Privacy Policy

1. Introduction

Ask Lucilla is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use Ask Lucilla and our text-message service. We do not sell your personal information.

2. Information We Collect

2.1 Account information

• Sign-in: your name, email address and profile information from Google, Apple, or the email address and password you register with
• Phone number: Ask Lucilla requires you to verify a mobile phone number
• Profile: username and profile picture (taken with your camera or chosen from your gallery)

2.2 Location

Ask Lucilla uses your device location only while the app is open. It does not request background location (Android ACCESS_BACKGROUND_LOCATION) and does not track you when the app is closed. With your permission, we use precise and approximate location to:

• show you the map and businesses and rewards near you;
• check, about every five minutes while the app is open, whether a reward is nearby so we can alert you;
• give the Lucilla assistant your approximate position when you ask it something, so answers are local (only if you have already granted location permission);
• verify a location or QR claim: at the moment you claim we record your GPS coordinates, their accuracy, and whether the device reports a simulated ("mock") location;
• follow your location while a "time at location" or multi-stop reward requirement screen is open;
• let business owners place rewards and reward zones on the map, and let hosts create community events;
• store the home area you set on your matching profile.

Location signals recorded with claims (such as accuracy, simulated-location flags and implausible movement between claims) are used to detect location spoofing and fraud, including to train our fraud-detection systems. If you share a location with us over WhatsApp, we record the coordinates and address you share. You can decline or revoke location permission at any time in your device settings; location-based rewards and the map will then be limited.

Public directory. A business's listing can appear in the public directory on asklucilla.com. The directory shows the business's city, province and country, and the street address only if the owner chose to show it. A business that works from home can hide its street entirely; for those listings the map shows an approximate area, not the front door.

2.3 Microphone, voice notes and voice conversations

The microphone is used only when you choose to talk to the Lucilla assistant.

• Voice notes: when you hold to talk, the app records an audio clip, uploads it to our cloud storage, and our servers transcribe it using Google's Gemini models on Google Cloud Vertex AI. The transcript is then handled like a typed message. The copy on your device is deleted after upload, and our copy is deleted right after the note has been transcribed (any clip left over is deleted within 1 day).
• Voice conversations: when you start a live conversation, the app listens continuously on your device and uploads only the segments in which it detects speech. Each segment is transcribed as above, and the assistant's reply is converted to speech using Google Cloud Text-to-Speech.
• While the app is in the background (Android): a live conversation keeps running through an Android foreground service so you can keep talking with the screen off or in another app. While it runs, a notification is always shown with the current state (listening, thinking, speaking, paused) and Stop / Resume buttons. It starts only when you start a conversation, requires microphone and notification permission, pauses during phone calls or when another app takes audio, and ends when you tap Stop, swipe the app away, or close it. On iOS, a conversation pauses whenever the app goes to the background.
• Voice notes sent by WhatsApp or MMS: the audio is retrieved from our messaging provider and transcribed by Gemini; the transcript is saved with your conversation.
• Retention: in-app voice notes are deleted right after transcription; a leftover clip is deleted within 1 day. The transcript is kept like a typed message (Section 9).

You can revoke microphone access at any time in your device settings.

2.4 Camera and photos

• QR codes: the camera scans reward QR codes and event tickets. Staff members use it to scan customers' codes at the counter.
• Proof for rewards: if a reward requires a photo or video, it is taken with your camera and uploaded and stored with the business's reward.
• Other uploads: profile photos, photos and media you post in event chats and store chats, and logos and media business owners add to their listings and reward cards.
• Photos and videos sent by text message: if you send us an image (for example a menu or flyer), we store it privately and process it with Gemini to read what it shows. It is shown only to the Lucilla assistant and to the business it concerns.

2.5 Conversations with the Lucilla assistant

The Lucilla assistant is an automated AI agent, not a person. It runs on Google's Gemini models through Google Cloud Vertex AI and answers in the app and by SMS and WhatsApp. When you use it, we collect:

• Your messages and the assistant's replies. In the app, your chat history is stored with your account; it also includes your earlier SMS/WhatsApp messages with us once your phone number is linked to your account. Every text message sent to or from our number is logged with the phone numbers involved.
• Your phone number and channel (SMS or WhatsApp), and whether you are using Lucilla as a customer or as a business.
• Location context: the city or area you mention, your approximate location, and your location at the time of a request.
• What you asked for and what we showed you: the type of place or offer you were looking for, the businesses we suggested and the one you picked. We keep a record of demand in an area (what people ask for, where) and a wishlist of things you asked for that we could not yet find, so we can tell you when they appear.
• Assistant memory: preferences you tell the assistant so it can answer better — for example dietary needs, party size, home area, budget, the kind of place you like, recent requests, interests, age range, gender, a short bio and your language. Text MEMORY to see what is saved and FORGET to delete it.
• Profiles for gigs, trades and activity partners if you use those features by text.

