Privacy Policy
1. Introduction
LuGrowth OÜ (“LuGrowth”, “we”, “us”, or “our”) respects your privacy and is committed to protecting personal data collected through lugrowth.ai.
This Privacy Policy explains what information we may collect, how we use and protect it, when it may be shared, and the rights available to individuals under applicable data protection laws, including the General Data Protection Regulation (GDPR).
2. Company Information
LuGrowth OÜ
Company Registration Number: 17109557
Registered Address: Harju maakond, Tallinn, Haabersti Linnaosa, Paldiski mnt 199a, 13517, Estonia
Website: lugrowth.ai
Email: support@lugrowth.ai
LuGrowth OÜ acts as the data controller for personal data collected through this website where it determines the purposes and means of processing.
3. Information We May Collect
Depending on how you interact with our website, we may collect:
- Name
- Business email address
- Company name
- Website address
- Contact information
- Information submitted through contact or enquiry forms
- Project requirements and business information you voluntarily provide
- Communications with our team
- IP address
- Browser and device information
- Website usage and technical information
- Cookie and consent preferences
Please do not submit confidential, sensitive, or unnecessary personal information through general website enquiry forms.
4. How We Collect Information
Information may be collected when you:
- Visit our website
- Submit a contact form
- Request information about our services
- Communicate with us by email
- Discuss a potential project with us
- Interact with website functionality
- Accept or manage cookie preferences
Certain technical information may also be collected automatically through cookies, server logs, and similar technologies.
5. How We Use Personal Data
We may process personal data to:
- Respond to enquiries
- Communicate with prospective and existing clients
- Evaluate project requirements
- Provide requested information
- Prepare proposals and discuss potential services
- Deliver and manage contracted services
- Maintain business relationships
- Operate and improve our website
- Maintain website and system security
- Diagnose technical problems
- Understand website performance
- Maintain appropriate business and compliance records
- Comply with legal obligations
- Establish, exercise, or defend legal claims
We do not sell personal data.
6. Legal Bases for Processing
Where the GDPR applies, we may process personal data on one or more of the following legal bases:
Consent
Where you have provided consent for a particular processing activity.
Contract
Where processing is necessary to enter into or perform a contract with you or the organisation you represent.
Legitimate Interests
Where processing is necessary for legitimate business purposes, such as responding to business enquiries, managing client relationships, maintaining security, improving our services, and operating our business, provided those interests are not overridden by your rights.
Legal Obligation
Where processing is required to comply with applicable laws or regulatory requirements.
7. Business Enquiries
When you contact LuGrowth regarding a potential project or business relationship, we may use the information you provide to understand your requirements, communicate with you, assess whether our services are suitable, and prepare relevant commercial information.
Submitting an enquiry does not create a contractual relationship between you and LuGrowth.
8. Data Sharing
We may share personal data with trusted service providers where reasonably necessary to operate our website or business.
These may include:
- Hosting providers
- Cloud infrastructure providers
- Email and communication providers
- IT and security providers
- Analytics providers
- Professional advisers
- Contractors supporting our operations
We may also disclose information where required by law, regulation, court order, or a competent authority.
Service providers are permitted to process personal data only for appropriate purposes and subject to applicable contractual and legal requirements.
9. International Data Transfers
Some service providers may process information outside Estonia or the European Economic Area.
Where personal data is transferred internationally, we take appropriate steps to ensure that legally required safeguards are in place.
Depending on the circumstances, these safeguards may include adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms recognised under applicable data protection law.
10. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes for which it was collected.
Retention periods may depend on:
- The nature of the information
- The purpose of processing
- The duration of a business relationship
- Contractual requirements
- Legal and accounting obligations
- Potential disputes or legal claims
When personal data is no longer required, it may be deleted, anonymised, or securely archived where retention is legally required.
11. Data Security
We use reasonable technical and organisational measures designed to protect personal data from unauthorised access, disclosure, alteration, loss, or misuse.
Measures may include access controls, authentication, secure infrastructure, system monitoring, and appropriate internal procedures.
However, no internet transmission or electronic storage system can be guaranteed to be completely secure.
12. Your GDPR Rights
Where the GDPR applies, you may have the right to:
- Request access to your personal data
- Request correction of inaccurate information
- Request deletion of personal data
- Request restriction of processing
- Object to certain processing
- Request data portability where applicable
- Withdraw consent where processing relies on consent
- Lodge a complaint with a competent data protection authority
These rights may be subject to legal limitations and exceptions.
To exercise your rights, contact: support@lugrowth.ai
We may request reasonable information to verify your identity before processing a request.
13. Automated Decision Making
LuGrowth does not intend to use information collected through general website enquiries to make decisions producing legal or similarly significant effects solely through automated processing.
If this changes, appropriate information and safeguards will be provided where required by law.
14. Cookies
Our website may use cookies and similar technologies for essential website functionality, security, preferences, and, where implemented, analytics.
Non-essential cookies should only be used in accordance with applicable consent requirements.
More information is available in our Cookie Policy.
15. Third Party Websites
Our website may contain links to external websites or services.
LuGrowth is not responsible for the privacy practices, security, or content of third party websites.
We recommend reviewing the privacy policies of external services before providing them with personal information.
16. Children's Privacy
Our website and services are intended for businesses and professional users and are not directed toward children.
We do not knowingly seek to collect personal data from children through the website.
17. Data Protection Complaints
If you have concerns regarding our handling of personal data, please contact us first at: support@lugrowth.ai
Where applicable, you also have the right to lodge a complaint with the relevant supervisory authority.
As LuGrowth OÜ is established in Estonia, the relevant supervisory authority is the Estonian Data Protection Inspectorate, subject to the rules governing jurisdiction under applicable data protection law.
18. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our website, services, technology, legal requirements, or data processing practices.
The latest version will be published on this page with an updated revision date.
19. Contact
For questions about this Privacy Policy or the processing of personal data, contact:
LuGrowth OÜ
Company Registration Number: 17109557
Registered Address: Harju maakond, Tallinn, Haabersti Linnaosa, Paldiski mnt 199a, 13517, Estonia
Email: support@lugrowth.ai
Website: lugrowth.ai