Privacy Notice

1. Who we are

NAT-CAT CONSULTING INC. ("we", "us", "our"), operating the Lucentra service, is the data controller for the personal data described in this notice.

2. Data we collect

• Account data: email address, display name, login credentials.
• Profile and preferences: support style, daily rhythm, intentions you set in onboarding.
• User content: check-ins, journal entries, vault items, ritual logs, and any text or voice notes you create.
• Usage and telemetry: pages viewed, features used, errors, timestamps.
• Device and technical data: browser type, device identifiers, IP address.
• Support communications: messages you send to us or to Paddle.

3. Why we use your data and on what legal basis

• To create and operate your account, and to provide the Service (performance of contract).
• To personalize the AI companion to your preferences (performance of contract; consent for sensitive personal reflections).
• To prevent fraud, abuse, and secure the Service (legitimate interests).
• To improve the Service, including aggregate analytics (legitimate interests).
• To provide customer support (performance of contract; legitimate interests).
• To send service and, where you have opted in, marketing communications (consent, withdrawable at any time).
• To comply with legal obligations (legal obligation).

4. Who we share data with

• Service providers / subprocessors: hosting, database, authentication, analytics, AI inference, voice synthesis, error monitoring, and customer support tooling.
• Merchant of Record — Paddle: Paddle.com Market Limited acts as the Merchant of Record for sales of the Service and handles subscription management, payments, sales tax, invoicing, and refunds. Paddle has its own privacy notice at paddle.com/legal/privacy.
• Professional advisers: legal, accounting, and audit firms when needed.
• Authorities: where required by law or to protect rights and safety.

5. International transfers

Your data may be processed in countries outside your own, including in jurisdictions where our service providers operate. Where required, we use appropriate safeguards (such as Standard Contractual Clauses or adequacy decisions) to protect the data.

6. Retention

We keep personal data only as long as needed for the purposes set out above, to comply with legal obligations, or to resolve disputes. You can delete your account at any time from the Profile page, which removes your User Content from the Service. Backup copies may persist for a limited additional period before automated deletion.

7. Your rights

Subject to your jurisdiction (including the GDPR for UK/EEA residents and similar laws elsewhere), you may have the right to: access your data, correct it, delete it, restrict or object to its processing, port it to another provider, withdraw consent at any time, and lodge a complaint with a supervisory authority. We will respond to verified requests within the timeframes required by applicable law (typically within one month under the GDPR).

8. Security

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, authentication, and least-privilege internal access. No system is completely secure; you are responsible for keeping your account credentials confidential.

9. Cookies

The Service uses essential cookies and local storage to keep you signed in and to remember preferences. Where analytics or marketing cookies are used, you can manage preferences via your browser settings.

10. Contact

To exercise your rights or ask questions about this notice, contact NAT-CAT CONSULTING INC. via the support channels listed in the Service.