2.6 Rewards, claims and redemptions

• Rewards you claimed, when and where, redemption codes, and the codes a business redeemed
• Answers and actions you complete to meet a reward's requirements — polls, surveys, reviews and star ratings, photo or video proof, likes, comments, follows, and time at a location
• Event tickets you bought or claimed and their check-in status
• Taps on reward cards and your interactions with business listings
• Cashback you received, where a business offers it

2.6a Orders, bookings and payments

• Payments you make in the app — event tickets, booking deposits and food orders placed ahead for pickup — with the business, items, amounts, taxes, status, refunds and receipts
• When you pay by card, Stripe collects your card details and processes the payment for the business; we receive the payment status and amount, never your full card number
• When you use a deal at an online shop, the shop's own checkout tells us that an order used our deal code, so the sale can be attributed to the deal
• When you buy or sell USDC through Coinbase, Coinbase collects and verifies your identity and payment details under its own privacy policy

2.7 Wallet and transaction data

• Your wallet address on the Base blockchain (and on Arc, if you use it)
• Transfers you make in the app and your on-chain transaction history and balance, which we look up from the public blockchain
• USDC reward payouts, ticket purchases and refunds, USDC payments for bookings and orders, campaign funding and refunds, and the network fees you paid

We never receive your biometric data or your passkey. Wallet and send confirmations use your device's own fingerprint, face or screen-lock check; we only receive a confirmation that it succeeded.

2.8 Groups, matching and community events

If you create a matching profile, we collect your display name, photo, activities, availability, travel radius, goal, preferred group size, home location and areas, age, gender and same-gender preference, languages, an "about" line, and favourite places. If you ask to join a hosted event, we collect the answers the host asks for. Messages in matched groups and event chats are stored so members can read them.

2.9 Business accounts

If you operate a business on Ask Lucilla we additionally collect: business name, address, hours, contact details and social links as you provide them; menus, product and event details, and photos you upload or text to us; your staff roster (members' usernames or phone numbers and their roles); your reward campaigns and their configuration, funding and performance; and your plan and billing status (card details for plan fees are held by Stripe, not by us).

2.10 Political campaign rewards

Some rewards are offered by political committees. To claim one you must provide your full name, street address, city, state, postal code and confirm that you are a US person, as required for those rewards. See asklucilla.com/political.

2.11 Device, usage and notifications

• Push notification tokens (Firebase Cloud Messaging) so we can send reward and deal notifications. Android asks for notification permission the first time you open the map. If push is off, a code may reach you by text message instead
• Usage analytics (Firebase Analytics) and crash reports (Firebase Crashlytics)
• App-integrity checks (Firebase App Check) to confirm requests come from the genuine app
• Device model, operating system and app version

Ask Lucilla contains no advertising SDKs, does not read your advertising ID, and does not track you across other companies' apps or websites.

2.12 Phone features you choose to use

These are each asked for at the moment you use them, never up front:

• Contacts ("Send to a contact"). The app opens your phone's own contact picker. It does not read or upload your address book. Only the one contact you pick is used, to open a message that is already filled in on your phone. (Android needs the contacts permission so the app can read that one picked row; iOS does not.)
• Calendar ("Add to calendar"). The app opens your phone's own calendar editor with the booking filled in and you tap Save. Ask Lucilla never reads your calendar. (iOS asks for write-only calendar access.)
• Bluetooth. Used only by business owners to connect a card reader for taking in-person payments.
• Texts, calls and maps. Messages opens with your text already written; nothing is sent from your number until you tap Send.

2.13 The shopping agent (browser tasks)

You can ask Lucilla to shop for you on a website — for example, fill a grocery cart. A task runs either on your phone or in a cloud browser: a temporary headless web browser on Google Cloud that runs one task and is then thrown away. For a task we collect and keep, under your account:

• the goal you gave, the store, the steps the agent took, and a picture of the page after each step (these pictures can show what is on the store's page, such as your cart);
• the page text and screenshots the agent reads, which are sent to Google's Gemini models to decide the next step;
• if you let it, your delivery address (kept in a private part of your account that only you and our servers can read), and the details of an order you approve.

Passwords, cards and one-time codes. The agent is built so that it never types a password, card number or one-time code, and never solves a CAPTCHA (it hands the screen to you). The cloud browser does not keep you signed in to any site. Every task starts signed out and asks you to sign in again; any session left over is discarded at the start and end of every task. The saved-login vault is on your phone only. If you choose to save a website login, the app stores the site, username and password in your phone's secure storage (the iOS Keychain, set so it is not synced to iCloud or restored onto another phone, or Android's Keystore). Nothing is written to our servers. It is released only after Face ID, your fingerprint or your passcode, and only to a page of the same website, so a look-alike address gets nothing. It is never shown to the AI model. When a cloud task needs it, the app seals it on your phone so that only that cloud browser can open it, it is typed in once and deleted. Deleting your account deletes everything the shopping agent kept: your task history and pictures, any sealed logins, queued tasks, the delivery identity used for shop checkouts, and buyer details kept for cloud checkouts. Task history and pictures do not expire on their own yet; they stay until you delete your account.

