Privacy Statement
Introduction
Luzarn sp. z o. o. is an AI website, CRM and business app builder/manager for online presence, sales, customer support, automation, user engagement and more.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes Luzarn sp. z o. o.’s policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.
Contacting Us About Data Protection
Luzarn sp. z o. o. is headquartered in Warsaw, Poland. For any inquiries or concerns regarding our personal data policies, practices, or if you wish to exercise your privacy rights, please feel free to reach out directly to our Privacy Team. Our team is equipped and committed to assisting you with any questions you might have and ensuring your data is handled with the utmost care and respect.
Privacy Team Contact Information:
Luzarn sp. z o.o.
ul. Władysława Jagiełły 16 lok. 1
How we collect and use (process) your personal information
Luzarn sp. z o. o. processes personal information about its website visitors, customers and individuals whose data customers submit to the service. Depending on the features used, this information includes:
- name
- company/website name
- email address
- chat prompts, messages, uploaded files and images, including reference images submitted for image editing
- customer contact details and other personal information stored in customer-managed websites, CRM systems and business apps
- billing details and payment transaction information
- domain registrant contact details, including names, company names, email addresses, telephone numbers and postal addresses
- technical and usage information, including IP addresses, browser and device information, page visits and analytics identifiers
- consented session recordings on customer-managed websites where analytics and recording are enabled
We use this information to create and manage accounts, provide and operate customer websites, CRM systems and business apps, process billing and domain registrations, communicate with users, and maintain service security.
AI processing and analytics
To provide AI features, we send relevant chat content, uploaded images and information retrieved through the AI's tools to OpenAI for language-model processing. Image generation and editing use Meta and may involve sending prompts and reference images. Web-search queries are processed through Bright Data. Content submitted to these features may contain personal information.
We use Google Tag Manager and website analytics where configured, and PostHog for website usage analytics and AI observability where enabled. On customer-managed Live websites, analytics and session recording use our self-hosted Umami installation. Collection requires activation by the website owner and visitor consent. Session recordings use masking and input/private-content blocking, and collection stops when consent is withdrawn.
We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.
From time to time, Luzarn sp. z o. o. receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third party website (e.g. LinkedIn)
Use of the Luzarn sp. z o. o. Website
As is true of most other websites, Luzarn sp. z o. o.’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Luzarn sp. z o. o.’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Luzarn sp. z o. o. has a legitimate interest in understanding how visitors, customers and potential customers use its website to improve the service and support users. Where consent is required for analytics or tracking, collection is subject to that consent.
Cookies and tracking technologies
Luzarn sp. z o. o. makes available a comprehensive Cookie Notice that describes the cookies and tracking technologies used on Luzarn sp. z o. o. website and provides information on how users can accept or reject them. To view the notice, just click Cookie Notice.
Sharing information with third parties
Our main application and database are hosted on Hetzner infrastructure in Europe. Other providers support managed website hosting, object storage and content delivery, email, encryption-key management, AI processing, billing, domain registration and analytics. These services may process relevant personal information to provide their functions; their roles are not limited to storage and retrieval. We also use service providers to deliver account, service and product communications.
A list of our third party sub processors can be found here: https://whiteboss.ai/legal/subprocessors
We do not otherwise reveal your personal data to non-Luzarn sp. z o. o. persons or businesses for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (3) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (4) to address emergencies or acts of God; or (5) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.
The Luzarn sp. z o. o. website connects with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Luzarn sp. z o. o. website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.
International Data Transfers
Our main application and database are hosted in Europe. Personal information may also be processed outside the EU/EEA by providers supporting particular service features, including AI processing. Hosting location does not mean that all processing takes place in the same region. Provider purposes and locations are described in our subprocessor list.
Luzarn sp. z o. o. does not transfer personal data outside of the EU/EEA without appropriate safeguards. For language-model processing, we use OpenAI, a United States provider. Consent may be given to perform a contract with you or to fulfill a compelling legitimate interest of Luzarn sp. z o. o. in a manner that does not outweigh your rights and freedoms. Luzarn sp. z o. o. endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Luzarn sp. z o. o. and the practices described in this Privacy Statement. Luzarn sp. z o. o. also enters into data processing agreements and standard contractual clauses with its vendors whenever feasible and appropriate.
For more information or if you have any questions, please contact us at hello@whiteboss.ai .
