PRIVACY POLICY

Last Updated: August 30, 2026

This Privacy Policy describes how Vincent LEGARDIEN, Sole Proprietor (SIRET: 98377742600013), hereinafter "we" or "the Editor", collects and processes your personal data when you visit the website yourfriendlucy.com.

The Lucy application itself is covered by a separate document. If you have an account and use the app, please refer to our App Privacy Policy.

1. DATA CONTROLLER

Vincent LEGARDIEN Sole Proprietor (Auto-entrepreneur)
SIRET: 98377742600013
Contact: help.lucyai@proton.me

2. DATA COLLECTED AND PURPOSE

Audience measurement. When you browse this website, we measure audience in order to understand how it is used and to improve it. We use PostHog, Vercel Analytics and Vercel Speed Insights for this purpose. These tools record page views, interactions with the page, and the technical information sent by your browser, such as your IP address, the approximate location derived from it, your browser type and the page you came from.

This measurement places no cookie and stores no identifier on your device. We have configured it that way deliberately, which is why this website displays no cookie banner. The trade-off is that a returning visitor is counted as a new one. We build no advertising profile, and we do not follow you across other websites.

A strictly necessary cookie is used by the private administration area of the site, which is reserved for the Editor and is not accessible to visitors.

Waitlist. Before the launch of the Lucy application, this website offered a waitlist. If you signed up, we hold the email address you gave us. It is no longer possible to sign up: the form has been removed from the site. The purpose of that collection remains the one stated when you signed up, namely to inform you of the opening and launch of the Lucy service, including any launch offer reserved for the people who signed up. Your email address will not be used for any other purpose without your prior consent.

3. LEGAL BASIS FOR PROCESSING

Audience measurement is based on our legitimate interest in understanding and improving our website, pursuant to Article 6.1.f of the GDPR. Because it places no cookie and stores no identifier on your device, it does not require your prior consent. You may still object to it at any time by writing to us at help.lucyai@proton.me.

The processing of your email address is based on your consent, pursuant to Article 6.1.a of the GDPR. You may withdraw this consent at any time by clicking the unsubscribe link in our emails or by contacting us at help.lucyai@proton.me. Withdrawal does not affect the lawfulness of processing carried out before it (Article 7.3 GDPR).

4. DATA RETENTION

Audience measurement data is kept for a maximum of 12 months from the date of collection.

Waitlist email addresses are kept until you withdraw your consent and, in any event, no later than 12 months after the launch of the Lucy application, which took place on August 26, 2026. After that date, any remaining address is deleted from our email provider.

5. DATA RECIPIENTS AND TRANSFERS

Your email address is transmitted to our email service provider, Resend, Inc. (USA). Audience measurement data is processed by PostHog, Inc. and Vercel, Inc. (USA). For technical and security reasons, browsing data (IP addresses) are also processed by our infrastructure providers, Cloudflare, Inc. and Vercel, Inc. (USA).

All transfers to the United States are governed by Standard Contractual Clauses (SCCs) and/or Data Privacy Framework certifications, pursuant to Article 46 of the GDPR.

6. USERS OUTSIDE THE EUROPEAN UNION

While this Privacy Policy is primarily designed to comply with European data protection law (GDPR), users located outside the European Union — including residents of the United States — may exercise equivalent rights regarding their personal data by contacting us at help.lucyai@proton.me.

We do not sell, rent, or share personal data with third parties for commercial or advertising purposes, regardless of the user's location.

7. YOUR RIGHTS (GDPR)

Pursuant to the GDPR and the French Data Protection Act, you have the following rights:

• Rights of access, rectification, and erasure (Articles 15, 16, 17 GDPR).
• Right to object to or limit processing (Articles 18, 21 GDPR).
• Right to data portability (Article 20 GDPR).
• Right to withdraw consent (Article 7.3 GDPR).

To exercise these rights, contact: help.lucyai@proton.me. We will respond within one month (Article 12.3 GDPR).

8. RIGHT TO LODGE A COMPLAINT

You have the right to lodge a complaint with a supervisory authority, such as the CNIL in France (www.cnil.fr).