Buying. Paying is off for a task unless you turn it on. When the agent could place an order it shows you an approval card with the exact amount, and it stays inside the limits you set: by default CA$275 per purchase and CA$1,000 per month, with an approval asked for every purchase. Payments go through payment providers (Stripe Link or Crossmint, depending on the store) and the store; we keep the order record and receipt, not your card number.

Watching a task. A task can be watched live in the app, or through a web link that is protected by a signed token and expires within two hours. Anyone who has the link can watch that task until it expires.

2.14 Settings and choices we store

Your notification choices (push, rewards near you, mutes for deals, matches and reminders), agent permission choices (when the agent must ask before acting, which websites you allowed), spending limits, display currency, and your per-business consents and unsubscribes.

3. How We Use Your Information

• Operate the app and the assistant: find businesses, deals, rewards and events near you, and answer your messages
• Verify and pay reward claims, issue and redeem codes and tickets, and process the payments you choose to make in the app (Section 2.6a)
• Carry out shopping tasks you start, within the limits you set (Section 2.13)
• Match you with groups, activity partners and events you asked for
• Send the notifications and text messages described in Section 4
• Let businesses run campaigns and see how they perform, as described in Section 5
• Prevent fraud, multi-account abuse and location spoofing, and keep the platform safe
• Comply with legal obligations
• Evaluate and improve the service. Assistant conversations may be used, in de-identified form (your phone number is replaced with a one-way hashed identifier), to evaluate and improve the service — including automated AI review that labels exchanges and uses them as examples to improve how the assistant understands and routes requests. Deleting your account removes your conversations from this use (Section 9).

4. Text Messages (SMS / WhatsApp) & Consent

Messages you ask for. When you text or WhatsApp our number, we reply. Replies to your messages and the transactional messages you ask for — codes, receipts, ticket, booking and order updates, and alerts you request — do not need any further consent.

Optional consent for proactive messages. When you add your phone number in the app, an optional box, unticked by default, asks whether Lucilla's agent may text or WhatsApp you on its own initiative. For customers this covers deal alerts nearby, a heads-up when something you asked for shows up, reminders, and group matches, plus reward emails. For businesses it covers messages when nearby people want what you offer, reminders, group matches and useful finds such as new suppliers, partners and deals, plus emails. The box says: "Optional — not needed to use Lucilla or to buy anything. Automated messages; frequency varies. Msg & data rates may apply. Reply STOP to opt out, HELP for help." You can give the same consent at asklucilla.com/sms or by texting START. Leaving the box unticked never blocks replies to your own messages.

Message and data rates may apply. Message frequency varies. Reply STOP (also UNSUBSCRIBE, CANCEL, END or QUIT) at any time to opt out, HELP for help, or START to opt back in. You can also mute a single category (for example, reply STOP DEALS). Businesses you claim rewards from can also send you their offers; you agree to that separately for each business, when you claim (Section 5.2).

We record when and how you opted in (including the wording you agreed to) and when you opted out. After STOP, we send no further messages except a reply to an emergency message. Promotional messages are not sent between 9 p.m. and 8 a.m. in your local time (estimated from your phone number) and are limited to two in any 24 hours and five in any 7 days; replies to your own messages and transactional messages such as codes and confirmations are not subject to those limits. Over WhatsApp we can only message you within 24 hours of your last WhatsApp message; otherwise we use SMS. WhatsApp messages are delivered through Meta. The full program terms are in the SMS & WhatsApp Terms.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing with subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text-messaging opt-in data and consent; this information will not be shared with any third parties.

Your consent to receive text messages from Lucilla, and the mobile phone number you provide for that purpose, are never sold or rented and are not shared with third parties or affiliates for their own marketing. When you claim a business's reward, the contact details that business may receive come from your Lucilla account under the separate claim disclosure described in Section 5.2; they are not part of the SMS opt-in data or messaging consent described here.

The assistant is automated and is not an emergency service. If you describe an emergency, it replies with the local emergency number (and, in the US and Canada, the 988 crisis line where relevant), but it cannot send help or contact responders.

5. Data Sharing and Disclosure

5.1 What businesses see in the app

Inside Ask Lucilla, a business identifies its customers by their @username. For people who claimed its rewards, a business sees your username, city, the rewards you claimed, when you claimed them and the general area of the claim, and campaign statistics. It does not see your email address or phone number in the app. In addition:

• Event hosts see guests' names, photos and check-in status, and, for events that require approval, the name, age, gender, photo, "about" line, who vouched for the person, and answers to the host's questions.
• Staff who scan your code see the code and the reward it is for.
• Reviews, polls and survey answers you submit to meet a reward's requirements are provided to that business.

