We provide economic infrastructure for the internet. Businesses of all sizes can our software and services to accept payments and manage their businesses online. Lucid cares about the security and privacy of the personal data that is entrusted to us.
“Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP address).
“Services” means the products and services that Lucid indicates are covered by this Policy, which may include Lucid-provided apps. Our “Business Services” are Services provided by Lucid to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services which Lucid directs to individuals (rather than entities) so that those individuals do business directly with Lucid. “Sites” means Lucid.Money and the other websites that Lucid indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.
Depending on the context, “you” means End Customer, End User, Representative or Visitor:
When you directly use an End User Service (such as when you sign up for an eWallet, or make a payment to Lucid in your personal capacity), for your personal use, we refer to you as an “End User.”
When you do business with, or otherwise transact with, a Business User (typically a merchant using the Lucid eWallet, e.g. when you buy a pair of shoes from a merchant that uses Lucid for payment processing) but are not directly doing business with Lucid, we refer to you as an “End Customer.”
When you are acting on behalf of an existing or potential Business User (e.g. you are a founder of a company, or administering an account for a merchant who is a Business User), we refer to you as a “Representative.”
When you visit a Site without being logged into a Lucid account or otherwise communicate with Lucid, we refer to you as a “Visitor.” (e.g. you send Lucid a message asking for more information because you are considering being a user of our products).
Depending on the activity, Lucid acts as a “data controller” or “data processor” and for more information about this and on the Lucid entity that is responsible under this Policy, please refer to our website.
1. Personal data that we collect and how we use and share it
1.1 End Users
We provide End User Services where we do not act as a service provider to Businesses but instead provide the Services directly to you for your personal use (e.g. Lucid eWallet user).
Using Link or Connecting your Bank Account. Lucid offers you the opportunity to store your payment methods with Lucid so that you can conveniently use it across merchants who are our Business Users – we call this “link”. When you opt in to the link, you agree to let us store your payment method so that you can more readily make purchases through the link with Business Users of our payment processing Business Services (e.g. name, card number, cvc, and expiration date). When you choose to pay with the link, we will also collect your Transaction Data.
If you choose to share bank account information (including for using the link) with us, Lucid will periodically collect and process your bank account information (e.g. account owner information, account balances, account number and details, account transactions and in some cases, credentials) until you ask us to disconnect your bank account.
Paying Lucid. If you are buying goods or services directly from Lucid, we receive Transaction Data. For example, when you make a payment to Lucid, we will collect contact information, payment method information, information about that transaction and in some cases, shipping information.
Other Services. We may offer other End User Services directly to you from time to time, including certain financial Services. For information about our collection and use of Personal Data.
More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.
How we use and share personal data of End Users
Services. We use your Personal Data to provide the End User Service to you, including security, delivery, support, personalization and messages related to the End User Service (e.g. communicating Policy updates and information about our Services). We also use your Personal Data for our fraud detection and mitigation Business Services and may share certain Personal Data as part of those Business Services with Business Users that you may seek to do business with. The use of this Personal Data is subject to the Business Users’ privacy policies.
Our Business Users. When you choose to connect your bank account with Lucid, you may also choose to share account information with certain Business Users that you do business with. These Business Users will have their own privacy policies which describe how they use that information.
Fraud Detection Services. We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction.
More. Please see below for more information about additional ways in which we may use and share your Personal Data.
1.2 End Customers
a. Personal data that we collect about End Customers
Transaction Data. If you are an End Customer, when you make payments to, get refunds from, begin a purchase, make a donation or otherwise transact with a Business User that uses us to provide payment processing Business Services, we will receive transaction data. The “Transaction Data” that we collect includes Personal Data, and may include the following: your name, email address, billing address, shipping address, payment method information (such as credit or debit card number, bank account information or payment card image selected by you), merchant and location, purchase amount, date of purchase, and in some cases, some information about what you have purchased and your phone number. We may also receive your transaction history with the Business User. We may collect information typed into a checkout form, even if you choose not to complete the form or purchase with the Business User. Identity/Verification Information. Lucid provides a verification and fraud Service that allows a Business User to verify Personal Data about you, such as your age (when purchasing age restricted goods) or your authorization to use a payment method. You will be asked to share Personal Data and we will collect the information that you share for this purpose, such as your government ID, your image, and Personal Data you input or that is apparent from the physical payment method (e.g. credit card image). We may compare this information with information about you we collect from Business Users, financial partners, business partners, identity verification services, publicly available sources, and third party service providers. More. Please see below for information about additional types of Personal Data that we may collect, including about online activity.
b. How we use and share personal data of End Customers
We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Lucid’s own purposes to secure, improve and provide our Business Services, as described below.
