Privacy Policy

1. Purpose

This Privacy Policy explains how Flair Technologies Ltd ("we", "us", "our") collects, uses, and protects personal data when you use LUPO ("the Service").

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data We Collect

We collect only the data necessary to provide and improve LUPO.

This may include:

• Account information: name, email address, and authentication details.
• Usage data: app activity, diagnostics, and performance metrics.
• Communication data: messages or support requests sent to us.

We do not require or store unnecessary personal identifiers.

3. How We Use Data

Your data is used to:

• operate and maintain LUPO;
• provide customer support;
• improve product performance and security;
• comply with legal obligations.

We never sell or rent your personal data.

4. Processing and Storage

Data is processed securely using cloud infrastructure and local computation as required for core functionality.

We use trusted third-party processors who act under written agreements and only on our instructions.

Data may be transferred outside the UK under Standard Contractual Clauses or equivalent safeguards.

5. AI and Automation

Some features of LUPO rely on automated processing to generate suggestions or insights.

These operations are designed to minimise personal data exposure and are governed by strict confidentiality and access controls.

6. Legal Basis for Processing

We process personal data under one or more of the following lawful bases:

• your consent;
• performance of a contract;
• legitimate interests (e.g., service improvement or fraud prevention);
• compliance with legal obligations.

7. Data Retention

We retain personal data only for as long as necessary to provide LUPO or comply with legal requirements.

You may request deletion of your data at any time by contacting support@lupolabs.ai.

8. Your Rights

Under UK GDPR you have the right to:

• access your personal data;
• request correction or deletion;
• object to or restrict processing;
• request data portability;
• withdraw consent at any time.

To exercise these rights, contact privacy@lupolabs.ai.

9. Security

We use encryption, secure access controls, and internal review procedures to protect your data against unauthorised access or disclosure.

10. Children's Privacy

LUPO is not intended for use by individuals under 18.

We do not knowingly collect data from minors.

11. Third-Party Links and Integrations

LUPO may link to or integrate with third-party services.

We are not responsible for their privacy practices.

Please review their policies separately when interacting with them.

12. Changes to This Policy

We may update this Privacy Policy periodically.

The "Effective Date" will indicate the latest revision.

Significant changes will be communicated within the Service or by email before they take effect.

13. Contact Us

Questions or data requests can be directed to:

Email: privacy@lupolabs.ai
Address: Flair Technologies Ltd, 45 Fitzroy St, Fitzrovia, London W1T 6EB, UK

Enterprise customers: See our Data Processing Addendum.