Privacy Policy

Effective Date: December 5, 2025
Controller: FO&WO VENTURES SP. Z O.O.

This Privacy Policy describes the policies and procedures of FO&WO VENTURES SP. Z O.O. ("Company", "we", "us") on the collection, use, and disclosure of your information when you use the Lustra AI platform (the "Service").

1. Data Controller

The Data Controller for the Service is FO&WO VENTURES SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, located at ul. Wapienna 13/7, 50-518 Wrocław, Poland (NIP: 6343002817). Inquiries regarding data protection can be directed to: jacek@lustra.dev.

2. Data Collection and Usage

We collect data necessary to operate our AI infrastructure and personalize your experience. This includes:

Account Data: Email address and a unique user identifier (UID) generated via Google Firebase Authentication. Used for secure login and account management.
Civic Engagement Metrics:
- Poll Votes: We store your interactions (support/oppose) to calculate aggregate sentiment for the Civic Algorithm. While linked to your UID for integrity, this data is displayed publicly only in anonymized, aggregated form.
- Followed Legislation: Data on bills you track is stored to provide personalized updates.
Grassroots Legislation Data: Content you voluntarily submit (e.g., bill proposals) is processed by our AI and may be displayed publicly within the Service.
System Logs: Error reports and performance metrics used to maintain system stability.

3. Third-Party Processors & AI Infrastructure

We utilize enterprise-grade cloud infrastructure to ensure security and scalability:

Google Cloud Platform (Firebase): Used for database hosting (Firestore), authentication, and backend logic. Data is stored within the European Economic Area (EEA).
LLM Providers (Google Gemini): Used for "Context Sterilization" of legislative texts. Note: We transmit only public legislative documents to our AI models. User personal data (PII) is never shared with LLM providers for processing.

4. Data Retention

We retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. Upon account deletion, your personal data is permanently removed from our active databases.

5. Communications

Users may opt-in to receive product updates, beta invitations, and ecosystem news ("Beta Program"). You may opt-out of receiving these communications at any time via the app settings.

6. Your GDPR Rights

Under the General Data Protection Regulation (GDPR), you have the right to:

Access, update, or delete the information we have on you.
Rectify incomplete or inaccurate information.
Object to the processing of your data.
Request data portability.
Withdraw consent at any time.

To exercise these rights, please contact us at jacek@lustra.dev.

7. Account & Data Deletion

We provide an automated mechanism for users to exercise their right to be forgotten.

To delete your account and all associated data:

Open the Lustra mobile application.
Navigate to the "Settings" tab.
Tap on "Delete Account".
Confirm the action. This process is irreversible and will erase all your personal data immediately.

8. Security

The security of your data is important to us. We implement industry-standard security measures, including encryption in transit and at rest, provided by the Google Cloud Platform infrastructure.

9. Children's Privacy

The Service is not intended for use by anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16.

10. Changes to this Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top.