Privacy Policy

This Privacy Policy explains how MeetLucas ("MeetLucas," "we," "us," or "our") collects, uses, discloses, and otherwise processes personal data in connection with our AI-powered educational chatbot service, as well as any specific product, service, or application that references or links to this Privacy Policy. We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.

This Privacy Policy does not address our privacy practices relating to MeetLucas job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information in certain jurisdictions). This Privacy Policy is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you register for an account, engage with our AI chatbot, make a purchase, or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our websites and services and may also collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us:

• Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

• Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes, grade level, school affiliation, learning preferences, and the educational services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our educational services, communicate with you regarding your account and your use of our services, and for customer support purposes.

• Educational Content, including any questions, assignments, notes, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to, or make available through, our AI chatbot and educational services. We use this content primarily to provide you with our educational services, to facilitate your learning requests, and to improve our AI models and educational services.

• Learning Data, including your interactions with our AI chatbot, learning progress, quiz results, study patterns, subject preferences, and educational achievements. We use this information to personalize your learning experience, track your progress, provide recommendations, and improve our educational services.

• Sensitive Information, including Payment Information as defined below and any information that may be revealed through your educational content or communications, such as learning disabilities, health information, or other sensitive personal information. We use this content primarily to provide you with our educational services, to facilitate your requests, and to improve our services.

• Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). Please note that we regularly use third-party payment providers, including Stripe, to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider's use of your personal data is governed by their privacy notice.

• Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, including our online live chat or automated chat functions, email addresses, or other contact information we make available to students and educators, as well as recordings of calls with us, where permitted by law. We use this information primarily to investigate and respond to your inquiries, to communicate with you via online chat, email, phone, text message or social media, and to improve our educational services.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our educational services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners' automatic data collection technologies, including (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted by law) to link information collected from different devices.

• Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the educational materials you access, the AI conversations you have, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or learning behavior. These third-party technologies may also record information you enter when you interact with our AI chatbot or engage in educational activities we provide.

• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address.

All of the information collected automatically through these tools allows us to improve your educational experience. For example, we may use this information to enhance and personalize your learning experience, to monitor and improve our educational services, to offer communications features such as live and automated chat, and to improve the effectiveness of our AI tutoring, educational content, offers, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized educational content and information, including targeted learning recommendations; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our educational services; (e) monitor aggregate metrics such as total number of students, usage, and learning patterns on our platform; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our educational services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

• Educational Institutions: We are able to offer you the educational services we make available because of partnerships with schools and educational institutions. To provide our educational services and facilitate our platform, we may receive personal data from educational institutions for purposes and uses that are consistent with this Privacy Policy. For example, we may receive your contact information and enrollment details to process and fulfill your educational program from a representative at your school.

• Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain, such as Google or Microsoft accounts. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our educational services.

• Other Students and Educators: We may receive your personal data from our other users. For example, a teacher may share your contact information when setting up class accounts, or other students may mention you in group learning activities.

• Parents and Guardians: For users under 18, we may receive personal data from parents or guardians, including contact information, consent records, and information about learning needs or accommodations.

• Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our educational services, as well as to communicate directly with you, such as to send you messages about educational features that may be of interest to you.

• Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us.

• Other Sources: We may also collect personal data about you from other sources, including through transactions such as mergers and acquisitions.

• Inferences: We may generate inferences or predictions about you and your learning interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our educational services, or to deliver the learning services requested;
• Manage our organization and its day-to-day operations;
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Request you provide us feedback about our educational offerings;
• Address inquiries or complaints made by or about an individual in connection with our educational services;
• Create and maintain accounts for our students and educators;
• Verify your identity and entitlement to our educational services;
• Administer, improve, and personalize our educational services, including by recognizing you and remembering your information when you return to our services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our educational services;
• Identify and analyze how you use our educational services;
• Infer additional information about you from your use of our educational services, such as your learning interests;
• Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Policy;
• Conduct research and analytics on our user base and our educational services, including to better understand the demographics of our students and learning patterns;
• Improve and customize our educational services to address the needs and interests of our students and other individuals we interact with. Data from users who will not be used for model training;
• Test, enhance, update, and monitor the educational services, or diagnose or fix technology problems;
• Help maintain and enhance the safety, security, and integrity of our property, educational services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of MeetLucas and others;
• Facilitate business transactions and reorganizations impacting the structure of our business;
• Comply with contractual and legal obligations and requirements, including educational privacy laws such as FERPA and COPPA;
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

• To Educational Institutions: When you access MeetLucas through your school or educational institution, we may disclose personal data to that institution for educational purposes consistent with this Privacy Policy. For example, we may share your learning progress, quiz results, and usage data with your teachers or school administrators to support your educational experience.