Payments. We use your Transaction Data to provide our Payments related Business Services to Business Users, including to process online payment transactions, to calculate applicable sales tax, to invoice and bill, and to calculate their revenue. We may also use Personal Data to provide and improve our Business Services.
Other Financial Services. Some of our Business Users use our Services in order to offer financial services to you, through Lucid or its financial partners. For example, they may provide a card product that enables you to purchase goods and services. These cards may carry the Lucid brand, bank partner brand and/or the brands of Business Users. In addition to any Transaction Data we may produce or receive when these cards are used for purchases, we will also receive and use your Personal Data in order to provide and manage these products. Please also see the privacy policies of the Business User and our bank partner, if applicable, associated with the financial service (whose brands may be shown on the card).
Identity/Verification Services. We use Personal Data about your identity, including information provided by you and our service providers, to perform verification Services for Lucid or for the Business Users that you are doing business with and to reduce fraud and enhance security. If you provide a “selfie” along with an image of your identity document, we will use technology to compare and calculate whether they match and you can be verified.
Fraud Detection Services. We use your Personal Data collected across our Services to detect and prevent fraud against us, our Business Users and financial partners, including to detect unauthorized log-ins using your online activity. We may provide Business Users (including card issuers and others involved in payment processing activities) that have requested our fraud Business Services with Personal Data about you (including your attempted transactions) so that they can assess the associated fraud risk with a transaction. You can learn more about how we may use technology to assess the fraud risk associated with an attempted transaction and what information we may share with Business Users about such risks on our website.
More. Please see below further information about additional ways in which we may use your Personal Data.
To provide Business Services, we collect, use and share Personal Information from Representatives of our Business Users (e.g. a business owner). If the Representative is the only employee of a Business User, please see the End User and End Customer sections to understand additional ways in which we can collect and use your Personal Data when you use our Services. See our website for further information on the legal bases which we rely on for using (processing) your Personal Data.
a. Personal data that we collect about Representatives
Registration and Contact Information. If you register for a Lucid account for a Business User (including incorporation of a Business), we collect your name and account log-in credentials. If you register for an event that Lucid organizes or attends or if you sign up for Lucid communications, we collect your registration and profile information. If you are a Representative of a potential Business User, we receive your Personal Data from third parties (including data providers) in order to advertise to, market and communicate with you as described further below and in Section 2.
Identification Information. If you are an owner of a Business User or you are expected to be a shareholder, officer or director of a Business User, we require that you provide your contact details, such as name, postal address, telephone number, and email address to fulfill our financial partner and regulatory requirements. We may also collect financial and personal information about you, such as your ownership interest in the Business User, your date of birth and government identifiers associated with you and your Business User (such as your national registration or identity number, tax number, or Employer Identification Number). You may also choose to provide bank account information.
More. Please see below for more information about additional types of Personal Data that we may collect, including about online activity.
b. How we use and share personal data of Representatives
We generally use Personal Data of Representatives to provide the Business Services to the associated Business Users, as well as for the purposes described below.
Business Services. We use and share Personal Data of Representatives with Business Users to provide the Services. For users of our tax Business Services, we may use your Personal Data to file taxes on behalf of your associated Business User. We may also use your Personal Data to submit forms to the tax office on your behalf and to file documents with other governmental authorities (e.g. articles of incorporation in your state of incorporation).
More. Please see below for more information about additional ways in which we may use and share your Personal Data.
1.4 Visitors (e.g. visitors to Lucid sites who are not an End User, End Customer or Representative)
See here for further information on the legal bases which we rely on for using (processing) your Personal Data.
a. Visitor personal data that we collect
Forms. When you choose to fill in a form on the Site or on third party websites featuring our advertising (e.g. LinkedIn or Facebook), we will collect the information included in the form, usually your contact information and other information about your question related to our Services.
More. Please see below for more information about additional types of Personal Data that we may collect, including about online activity.
b. How we use and share visitor personal data
Personalization. We use information about you that we gather from cookies and similar technologies to measure engagement with the content on the Sites, to improve relevancy and navigation, to personalize your experience and to tailor content about Lucid and our Services to you.