5.2 Claiming a reward: sharing with the business and its offers to you

Claiming a business's reward includes agreeing to hear from that business. This is a condition of claiming, and it is disclosed before you claim:

• Before your first claim, the app shows a disclosure with an Agree & Claim button. It explains that the business receives your @username, your contact details (name and email, and your phone number if you have added one) and the time and general area of your claim; that each business you claim from may send you its offers by email or text message; that businesses often keep their best rewards for customers who stay subscribed; that this is required to claim; and that you can unsubscribe from any business at any time.
• Every claim screen repeats this and names the specific business.
• What claiming records: that business's consent to contact you by email, and by text message only if your phone number is verified. It applies only to the business whose reward you claimed.
• Unsubscribing wins. If you have unsubscribed from a business, a later claim from that business never turns its messages back on.

How your contact details reach a business. In the app, a business sees you only as described in Section 5.1. Your name, email address and phone number are made available to a business only through Lucilla's enterprise business dashboard and emailed campaign reports, and only while that business holds your consent (email for your email address; text messages, with a verified phone number, for your phone number). If that business has connected its own customer-management (CRM) tool to Lucilla, such as GoHighLevel, and switched contact sharing on, the same details may also be sent to that tool, under the same consent and only while it lasts; unsubscribing from the business stops any further sending.

Unsubscribe anytime. You can unsubscribe from any business in the app under You → Businesses you hear from, or by replying STOP to a text. Unsubscribing stops that business's messages through Lucilla and stops further release of your contact details to it; it does not recall details the business already received. Businesses that receive your contact details must use them lawfully (including CAN-SPAM, TCPA, CASL, GDPR, CCPA and PIPEDA where applicable), only for communications about their own business, must honor unsubscribes, and may not sell or share them with unrelated third parties. If you do not want to hear from a business, do not claim its reward — you can still browse its offers.

5.3 Messages we pass between people

• Questions to a business: if you ask the assistant a question for a business, we text the owner your question as coming from "a customer near you." Neither side sees the other's phone number.
• Masked text threads (for example with a business, a gig, or an activity partner): each side texts Lucilla and we forward the message. Phone numbers are never shared; forwarded messages are logged. Threads close after 48 hours. Reply BLOCK to report and stop a thread.
• Matches: a match needs both people to say yes. If both of you have app accounts, each is told the other's @username and you can message in the app.
• Groups: in groups formed by text, members never see each other's numbers and the host sees only a member count. In app groups, other members see your name, photo, "about" line and whether you are bringing a guest — never your phone number or email.
• Community events: a private venue's exact address is shown only to people who join; others see an approximate location.

5.4 Service providers

We use service providers to run Ask Lucilla. They process data for us under their own terms and may not use it for their own purposes beyond what those terms allow. The full list, with what each one receives, is on the Service Providers page. In short:

• Google — Firebase (authentication, database, storage, messaging, analytics, crash reporting, App Check), Google Cloud (including Vertex AI Gemini models for understanding messages, voice notes, images and web pages, Cloud Text-to-Speech, Cloud Tasks, and the Cloud Run cloud browser), and Google Maps (maps and address lookup)
• Twilio — SMS, MMS and WhatsApp delivery
• Meta — WhatsApp messages, and Messenger and Instagram messages for businesses that connect them (Section 13)
• Circle — wallet infrastructure and network-fee sponsorship (Gas Station)
• Stripe — card payments for bookings and orders, processed for the business you pay, plan billing for businesses, Tap to Pay card readers, and Stripe Link for agent purchases
• Crossmint — card checkout for some purchases the shopping agent makes for you, only when you approve them
• Coinbase — buying and selling USDC (on-ramp and off-ramp), under Coinbase's own terms and privacy policy
• Resend — email delivery (receipts, codes, reports and notices). When a shop has connected its own Gmail, the customer emails it sends through Ask Lucilla (such as booking confirmations and dispute notices) go out from the shop's own Gmail address, using the send-only permission it granted, and not through Lucilla's sender. Without a connected Gmail they go out through Resend.
• Blockchain data services — to read your public on-chain transaction history

5.5 Public blockchain

USDC transfers, reward payouts, ticket escrow, USDC payments and campaign funding are recorded on the Base blockchain (or Arc, where you use it), which is public and permanent. Wallet addresses are pseudonymous, but anyone can see the transactions made by an address.

5.6 Legal requirements

We may disclose information when required by law, to respond to valid legal process, or to protect the rights, property and safety of Lucilla, our users or others.

