Privacy Policy
Last updated: 30 aprile 2026
This policy describes how Lucex("we", "Lucex") processes the personal data of service users, in accordance with EU Regulation 2016/679 ("GDPR").
1. Data controller
The data controller is Lucex. Any privacy-related request can be sent to privacy@lucex.app.
2. Data we process
- Account data: email, Clerk user ID, country, currency, timezone, self-declared experience level.
- Position data: stock tickers, share counts and average cost prices manually entered by you. Lucex never accesses bank or broker credentials.
- AI chat history: messages exchanged with the analysis engine are stored linked to the relevant position.
- Payment data: handled entirely by Stripe. We only retain transaction and subscription identifiers.
3. Purposes and legal bases
- Service delivery (contract performance, art. 6.1.b GDPR): account management, positions, AI analyses, billing.
- Legal obligations (art. 6.1.c): retention of fiscal records, fraud prevention.
- Service improvement (legitimate interest, art. 6.1.f): aggregated, anonymous usage analytics. We do not profile individual users for marketing without consent.
4. Sub-processors
To deliver the service we rely on the following sub-processors:
- Clerk Inc. (USA) — authentication and account management.
- Anthropic PBC (USA) — AI analysis generation via the Claude model. Prompts contain position data and market context; Anthropic does not use paid-API data for training.
- Stripe Payments Europe (Ireland) — payments, subscriptions, and billing portal.
- Neon Inc. (USA) — managed PostgreSQL database.
- Vercel Inc. (USA) — application hosting.
- Twelve Data Inc. (USA) and Yahoo Finance — market data providers. We do not share personal data with them, only public stock tickers.
Extra-EU transfers are governed by Standard Contractual Clauses approved by the European Commission.
5. Retention
- Account and position data: for the duration of the relationship, and up to 12 months after account deletion.
- Tax-related data (Stripe transactions): 10 years (Italian law).
- Chat history: deleted together with the linked position.
6. Your rights
You can access, rectify, delete your data, restrict processing, object to processing, and request portability. To exercise these rights, contact privacy@lucex.app. You may also lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it).
7. Cookies and tracking
Lucex only uses essential technical cookies (Clerk session, language preference). We do not use profiling cookies or third-party advertising trackers.
8. Changes
We may update this policy. Material changes will be notified by email or in-app.
Important notice
Lucex is an informational tool. It is not a licensed financial advisor under Italian TUF (Legislative Decree 58/1998). The analyses produced do not constitute investment recommendations.