• To Parents and Guardians: For users under 18, we may share learning progress, account activity, and other educational information with parents or guardians as permitted by applicable law, including FERPA and COPPA.

• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.

• To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.

• To AI Infrastructure Providers: We use third-party AI services (such as OpenAI, Anthropic, or Google) to power our educational chatbot. These providers:

• Process your educational content only to generate responses
• Do not retain your conversations for their own training (where contractually guaranteed)
• Are bound by data processing agreements that limit their use of your data
• May be located outside your jurisdiction with appropriate safeguards in place

• To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.

• To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:

• in connection with the establishment, exercise, or defense of legal claims;
• to comply with laws or to respond to lawful requests and legal process;
• to protect our rights and property and the rights and property of our agents, students, educators, and others, including to enforce our agreements, policies, and terms of use;
• to detect, suppress, or prevent fraud;
• to reduce credit risk and collect debts owed to us;
• to protect the health and safety of us, our students, educators, or any person; or
• as otherwise required by applicable law.

• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

Your Privacy Choices

Communication Preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or educational service update emails).

• Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out of promotional phone calls (where available), or replying STOP to any one of our promotional text messages. Please note we may need to continue to communicate with you via phone for certain service-related messages (such as, sending a verification code to your phone via call or text for purposes of verifying the authenticity of a log-in attempt).

• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device's notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device's notifications settings and are not responsible if they do not function as intended.

AI Training and Data Usage Preferences

Important: We may use your educational content and interactions to improve our AI systems and train our models, but only with your explicit consent or where you have not opted out.

Your Rights Regarding AI Training:

• You can opt out of AI training at any time through your account settings or by contacting us
• When we use your content for training, we remove personally identifiable information where possible
• We implement technical safeguards to prevent memorization of specific conversations
• We do not use sensitive information for training purposes
• You retain the right to request deletion of your data from training datasets

How to Opt Out: Visit your account settings and toggle off "Allow data for AI improvement" or email privacy@meetlucas.ai with "AI Training Opt-Out" in the subject line.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

Automatic Data Collection Preferences

You may be able to utilize third-party tools and features to restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Targeted Advertising Preferences

We may engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services.

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance's self-regulatory program.

• Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative's self-regulatory program.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties' opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Modifying or Deleting Your Personal Data

If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us as set forth in the Contact Us section below. We may not be able to modify or delete your personal data in all circumstances.

Partner-Specific Preferences

• Google Analytics: Google Analytics allows us to better understand how our students interact with our services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics' currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/?ref=help-center.

Children's Personal Data

COPPA Compliance

MeetLucas is designed for educational use and may be used by children under 13. We comply with the Children's Online Privacy Protection Act (COPPA):

• Parental Consent: We obtain verifiable parental consent before collecting personal information from children under 13, except where we rely on the school official exception under COPPA • Limited Collection: We collect only information necessary for educational purposes • No Marketing: We do not use children's data for marketing or advertising • Parental Rights: Parents can review, delete, or refuse further collection of their child's information

Educational Institution Access

When students under 18 access MeetLucas through their school:

• We rely on the school's authority to provide consent under FERPA and the school official exception under COPPA
• Parents retain the right to review their child's educational records
• Enhanced security measures apply to accounts identified as belonging to minors
• Schools can request bulk deletion of student data upon program termination

Teen Users (13-17)

For users aged 13-17, we may collect information with the teen's consent, but parents retain certain rights to access and control their child's account.

If a child under the age of 13 has provided personal data to us outside of the school context without proper parental consent, we encourage the child's parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13 without proper consent, we will promptly delete that personal data.

Automated Processing

We may conduct automated processing of personal data in order to provide the educational services you request. To the extent that these activities constitute automated decision making or profiling, we do not process your personal data for purposes that produce a legal or similarly significant effect, such as a decision to offer to you or decline a request for educational services. Our AI systems are designed to support learning and provide educational assistance, not to make decisions that would significantly impact your educational opportunities.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. In addition, we take steps designed to ensure any third party with whom we share personal data provides a similar level of protection. However, despite these controls, we cannot completely ensure or warrant the security of your personal data.

Enhanced Security for Educational Data:

• Encryption of all educational content and personal data in transit and at rest
• Multi-factor authentication for administrative access
• Regular security audits and penetration testing
• Data loss prevention (DLP) systems
• Incident response procedures with notification timelines
• Employee security training and background checks

Third-Party Websites and Services

Our websites and other services may include links to or redirect you to third-party websites, plug-ins, applications, or other services. Third-party websites and other services may also reference or link to our websites and services. This Privacy Policy does not apply to any personal data practices of these third-party websites, plug-ins, applications, or other services. To learn about these third parties' personal data practices, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please click here for additional European-specific privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.