5.7 Data ownership & sale

• We do not sell your personal data to any third parties
• We may analyze anonymized or aggregated usage patterns, including demand in an area, to improve our services
• In the future, we may engage in partnerships that involve sharing aggregated, anonymized data — we will notify users in advance and update this policy accordingly
• We do not use your data for third-party advertising without permission
• If we are involved in a merger, financing or sale of the business, personal information may be transferred to the new owner, which must honor this policy

6. Blockchain & Cryptocurrency Disclosures

6.1 USDC and your wallet

Your Ask Lucilla wallet is a non-custodial smart wallet that you create and control with a passkey on your device, using Circle's modular wallet infrastructure. We never receive your passkey and cannot move funds out of that wallet. That passkey wallet is the only wallet that is user-controlled. Some accounts also have a wallet that Lucilla manages through Circle on the person's behalf (shown as server-managed in the data download); our servers can move funds in such a wallet, and it is kept when an account is deleted so funds are not stranded. USDC moves on the Base blockchain (and Arc, if you choose it) between users' own wallets, businesses' wallets and Ask Lucilla smart contracts. We do not sell cryptocurrency; if you want to buy USDC, Coinbase sells it to you under its own terms, or you can bring USDC you already own. Ask Lucilla is not a money services business: it does not hold merchants' sales proceeds or the sales tax collected for them. Apart from the specific flows below, we do not hold, transmit or exchange customers' funds on their behalf:

• Escrow: USDC for reward campaigns and paid event tickets is held by Ask Lucilla smart contracts and released only under the rules in the Ask Lucilla Terms. Lucilla's servers submit claim, check-in, refund and settlement transactions. The contracts are upgradeable and administered by a multi-signature wallet controlled by Lucilla, whose administrative functions can recover tokens held by the contracts.
• Enterprise business wallets: businesses that use Lucilla's enterprise dashboard may have a Circle wallet that Lucilla manages on the business's behalf; Lucilla initiates transfers from it (for example to fund campaigns or pay prizes and cashback) under the business's instructions and enterprise arrangement.
• Lucilla-funded campaigns and payouts: Lucilla may fund a campaign from a wallet it operates, in which case unclaimed funds return to Lucilla. Some payouts — equal-split and draw-style distributions, and cashback sent when an escrow payout cannot be completed — are sent by Lucilla's servers from a Lucilla-operated wallet or the business's managed wallet.
• Network fees: each blockchain transaction has a small network fee. You pay it in USDC from your wallet, or Ask Lucilla sponsors it through Circle's Gas Station; the app shows which applies before you confirm.

USDC is a digital stablecoin pegged to the US Dollar, issued by Circle Internet Financial. USDC transactions are recorded on the Base blockchain (Ethereum Layer 2), a public ledger. We cannot modify blockchain data once recorded.

6.2 Cryptocurrency risks

• Peg risk: USDC is designed to maintain a 1:1 value with USD, but no guarantee exists that the peg will always be maintained
• Regulatory risk: cryptocurrency regulations vary by jurisdiction and may change. You are responsible for compliance with your local laws
• Irreversibility: blockchain transactions cannot be reversed once confirmed. Sending to a wrong address results in permanent loss
• Custody: you are responsible for safeguarding your device, passkey and recovery credentials
• Smart contract risk: smart contracts may contain bugs or vulnerabilities
• Network risk: blockchain networks may experience congestion, delays or outages

6.3 Not financial advice

Lucilla does not provide investment, financial, tax or legal advice.

7. Children's Privacy & Age-Based Access

Ask Lucilla is for adults. You must be 18 or older to create an account or use the Service. It is not directed to children, and we do not knowingly collect personal information from anyone under 18. If we learn a user is under 18, we will delete the account and associated data.

In-person matching with other people is limited to adults (18+). Event hosts may set a higher minimum age for their events, and businesses must verify age at the point of service where the law requires it.

8. Security

Lucilla runs on Google Cloud and Firebase and uses Circle for wallets; these providers maintain independent security certifications such as SOC 2 and ISO 27001. Data is encrypted in transit (TLS) and at rest by these providers. Access tokens for linked services are stored encrypted. Access to production systems is restricted and logged. We also use secure sign-in (Google, Apple, email with phone verification), app-integrity checks, rate limits, and device biometric confirmation for wallet transfers. No system is perfectly secure; if a breach affects your personal information in a way that creates a real risk of significant harm, we will notify you and the regulators as the law requires.

9. Data Retention & Deletion

We keep personal data as long as necessary to provide the service, comply with legal obligations, resolve disputes and enforce agreements. A schedule of what is kept and for how long is on the Retention & Deletion page. Our policy is to blank the text of assistant conversations and text-message logs 24 months after it was written, leaving only a record that a message existed and when; that automatic cleanup is being rolled out in stages, and until it has run over a message the text is kept until you delete your account. In-app voice notes are deleted right after transcription. Some data has no automatic expiry yet and stays until you or the business deletes it: shopping-agent task history, and conversations a business receives through Messenger, Instagram or WhatsApp.

