Privacy Policy
Effective date — December 01, 2023
Last updated 
— November 14, 2024

We do not place cookies on your device unless you sign up for a paid Service. Even then, the cookies used are for authentication, only. This allows you to bypass the "login" screen when you return to our sites.

We use Plausible Analytics to track page views, referral sources, and country-level location, for all visitors to our sites. Plausible Analytics does not track individuals and is fully GDPR-compliant. If you sign up for a Service from us, we collect several different types of information for various purposes to provide and improve our Service to you. Types of data collected:

  • “Service” refers to a paid membership accessed through https://www.nuluca.com or https://pavilion.nuluca.com;
  • "Personal Data" means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession);
  • “Usage Data” is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit);
  • “Cookies” are small files stored on your device (computer or mobile device);
  • "Data Controller" means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed; for the purpose of this Privacy Policy, we are a Data Controller of your Personal Data;
  • "Data Processor" (or "Service Provider") means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
  • "Data Subject" (or "User") is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you. Types of data collected:

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
  • Email address
  • First and last name
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data
We may use your Personal Data to contact you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Use of Data

nuLUCA co. uses the collected data for various purposes:
  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), nuLUCA's legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

nuLUCA may process your Personal Data because:
  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it is not overridden by your rights
  • For payment processing purposes
  • To comply with the law
Retention of Data

nuLUCA will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

nuLUCA will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

nuLUCA will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If nuLUCA is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, nuLUCA may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

nuLUCA may disclose your Personal Data in the good faith belief that such action is necessary to:
  • Comply with a legal obligation
  • Protect and defend the rights or property of nuLUCA
  • Prevent or investigate possible wrong doing in connection with the Service
  • Protect the personal safety of users of the Service or the public
  • Protect against legal liability