• United States - State Privacy Laws: Residents of California, Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws have specific rights under applicable state privacy laws. Contact us to exercise these rights.

• Student Privacy Laws: We comply with applicable student privacy laws including FERPA, COPPA, and state student privacy acts such as California's Student Privacy Acts.

Updates to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Policy or other privacy-related matters, please contact us at:

Email: privacy@meetlucas.ai
Subject Line Guidelines:

• "Data Request" for access, deletion, or portability requests
• "AI Training Opt-Out" to opt out of AI training
• "Privacy Complaint" for concerns about our practices
• "GDPR Request" for EU-specific inquiries
• "Student Privacy" for FERPA or COPPA-related inquiries

Response Time: We respond to all privacy inquiries within 30 days.

ADDITIONAL EUROPEAN ECONOMIC AREA, UNITED KINGDOM, AND SWITZERLAND PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Policy by providing additional information about our personal data processing practices relating to individuals who access our services or otherwise interact with us from the European Economic Area ("EEA"), United Kingdom ("UK"), and Switzerland. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Policy.

Controller Details and Privacy Contacts

EEA, UK, and Swiss Controller

MeetLucas, a company duly incorporated and organised under the laws of the United States, is the "controller" responsible for the processing of personal data in connection with our EEA, UK, and Swiss services and operations. This means MeetLucas determines and is responsible for how your personal data is used. You may contact MeetLucas by emailing privacy@meetlucas.ai.

Our Data Protection Officer

We have appointed a Data Protection Officer who is responsible for monitoring our compliance with applicable data protection law. You can contact our Data Protection Officer with any questions or complaints you may have about our privacy practices by emailing privacy@meetlucas.ai.

Additional Questions or Complaints

If you have a concern about our processing of personal data, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:

• European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
• United Kingdom: https://ico.org.uk/global/contact-us/
• Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please contact us directly at privacy@meetlucas.ai if you have any concerns.

Purposes and Legal Bases of Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

• Contract: Where the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract with you. This applies to any processing where you sign a contract with us, for example when you become our student or your school contracts with us for educational services. This may also include processing necessary for the performance of our Terms of Service.

• Legitimate Interest: Where the processing is necessary for the purposes of a legitimate interest that are not overridden by your interests or fundamental rights and freedoms (e.g., to provide, maintain, and improve our educational services, conduct learning analytics, and communicate with you regarding our services).

• Vital Interest: Where the processing is necessary to protect the vital interests of you or another person (e.g., to protect your physical safety).

• Public Interest: Where the processing is necessary to perform tasks carried out in the public interest or in the exercise of official authority vested in us (e.g., to cooperate in an ongoing law enforcement investigation).

• Legal Obligation: Where the processing is necessary to comply with our legal obligations (e.g., to maintain a record of your personal data to comply with laws and regulations related to education, bookkeeping, accounting, taxation, and FERPA requirements).

• Consent: Where we have your consent for the processing (e.g., when you opt in to receive marketing communications from us or consent to AI training). When consent is the legal basis for our processing of your personal data, you may withdraw your consent at any time.

You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our educational services. For example, we need your personal data to facilitate and deliver educational services that you request. If you choose not to provide us with your personal data, we may not be able to provide you with educational services you request. We will inform you at the point that we collect personal data from you if the provision of certain personal data is mandatory or optional for receipt of our educational services.

Your Additional EEA, UK, and Swiss Privacy Choices

Subject to certain limitations at law, you may be able to exercise the following rights:

• Right to Access: The right to obtain confirmation of whether we are processing personal data about you, access to and a copy of the personal data we are processing about you, and information relating to its processing, including:

• The categories of personal data being processed;
• The purposes of the processing;
• The categories of the sources of the personal data;
• The categories of recipients to whom the personal data have been or will be disclosed;
• The envisaged period for which the personal data will be stored, or the criteria used to determine that period;
• Any automated decision-making or profiling performed in connection with your personal data; and
• The safeguards relied upon for the transfer of personal data to any third country.

• Right of Portability: The right to obtain a copy of the personal data we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal data to another controller without hindrance.

• Right to Rectification: The right to correct or update any personal data about you that is inaccurate or incomplete.

• Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.

• Right to Object to Processing: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

• Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal data. Please note withdrawing your consent will not affect the lawfulness of our use of your personal data before your consent was withdrawn, nor our processing of personal data pursuant to a different lawful basis for processing.

• Right to Erasure: The right to have us erase your personal data if the continued processing of that personal data is not otherwise justified.

Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our educational services to you, or otherwise engage with you in the same manner.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by contacting us at privacy@meetlucas.ai.

Before processing your request to exercise certain rights (taking into account the confidential nature of any personal data we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal data or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland.

This privacy policy is effective as of 1 November 2025 and applies to all information collected by MeetLucas.