More. Please see below for more information about additional ways in which we may use your Personal Data.
2. More ways we collect, use and share personal data
In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows.
a. Personal Data Collection
Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
Devices and browsers across our Sites and third-party websites, apps and other online services (“Third-Party Sites”),
Usage data associated with those devices and browsers, including IP address, plug-ins, language used, time spent on Sites and Third-Party Sites, pages visited, links clicked, and the pages that led or referred you to Sites and Third-Party Sites. For example, activity indicators, like mouse activity indicators, help us detect fraud.
Communication and Engagement Information. We will collect any information you choose to provide to us, for example, through support tickets, emails or social media. When you respond to Lucid emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Lucid, as well as other information you may provide during the call. We will also collect your engagement data such as your registration for, attendance of, or viewing of Lucid events and other interaction with Lucid personnel.
Forums and Discussion Groups. Where our Sites allow you to post content, we will collect Personal Data that you provide in connection with the post.
b. Personal Data Usage. In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways:
Communications. We will use the contact information we have about you to perform the Services, which may include sending codes via SMS to authenticate you. If you are an End User, Representative or Visitor, we may communicate with you using the contact information we have about you (e.g. using email, phone, text message or videoconference) to provide information about our Services and our affiliates’ services, invite you to participate in our events or surveys, or otherwise communicate with you for our marketing purposes, provided that we do so in accordance with applicable law, including any consent or opt-out requirements. For example, when you submit your contact information to us or when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and include you on our marketing information campaigns.
Social Media and Promotions. If you choose to submit Personal Data to us to participate in an offer, program or promotion, we will use the Personal Data you submit to administer the offer, program or promotion. Based on your permission or opt-out, we will also use that Personal Data and Personal Data you make available on social media to market to you.
Fraud Prevention and Security. We collect and use Personal Data to help us to detect and manage the activity of fraudulent and other bad actors across our Services, to enable our fraud detection Business Services, and to otherwise seek to secure our Services and transactions against unauthorized access, use, modification or misappropriation of Personal Data, information and funds. In connection with fraud and security monitoring, prevention, detection, and compliance activities for Lucid and its Business Users, we receive information from service providers (including credit bureaus), third parties, and the Services we provide. We may collect information from you, and about you, from Business Users, financial parties and in some cases third parties. For example, to protect our Services, we may receive information from third parties about IP addresses that malicious actors have compromised. Learn More. This Personal Data (e.g. name, address, phone number, country) helps us to confirm identities, run credit checks subject to applicable law and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by an End Customer or End User with a Business User or financial partner.
Compliance with Legal Obligations. We use Personal Data to meet our contractual and legal obligations related to anti-money laundering, Know-Your-Customer ("KYC") laws, anti-terrorism, export control and prohibitions on doing business with restricted persons or in certain business areas, and other legal obligations. We strive to make our Services safe, secure and compliant, and the collection and use of Personal Data is critical to this effort. For example, we may monitor patterns of payment transactions and other online signals and use those insights to reduce the risk of fraud, money laundering and other activity that is harmful to Lucid, our End Users and their End Customers.
Minors. The Services are not directed to minors, including children under the age of 13, and we request that they do not provide Personal Data through the Services. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of End Customers, Representatives, Visitors or End Users, including those aged between 13 to 16.
c. Personal Data Sharing. In addition to the ways described above, we share Personal Data in the following ways:
Lucid Affiliates. We share Personal Data with other Lucid affiliated entities. When we share with these entities, it is for purposes identified in this Policy.
Service Providers or Processors. In order to provide Services to our Business Users and End Users and to communicate, market and advertise to Visitors, Representatives and End Users regarding our Services, we will rely on others to provide us services. Service providers (provide a variety of critical services, such as hosting (storing and delivering), analytics to assess the speed, accuracy and/or security of our Services, identity verification, customer service, email and auditing. We authorize such service providers to use or disclose the Personal Data of our Users that we make available to perform services on our behalf and to comply with applicable legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United Kingdom.
Financial Partners. “Financial Partners” are financial institutions that we partner with to offer the Services (including payment method acquirers, banks and payout providers). We share Personal Data of our Users with certain Financial Partners to provide the Services to the associated Business Users and to offer certain Services in partnership with our Financial Partners. For example, we share certain Personal Data of Representatives (e.g. loan repayment data and contact information) with institutional investors who purchase the Capital loans that we have made to the associated Business Users.
