and claims by or on behalf of any person, firm, corporation, governmental entity, or other entity arising from or relating to your uploading of PII to Lucy.


Customer Data

Customer Data is data that you are allowed to upload to our servers, however, Customer Data does not include PII.


Acceptable Use of Customer Account Data

You may choose to provide us with certain information from time to time to transact business with us (collectively, Customer Account Data). For example, Customer Account Data consists of:

  • Your name and contact information so we can contact you regarding our service, process an order for a service you requested; process any other request you have made;

  • Information required to sign you up to become a supplier or business partner with us.

  • A credit card number for purchasing services from us.

  • Your education and work experience in connection with a job opening at Equals 3 for which you wish to be considered.

If you tell us that you do not want us to use your Customer Account Data to make further contact with you beyond fulfilling your request, we will respect your wishes.


Data Security Controls 

Lucy maintains data security controls that are consistent with best practices to help ensure the privacy of your Customer Account Data and Customer Data. These data security controls, include, for example:

  • restricting access to our servers by issuing authorized users a username and password;

  • implementing Secure Socket Layer (SSL) certification in all our servers;

  • using Secure File Transfer Protocol (SFTP) to upload data to our servers;

  • encrypting all data uploaded (at rest and in transit);

  • logical data separation controls; and

  • for credit card payment processing, compliance with Payment Card Industry Data Security Standards (PCI DSS).


Supplier Requirements

We also contractually require that our suppliers protect Customer Account Data from unauthorized access, use and disclosure.


Collection of Non-Personally Identifiable Information

We may also collect non-personally identifiable information relating to your use of our Web sites and SaaS offerings through the use of various technologies. For example, when you visit our Web sites or access our SaaS offerings, we may log certain information that your browser sends us, such as your IP address, browser type and language, access time, and referring Web site addresses, and we may collect non-personally identifiable information about the pages you view within our sites and other actions you take while visiting us. In addition, some of our software products include technologies that allow Lucy to collect certain non-personally identifiable information about your product use. We may also use such technologies to determine whether you've opened an e-mail or clicked on a link contained in an e-mail. Collecting non-personally identifiable information in this manner allows us to collect statistics about the usage and effectiveness of our Web sites, our software products and our SaaS offerings, personalize your experience and tailor our interactions with you. For details regarding the technologies we employ, see Cookies, Web Beacon and Other Technologies below.

From time to time, we may also collect information that pertains to you indirectly through other sources, such as list vendors. When we do so, we ask the vendors to confirm that the information was legally acquired by the third party and that we have the right to obtain it from them and use it.

The information that we collect, either directly or indirectly, may be combined to help us improve our service, overall accuracy and completeness and to help us better tailor our interactions with you. To the extent that any such data becomes Customer Account Data, we will protect it in accordance with the provisions noted above.


Third Party Storage Solutions

Lucy permits our customers to select their own third-party storage plug-in solutions such as SharePoint, Box, Dropbox or other solutions through an API. Customers are solely responsible to ensure that their third-party storage solutions have the appropriate security configurations (e.g., two-factor authentication). Lucy is not liable for any data security aspects of third-party storage plug-in solutions.


Customer Selected Query Controls

Customers may select to implement an API of their choice to perform live query on our servers. Customers may also implement their own SSL solution of choice. Customers are solely responsible to ensure that their third-party API query and SSL solutions have the appropriate security configurations. Lucy is not liable for any data security aspects of such APIs or SSL solutions.


Acceptable Use of Customer Account Data, Non-Personally Identifiable Information and International Data Transfers

The following paragraphs describe in more detail how Lucy may use your Customer Account Data, non-personally identifiable information and conduct international data transfers. 

Fulfilling your Transaction Request

If you request something from Lucy, for example, a product or service, a callback, or specific marketing materials, we will use your Customer Account Data to fulfill your request. To help us do this, we may share this information with others, for instance, Equals 3's business partners, financial institutions, shipping companies, or postal or government authorities, such as customs authorities, involved in fulfillment. In connection with a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

Personalizing your Experience on our Web Sites

We may use non-personally identifiable data to collect about you to provide you with a personalized experience on our Web sites, such as providing you with content in which you may be interested and making navigation on our sites easier.