9.1 Deleting your account

You can delete your Lucilla account in the app under You → Delete account, or request it at asklucilla.com/legal/rewards/delete-account. We email you a link to confirm that the request is yours; once you confirm, your account enters a 30-day grace period (you can cancel during it) and is then deleted. You can also ask us to delete specific categories of data (messages, claims, orders, business listings, wallet link, device identifiers) at asklucilla.com/delete-data. Your Ask Lucilla account is separate from any Lucilla fitness app account, so deleting one does not delete the other. You can also ask us to delete your data by writing to support@asklucilla.com.

Deleting your account removes:

• your account, profile, login, and the data and files stored under your account;
• your conversations with the Lucilla assistant in the app and by SMS/WhatsApp, including message logs, session data, and demand and wishlist records;
• voice notes and voice-conversation audio, and photos and other media you texted us;
• assistant memory;
• shopping-agent tasks, saved cloud sign-ins and your delivery address;
• leads and marketing-consent records held for businesses whose rewards you claimed;
• reward claims that did not pay out USDC, posts, chats and notifications.

What we keep: transaction and other records that applicable law requires us to keep — such as your wallet address(es), USDC transactions, reward claims that paid out USDC, and the identifying details linked to them — are moved to a locked retention store for as long as the law requires and then deleted. On-chain transaction records are public and permanent. You can also delete assistant memory at any time by texting FORGET, and stop all Lucilla texts by replying STOP.

10. Your Rights & Choices

You have the right to:

• Access: request a copy of your personal data
• Correction: update inaccurate information
• Deletion: delete your account and associated data (Section 9)
• Data portability: get your data in a common, machine-readable format
• Opt-out: disable location or notifications in device settings, reply STOP to texts, and unsubscribe from any business under You → Businesses you hear from (Section 5.2)

How to get a copy of your data. In the app, open Settings → Download my data. You get one private file with your own data (profile, conversations, text messages, claims, orders, shops you own and wallet addresses). It leaves out passwords, tokens, secrets and screenshots, and shows connected tools only as connected or not. The download link works for 24 hours, the file is deleted 48 hours after it is made, and you can make one export per hour. The file also lists wallets that Lucilla manages for you, marked as server-managed. You can also write to support@asklucilla.com.

10.1 California residents (CCPA/CPRA)

• Right to Know: you can request details about the categories and specific pieces of personal information we have collected about you
• Right to Delete: you can request deletion of your personal information, subject to certain legal exceptions
• Right to Opt-Out of Sale or Sharing: we do not sell your personal information and do not share it for cross-context behavioral advertising. If this changes, we will provide a "Do Not Sell or Share My Personal Information" mechanism
• Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights
• Right to Correct: you can request correction of inaccurate personal information
• Right to Limit Use of Sensitive Personal Information: you can limit how we use sensitive personal information (such as precise geolocation) to purposes necessary for providing services

To exercise these rights, contact us at support@asklucilla.com. We will respond within 45 days.

10.2 European users (GDPR)

Ask Lucilla is offered in Canada and the United States and is not directed at people in the EEA, the UK or Switzerland. If you are located there anyway, you have the rights of access, rectification, erasure, restriction of processing, data portability, objection (including to direct marketing) and withdrawal of consent, and you can use them by contacting support@asklucilla.com.

Legal bases for processing: contract (to provide the service), legal obligation (record-keeping), legitimate interest (fraud prevention, evaluating and improving the service with de-identified conversations, platform security), consent (location, microphone and text messages), and contract and consent for the business offers you agree to receive when you claim a reward (Section 5.2), which you can withdraw at any time.

10.3 Canadian users (PIPEDA and provincial laws)

Canadian users have rights under the Personal Information Protection and Electronic Documents Act and, where they apply, provincial privacy laws, including the right to access, correct, and withdraw consent for the collection and use of personal information, and to complain to the Office of the Privacy Commissioner of Canada. We rely on your consent for the collection, use and disclosure described in this policy, and you can withdraw it (for example by deleting your account), subject to legal and contractual limits.

10.4 Other jurisdictions

Residents of Virginia, Colorado, Connecticut, Nevada, and other states with consumer privacy laws have rights similar to those described above under their respective state laws. Contact us to exercise these rights.

11. International Users

Your data may be transferred to and processed in countries outside your residence, primarily the United States and Canada. Our primary data region is the United States (Google Cloud us-east1). We ensure appropriate safeguards are in place for international transfers, including standard contractual clauses where required.

12. User-Generated Content & Moderation

Ask Lucilla includes content from users and businesses: reviews, event and store chats, group messages, business listings and reward cards. When you report content or a person in the app, block or unblock someone, or reply BLOCK in a masked text thread, we record your account ID, what you reported or blocked, the reason and the time. Appeals for moderation decisions may be sent to social@lucilla.ca.