Others with Consent. In some cases we may not provide a service, but instead refer you to, or enable you to engage with, others to get services. In these cases, we will disclose the identity of the third party and the information that will be shared with them, and seek your consent to share the information.
Corporate Transactions. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Policy.
Compliance and Harm Prevention. We share Personal Data as we believe necessary: (i) to comply with applicable law, (ii) to comply with rules imposed by payment method in connection with use of that payment method (e.g. network rules for Visa); (iii) to enforce our contractual rights; (iv) to secure or protect the Services, rights, privacy, safety and property of Lucid, you or others, including against other malicious or fraudulent activity and security incidents; and (v) to respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
3. Legal bases for processing data
For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data.
a. Contractual and Pre-Contractual Business Relationships. We process Personal Data for the purpose of entering into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include:
Creation and management of Lucid accounts and Lucid account credentials, including the evaluation of applications to commence or expand the use of our Services;
Creation and management of Lucid Checkout accounts;
Accounting, auditing, and billing activities; and
Processing of payments, including fraud detection and prevention, optimizing valid transactions, communications regarding such payments, and related customer service.
b. Legal Compliance. We process Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
c. Legitimate Business Interests. Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:
Detect, monitor and prevent fraud and unauthorized payment transactions;
Mitigate financial loss, claims, liabilities or other harm to End Customers, End Users, Business Users and Lucid;
Determine eligibility for and offer new Lucid products and services;
Respond to enquiries, send Service notices and provide customer support;
Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
Analyze and advertise our Services;
Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
Enable network and information security throughout Lucid and our Services; and
Share Personal Data among our affiliates.
d. Consent. We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services like our link and Lucid.Money apps. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.
4. Your rights and choices
You may have choices regarding our collection, use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or as described on our website. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.
b. Your data protection rights
Depending on your location and subject to applicable law, you may have the following rights described on our website with regard to the Personal Data we control about you:
The right to request confirmation of whether Lucid processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
The right to request that Lucid rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
The right to request that Lucid erase your Personal Data in certain circumstances provided by law;
The right to request that Lucid restrict the use of your Personal Data in certain circumstances, such as while Lucid considers another request that you have submitted (including a request that Lucid make an update to your Personal Data);
The right to request that we export your Personal Data that we hold to another company, where technically feasible;
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
Where we process your information based on our legitimate interests, you may also have the right to object to the processing of your Personal Data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
c. Process for exercising your data protection rights
5. Security and retention
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that your interaction with us is no longer secure (e.g. you feel that the security of your account has been compromised), please contact us immediately.
We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with which you are doing business, and even if you close your Lucid account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to allow for fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
6. International data transfers
We are an international business. Personal Data may be stored and processed in any country where we do business, where our service providers do business or if you use an international payment method or financial partner service, the countries in which that payment method or financial partner operates. We may transfer your Personal Data to countries other than your own country. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities).
If you are located in the European Economic Area (“EEA”), the "United Kingdom ("UK")" or Switzerland, please see the specific Privacy issues on our website for more information. Where applicable law requires a data transfer mechanism, we use one or more of the following: EU Standard Contractual Clauses with a data recipient outside the EEA, Switzerland or the UK, verification that the recipient has implemented Binding Corporate Rules, or other legal methods available to us under applicable law. For transfers to third countries we have entered into Standard Contractual Clauses, approved by the European Commission, to ensure an adequate level of protection for the transfer of your Personal Data to those entities outside the EEA. You can obtain a copy of the relevant Standard Contractual Clauses.
While Lucid Inc. remains self-certified under the E.U.-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield, it is not currently relying on these frameworks for the transfer of personal data to the U.S.
7. Updates and notifications
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Services.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Lucid Dashboard, email address and/or the physical address listed in your Lucid account.
If applicable law requires that we provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.
8. Jurisdiction-specific provisions
EEA and UK. To exercise your rights, you may contact our Data Privacy Officer. If you are a resident of the EEA or we have identified Lucid as your data controller, and believe we process your information within the scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the appropriate Data Protection Commission. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office. Where Personal Data is used for regulated financial activities in Europe, Lucid Payments Europe Limited and Lucid local regulated entities (defined as those who are licensed, authorized or registered by a Local Regulatory Authority) are considered joint controllers.
9. Contact us