Providing Support 

We may use your Customer Account Data to support products or services you have obtained from us, such as notifying you of a product update or fix.

We may also provide “Live Chat” sessions on our Web sites to assist you while you’re navigating through our sites; we will use your Customer Account Data you provide via these chat sessions in accordance with this Privacy Statement.

In the course of providing technical support to you, we may sometimes have incidental access to Customer Data. This Privacy Statement does not apply to our access to or handling of this data; the conditions regarding the handling and processing of that data is covered by the applicable Terms of Use or other agreements between you and Lucy.


Customer Account Data and non-personally identifiable information may be used by Lucy for marketing purposes. Before we do so, however, we will offer you the opportunity to choose whether or not to have your information used in this way. You may at any time choose not to receive marketing materials from us by following the unsubscribe instructions included in each e-mail you may receive, by indicating so when we call you, or by contacting us directly (please refer to “Privacy Questions and Access” below).

Some of our offerings may be co-branded, that is sponsored by both Lucy and third parties. If you sign up for these offerings, be aware that your Customer Account Data and non-personally identifiable information may also be collected by and shared with those third parties. We encourage you to familiarize yourself with their privacy policies to gain an understanding of the manner in which they will handle information about you.

If you choose to “Email This Page” to a friend or colleague, we will ask for their name and e-mail address. We will automatically send a one-time e-mail sharing the page you indicated, but will not use that information for other purposes.


In connection with a job application or inquiry, whether advertised on a Lucy Web site or otherwise, you may provide us with information about yourself, such as a resume. We may use this information throughout Lucy in order to address your inquiry or consider you for employment purposes. Unless you tell us not to do so in writing, we may keep this information for future consideration.

Monitoring or Recording of Calls, Chats and Other Interactions

Certain online transactions may involve you calling us or us calling you. They may also involve online chats. Please be aware that it is Lucy's general practice to monitor and in some cases, record such interactions for staff training or quality assurance purposes or to retain evidence of a particular transaction or interaction.

Mobile Applications and Use of Information in the Social Computing Environment

Lucy makes available mobile applications for download from various mobile application marketplaces. Lucy also provides social computing tools on some of its Web sites to enable online sharing and collaboration among members who have registered to use them. These include forums, wikis, blogs and other social media platforms.

When downloading and using these applications or registering to use these social computing tools, you may be asked to provide certain personal information. This registration information will be protected as Customer Account Data, except for the information that is automatically made available to other participants as part of your profile and as otherwise excepted by supplemental privacy statements that are specific to these mobile applications. It is your responsibility to read those supplemental statements to understand the applicable conditions.

Any content you post, such as pictures, information, opinions, or any other type of personal information that you make available to other participants on these social media platforms are not subject to this Statement. Rather, such content is subject to the Terms of Use of those applications and any additional guidelines and privacy information provided in relation to their use, as well as the process by which you can remove your content from such tools or get help to do so. Please refer to them to better understand yours, Lucy's, and other parties' rights and obligations with regard to such content. You should be aware that the content you post to these social media platforms may be made broadly available to others inside and outside of Lucy.

Protect the Rights and Property of Equals 3 and Others

We may also use or share your Customer Account Data to protect the rights or property of Lucy, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your Customer Account Data as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process served on our Web sites.


Information for Business Partners

If you represent a Lucy business partner, you may visit Lucy Web sites intended specifically for Lucy business partners. We may use Customer Account Data provided on those sites to administer and develop our business relationship with you, the business partner you represent, and Lucy business partners generally. For instance, this may involve using your Customer Account Data to send you details of Lucy business partner programs. It may also include sharing certain information with other business partners (subject to any confidentiality obligations that may exist), or Lucy customers or prospects. In connection with a particular transaction or program, we may also contact you as part of customer satisfaction surveys or for market research purposes.


Information for Suppliers

If you represent a Lucy supplier, you may visit Lucy Web sites intended specifically for use by Lucy suppliers. We may use Customer Account Data provided on those sites in connection with entering into or performing a transaction with you. For example, this may include sharing information with other parts of Lucy, Lucy's business partners, customers, shipping companies, financial institutions and postal or government authorities involved in fulfillment. It may also be used to administer and develop our relationship with you, the supplier you represent, and other Lucy suppliers generally.