13. Connected Services You Link (Google, Meta, Stores, Marketing, Bookings, Accounting)

Business owners can link third-party services to their Ask Lucilla business account so that a listing, menu, calendar or inbox stays in step with the tools they already use. Each link is created by the owner through that provider's own sign-in (OAuth) or install flow and can be removed at any time from the Connectors screen or from the provider's own account settings. We store the access tokens that the provider issues, encrypted, and use them only for the features described below. Which services are available at a given time is shown in the Connectors screen; a service marked "coming soon" is not active, and nothing is collected from it until you link it.

13.1 Google services

When an owner links Google Calendar, we read free/busy times and write bookings into the calendar the owner chooses; customers never see calendar contents, only availability. When an owner links Google Sheets, Google Docs or Google Drive, we read only the specific files the owner picks (or pastes a link to) in order to import a menu, price list, supplier order guide or listing photos; we do not scan the owner's Drive. When a business links its YouTube channel we read public video listings only. When an owner links Google Shopping (Google Merchant Center), we send that business's product listings, prices and stock to Google so they can appear in Google's free product listings, and we read the status Google returns for them. Ask Lucilla's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements: Google user data is used only to provide the feature the owner asked for, is never sold, is never used for advertising, and is never read by a human except with the owner's consent, for security purposes, or as required by law.

13.2 Meta services (Facebook Messenger, Instagram, WhatsApp Business)

When an owner links a Facebook Page, an Instagram professional account or a WhatsApp Business number, messages that customers send to that business are delivered to the Ask Lucilla assistant so the business can answer them by text, and replies are sent back through Meta. We store message content and sender identifiers for that business only as long as needed to run the conversation and the business's order or booking records. We do not post to a business's page or send marketing messages unless the owner asks for it in the assistant. Data received from Meta is handled under Meta's Platform Terms in addition to this policy.

13.3 Point-of-sale, online-store and accounting services

When an owner links Square, Clover, Lightspeed, Shopify, WooCommerce, Toast, Squarespace, Wix, BigCommerce, Etsy, eBay, QuickBooks or Xero, we read the catalogue, inventory, hours and order or sales records needed to keep the listing accurate, to record customer orders in the business's own system, and to summarise sales back to the owner. For an online shop, we may also create a discount code or payment link in the shop's own checkout so a customer's Ask Lucilla deal applies there; the customer pays the shop directly. For Etsy, eBay, Squarespace, BigCommerce, TikTok Shop and the other online marketplaces and stores, we read listings and order totals, order numbers, item names and quantities only. We do not read your customers' names, email addresses, phone numbers, shipping addresses or messages from those orders, and we never write to the marketplace or store account from the order records. We never move money inside those systems and never store card numbers from them.

13.4 Messenger, Instagram and WhatsApp Business messages: the details

This section adds detail to Section 13.2 for businesses that connect a Facebook Page (Messenger), an Instagram professional account or a WhatsApp Business number, and for the people who message those businesses.

• What we receive. The messages a customer sends to the connected business account and the replies sent from it through Ask Lucilla; the sender identifiers Meta provides for that conversation (a page-scoped or Instagram-scoped ID, or the WhatsApp phone number, and a display name where Meta supplies one); message timestamps and delivery or read status; and metadata about attachments (such as type, size and the link Meta provides), plus the attachment itself where it is needed to answer the message, for example a photo of an item the customer asks about.
• Why. Only to let the business answer its own customers, who message that business first. We reply only inside the window Meta allows (within 24 hours of the customer's last message), and we do not use these conversations to message people who have not contacted the business.
• Where it is stored. On Google Cloud and Firebase, in the United States (us-east1 region), encrypted in transit and at rest (Section 8).
• How long we keep it. Our policy is to blank message text 24 months after it was received, leaving only a record that it existed and when; that cleanup is being rolled out in stages, and until it has run, messages and sender identifiers are kept until the business deletes them or disconnects the account and asks us to delete them, or until the person who sent them requests deletion — including by requesting account deletion at asklucilla.com/legal/rewards/delete-account or by writing to support@asklucilla.com.
• No sale. We do not sell this data, rent it, or use it for advertising, and we do not share it with other businesses. The connected business can see its own conversations; Meta processes the messages under its own terms because they travel through Meta's platforms.

