Privacy Policy
Effective date: [DATE] — Draft, pending legal review.
Who we are
[LEGAL ENTITY NAME] (“Lucerna Markets,” “we,” “us,” or “our”) operates this website. This Privacy Policy explains what information we collect, how we use it, and the choices you have. Registered address: [FULL REGISTERED ADDRESS]. Contact: [BUSINESS EMAIL].
Information we collect
Information you provide directly (name, organization, role, email, message content submitted via our forms); automatically collected information (IP address, browser type, device information, usage data via cookies and analytics); and information from third parties if you’re referred to us.
How we use your information
To respond to inquiries and evaluate potential business relationships; to operate, maintain, and improve this site; and to comply with legal and regulatory obligations, including counterparty due diligence. We do not sell personal information to third parties.
Legal basis for processing (GDPR)
Where GDPR applies, we process personal data under: consent (optional cookies, marketing), legitimate interest (responding to inquiries, operating the site), contractual necessity (steps toward a potential business relationship), and legal obligation (compliance and due diligence).
Your rights
If GDPR or a similar law applies to you, you have the right to access, correct, or delete your data; object to or restrict processing; request portability; and withdraw consent at any time. Contact [BUSINESS EMAIL] to exercise these rights.
Data retention
We retain personal information only as long as necessary for the purposes above, or as required by applicable law.
Data security
We use reasonable administrative, technical, and organizational measures to protect personal information. No method of transmission or storage is completely secure.
Contact
Questions about this Privacy Policy: [BUSINESS EMAIL]