Information Security and Accuracy

Lucy is an organization with business processes, management structures and technical systems that cross borders. As such, we may share Customer Account Data within Lucy and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Statement.

Our Statement and our data practices are designed to provide a globally consistent level of protection for Customer Account Data and Customer Data all over the world. This means that even in countries whose laws provide for less protection for your Customer Account Data and/or Customer Data, Lucy will comply with the practices in this Statement.

In some cases, Lucy uses suppliers located in various countries to collect, use, analyze, and otherwise process Customer Account Data on its behalf. It is Lucy's practice to require such suppliers to handle information in a manner consistent with Lucy's Statement.

From time to time, we may disclose Customer Account Data and non-personally identifiable information to other non-Lucy entities that are not acting as our suppliers, such as our business partners. Except as described in this Statement, we will only do so with your prior consent. We do not sell or lease such information however.

Circumstances may arise where, whether for strategic or other business reasons, Lucy decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of Customer Account Data to prospective or actual purchasers, or the receipt of such information from sellers. It is Lucy’s practice to seek appropriate protection for Customer Account Data in these types of transactions.

When transferring your Customer Account Data outside of the country of collection for the purposes identified above, Lucy complies with applicable law. For data originating from a European Union member state, Lucy uses a variety of data transfer mechanisms (including standard contractual clauses) for this purpose.

Please be aware that in certain circumstances, Customer Account Data may be subject to disclosure to government agencies pursuant to judicial proceeding, court order, or legal process. We may also share your Customer Account Data to protect the rights or property of  Lucy, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.


Cookies, Web Beacons and Other Technologies

We will retain your Customer Account Data for as long as your account is active or as needed to provide you services. If you wish to request that we no longer use your Customer Account Data to provide you services contact us at  We will retain and use your Customer Account Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

As mentioned above, we collect non-personally identifiable information from your visits to our Web sites and your use of our SaaS offerings and our software products to help us gather statistics about usage and effectiveness, personalize your experience, and tailor our interactions with you. We do so through the use of various technologies, including scripts, tags, Local Shared Objects (Flash cookies), Local Storage (HTML5) beacons, and one called "cookies". A cookie is a piece of data that a Web site can send to your browser, which may then be stored on your computer as a tag that identifies your computer. While cookies are often only used to measure Web site usage (such as number of visitors and duration of visit) and effectiveness (such as topics visitors are most interested in) and to allow for ease of navigation or use and, as such, are not associated with any Customer Account Data, they are also used at times to personalize a known visitor's experience to a Web site by being associated with profile information or user preferences. Over time this information provides valuable insight to help improve the user experience.

Cookies are typically categorized as "session" cookies or "persistent" cookies. Session cookies help you navigate through the Web site efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current visit. Session cookies are stored in temporary memory and erased when the web browser is closed. Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device's hard disk, and are still valid when you restart your browser. We use persistent cookies, for example, to record your choice of language and country location.

While Lucy Web sites at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies though your web browser. Look under the heading "Tools" (or similar heading) in your particular browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You can also generally set your browser to turn off cookies.

Cookies in our software products can be turned off in the product itself. Since cookies allow you to take advantage of some of our Web sites' features or features of our software products and SaaS offerings, we recommend that you leave them turned on. If you block, turn off or otherwise reject our cookies, some Web pages may not display properly or you will not be able, for instance, to add items to your shopping cart, proceed to checkout, or use any Web site services that require you to sign in.

Some Lucy Web sites, SaaS offerings and software products may also use Web beacon or other technologies to better tailor those sites to provide better customer service. These technologies may be in use on a number of pages across Lucy's Web sites. When a visitor accesses these pages, a non-identifiable notice of that visit is generated which may be processed by us or by our suppliers. These Web beacons usually work in conjunction with cookies. If you don't want your cookie information to be associated with your visits to these pages or use of these products, you can set your browser to turn off cookies or turn off cookies in the product itself, respectively. If you turn off cookies, Web beacon and other technologies will still detect visits to these pages; however, they will not be associated with information otherwise stored in cookies.