13.5 Email, marketing, booking and social services

• Mailchimp. When an owner links Mailchimp, we send its audience only the email address of customers who have given that business their email-marketing consent (Section 5.2) — never a phone number — and we create campaign drafts for the owner to review; nothing is sent until the owner approves it. If a customer withdraws consent, they are removed from the audience, and a customer who unsubscribes in Mailchimp stays unsubscribed.
• Klaviyo. When an owner links Klaviyo, Ask Lucilla sends campaigns to the owner's own Klaviyo list. Klaviyo keeps the consent and the unsubscribe; Ask Lucilla never creates, imports or subscribes a profile in Klaviyo.
• Calendly and other booking tools. When an owner links Calendly, we read the event types the owner publishes (they become bookable services) and the scheduled events and their status. We do not read the invitee's name, email, phone or answers; the owner sees those in Calendly itself. For Vagaro, Mindbody and Outlook Calendar we read the services and availability the owner publishes and record bookings so they appear on the owner's calendar.
• Pinterest and other posting tools. When an owner links a social account, we post only what the owner has previewed and approved.
• Canva, Zapier, Monid and similar tools. These run only when the owner asks. Zapier passes the events the owner chooses to the owner's own automations; Monid lets the owner's agent run pay-per-use data tools from the owner's own Monid balance.
• Amazon Business. When an owner links its own Amazon Business account, the agent can search supplies, show prices and read recent order history (buyer names and emails in that history are dropped). It cannot place an order unless the owner has separately enabled ordering and then approves each order after a preview.

13.6 Email and SMS invitations for staff

A business owner or manager can invite staff to help run the business account. To do that, the owner enters the staff member's email address or mobile number, and we send an invitation by email or SMS with a link to join (asklucilla.com/join); we send it again only if the owner re-sends it. Invitations expire after 14 days, and the link only works for someone who signs in with the same phone number or email the invitation was sent to. We store the address or number, the role offered, who sent the invitation and whether it was accepted, declined or expired, so the owner can see and cancel pending invitations. We use this contact only for the invitation and the staff account it creates; it is not added to marketing lists and is not sold. The invited person can decline the invitation, and can ask us to delete their details at support@asklucilla.com.

13.7 Removing a link

Unlinking a service stops us reading from it and deletes the stored access token. Content already imported into the listing stays until the owner removes it. Linked-service data is deleted when the business deletes its account (Section 9).

14. AI: the Assistant and the Agents You Connect

The assistant. Ask Lucilla's own assistant runs on Google's Gemini models through Google Cloud Vertex AI. We do not send your conversations to any other AI company. The assistant only takes actions with a consequence (claiming, ordering, paying, changing a listing) after you confirm, and money actions also respect the spending limits you set. Automated fraud and location-spoofing checks may reject a claim; you can contact us to have a rejection reviewed by a person.

AI agents you connect. You can let an AI assistant you already use (for example Claude, ChatGPT or Meta AI / Muse) act on your Ask Lucilla account through our agent connection (an MCP server). You approve that connection yourself, on our sign-in page, and choose what the agent may do: read deals, claim deals, read or update your shop, place orders, or spend from your wallet. Every permission is a separate choice and can be revoked at any time from your account or by disconnecting the agent. Actions with a consequence (claiming, ordering, paying, changing a listing) always ask for confirmation first, and the highest-risk ones — paying a shop, raising the spending limit, approving an agent purchase, refunds — also need your own approval in the app or by replying YES from your own phone, so a connected AI cannot approve them on its own. When an agent acts, we receive the request from the agent provider together with the identity of the connected account; we do not receive your other conversations with that agent, and we do not share your Ask Lucilla data with the agent provider beyond the answer to the specific request. The agent provider's own privacy policy governs what it does with what it shows you.

15. Website, Cookies and Analytics

The asklucilla.com website asks before it uses anything that is not strictly necessary. Google Analytics 4 runs only if you choose "Accept all" or switch Analytics on; until then it is not loaded, and nothing is sent to Google for analytics or stored for it. If you decline, or your browser sends a Global Privacy Control or Do Not Track signal, analytics stay off. Your choice is kept in a first-party cookie for 180 days, and you can change it any time from "Cookie settings" in the footer. We use no advertising cookies, do not sell data and do not show ads. Necessary storage (sign-in, security checks, your choice, and a few items that make forms and pages work) does not need consent. The staff-invitation page uses Google reCAPTCHA, which may set its own cookies on that page. The Cookie Notice lists every cookie and storage item. The app does not use web cookies.

16. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of significant changes via email or in-app notification. Continued use after changes constitutes acceptance.

17. Contact Us

For questions about this Privacy Policy, GDPR / PIPEDA / CCPA rights requests, and data-deletion requests:

• Email: support@asklucilla.com
• Website: asklucilla.com/legal/rewards
• Legal notices: Lucilla, Inc. (a Delaware corporation), c/o its affiliate 16699448 Canada Corporation, attention Sebastian Borjas, s.borjas@asklucilla.com, at the mailing address below
• Mailing address: Lucilla, Inc., c/o 16699448 Canada Corporation, 145 1/2 Church Street, Unit 5, Office 52, Toronto, Ontario M5B 1Y4, Canada. This is a mailing address for legal notices and mail only. It is not a shopfront and we do not meet visitors there.

For abuse reports, moderation and support: social@lucilla.ca.