Data Subject rights
The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:
- Right to be informed
- Right of access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right of data portability
- Right to object
- Rights related to automated decision making including profiling
This Privacy Notice is intended to provide you with information about what personal data Luzarn sp. z o. o. collects about you and how it is used.
If you wish to confirm that Luzarn sp. z o. o. is processing your personal data, or to have access to the personal data Luzarn sp. z o. o. may have about you, please contact us.
You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Luzarn sp. z o. o. might have received the data from Luzarn sp. z o. o.; what the source of the information was (if you didn’t provide it directly to Luzarn sp. z o. o.); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Luzarn sp. z o. o. if it is inaccurate. You may request that Luzarn sp. z o. o. erase that data or cease processing it, subject to certain exceptions. You may also request that Luzarn sp. z o. o. cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Luzarn sp. z o. o. processes your personal data. When technically feasible, Luzarn sp. z o. o. will—at your request—provide your personal data to you.
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Luzarn sp. z o. o. will provide you with a date when the information will be provided. If for some reason access is denied, Luzarn sp. z o. o. will provide an explanation as to why access has been denied.
For questions or complaints concerning the processing of your personal data, you can email us at hello@whiteboss.ai.
Use of Google Workspace APIs
Luzarn sp. z o. o. uses Google Workspace APIs to provide certain functionalities within our service. We want to explicitly affirm that any data obtained through Google Workspace APIs is not used to develop, improve, or train generalized AI and/or ML models. The data accessed through these APIs is solely used for the specific purposes of providing our service features and is handled in accordance with our privacy practices as outlined in this policy.
Data Protection Mechanisms
At Luzarn sp. z o. o., we implement robust data protection mechanisms to safeguard your sensitive information:
- Encryption: All customer data is encrypted using industry-standard encryption algorithms both at rest and in transit.
- Access Control: We employ user roles and permissions to ensure that only authorized personnel can access sensitive data.
- Rate Limiting: To protect against abuse, we implement rate limiting on our agents, controlling the number of requests per user.
- Infrastructure Security: Our main application and database run on Hetzner infrastructure in Europe. Managed websites use OVHCloud or AWS hosting. Cloudflare provides object storage and content delivery, and AWS provides SES email delivery and KMS encryption-key management.
- Compliance: We are GDPR compliant.
- No AI Training: We do not use your data to train AI models. We use Retrieval-Augmented Generation (RAG) to generate responses without compromising your data.
Data storage and retention
Your personal data is stored by Luzarn sp. z o. o. on its servers, and on the servers of the cloud-based database management services Luzarn sp. z o. o. engages, located in the European Union. Luzarn sp. z o. o. retains service data for the duration of the customer’s business relationship with Luzarn sp. z o. o. and for a period of time thereafter, to analyze the data for Luzarn sp. z o. o.’s own operations, and for historical and archiving purposes associated with Luzarn sp. z o. o.’s services. We retain personal data for no longer than 3 years from last interaction, unless a longer period is required by law or necessary to establish, exercise or defend legal claims. Luzarn sp. z o. o. retains prospect data until such time as it no longer has business value and is purged from Luzarn sp. z o. o. systems. All personal data that Luzarn sp. z o. o. controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: hello@whiteboss.ai
Transfer of Personal Data in the Event of Corporate Changes
The Controller may transfer personal data to another entity in the event of a merger, acquisition, corporate reorganization, transfer of assets, or transfer of ownership or operation of the Service to another entity.
In such cases, personal data shall be transferred only to an entity that:
processes personal data in accordance with GDPR,
provides safeguards ensuring a level of data protection no less protective than those described in this Privacy Policy, processes personal data solely for purposes compatible with those for which the data was originally collected.
Legal Basis for Data Transfer
The legal basis for the transfer of personal data in the circumstances described above is the Controller’s legitimate interest in ensuring the continuity, development, and lawful operation of the Service.
User Information Obligation
Users shall be informed of any transfer of personal data resulting from corporate changes in accordance with Articles 13 and 14 of the GDPR, including information about the new controller, where applicable.
User Rights Remain Unchanged
The transfer of personal data as described above shall not affect the rights of Users under applicable data protection laws. Users retain all rights granted to them under the GDPR, including the right of access, rectification, erasure, restriction of processing, data portability, and objection.
Children’s data
We do not knowingly attempt to solicit or receive information from children.
Questions, concerns or complaints
If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
Luzarn sp. z o.o.
ul. Władysława Jagiełły 16 lok. 1
Warsaw, Poland