For more information about the technologies employed by our SaaS offerings and software products, including how to turn them off, please consult the user guide for the particular software product or SaaS offering you are using.

We use Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display Lucy advertising on others’ web sites based upon your web browsing activity also use Flash cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please visit

We may also include Web beacons in marketing e-mail messages or our newsletters in order to determine whether messages have been opened and links contained within clicked on.

Some of our business partners set Web beacons and cookies on our site. In addition, third-party social media buttons may log certain information such as your IP address, browser type and language, access time, and referring Web site addresses, and, if you are logged in to those social media sites, they may also link such collected information with your profile information on that site. We do not control these third-party tracking technologies.


Links to Non-Lucy Web Sites and Third-Party Applications

Lucy does not deliver third party online advertisements on our Web sites but we advertise our products and services on others' Web sites. Please familiarize yourself with those Web site operators' or network advertisers' privacy policies to understand their practices relating to advertising, including what type of information they may collect about your Internet usage. Some advertising networks we may use may be members of the Network Advertising Initiative (NAI) or the European Interactive Digital Advertising Alliance (EDAA). Individuals may opt-out of targeted advertising delivered by NAI or EDAA member ad networks by visiting  and

We have also engaged with certain third parties to manage some of our advertising on other sites. These third parties may use cookies and Web beacons to collect non-personally identifiable information (such as your IP address) about your activities on Lucy's and others' Web sites to provide you targeted Lucy advertisements based upon your interests. In the U.S. and Canada, those Lucy advertisements that are targeted to you will be identified with the AdChoices icon, as Lucy participates in the Digital Advertising Alliance self-regulatory program for online behavioral advertising (see and You can click on the icon in the advertisements itself to manage your preferences.

Please note that this does not opt you out of being served non-targeted advertising. You will continue to receive generic, non-targeted ads.


Notification of Changes

To allow you to interact with other Web sites on which you may have accounts (such as Facebook and other social media sites) or join communities on such sites, we may provide links or embed third-party applications that allow you to login, post content or join communities from our Web sites. We may also provide you with general links to non-Lucy Web sites. Your use of these links and applications is subject to the third parties’ privacy policies, and you should become familiar with the third-party sites' privacy policies before using the links or applications.

Lucy is not liable for the privacy practices or the content of those other Web sites.


Privacy Questions and Access

We will post a notice for 30 days at the top of this page notifying of material updates to this Statement. If we are going to use Customer Account Data in a manner different from that stated at the time of collection, we will notify you, and you will have a choice as to whether or not we can use it in such a way. 

If you have a question about this Statement or Lucy's handling of your information, you can send an email to with “Privacy” in the subject line.

You can also contact us at:

Lucy - Privacy

4951 W 77th St, Suite 30

Minneapolis MN 55435


In certain cases, you may have the ability to view or edit your Customer Account Data online. If you become aware the information is incorrect and you would like us to correct it, write to us at with “Privacy” in the subject line.

Before Lucy is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

We will contact you within 30 days of receiving your request. If you no longer wish to receive marketing e-mails from Lucy, please send an e-mail to or follow the unsubscribe instructions included in each marketing email.


Use of Subprocessors

Lucy may use processors and sub processors (including personnel and resources) in locations worldwide to deliver the SaaS. If Lucy subcontracts the performance of any of the SaaS pursuant to any attachment or TD, Lucy will be liable to the customer for the acts and omissions of Lucy subcontractors as if they were the acts or omissions of Lucy under the agreement governing the SaaS (subject to the limits and exclusions of liability).


Regulatory Authority and Disclosures

Lucy is subject to investigatory and enforcement powers of the Federal Trade Commission in the United States in connection with this Statement. Lucy may also be required to disclose Customer Account Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


Additional Information for End Users

If customers have any questions or complaints concerning Lucy’s processing of Customer Account Data on behalf of an Lucy enterprise client, they are invited to contact the enterprise client directly, or they may contact Lucy at Customers who wish to access the Customer Account Data or Customer Data that Lucy hosts on behalf of an enterprise client, or to make choices concerning such data, are invited to contact the enterprise client directly.