lucy platforms

Privacy Policy

Last Revised: May 21 2018

Lucy Platforms Ltd.  (“Lucy”, “Company”, “our,we” or “us”) respects the privacy of the users (“User” or “you”) of its Services and/or our website, and is committed to protect the personal information that its Users share with it. This Privacy Policy (the “Privacy Policy”) is intended to describe our practices regarding the information we may collect from you when you use the Lucy platform for enhanced digital diamonds commerce (the “Services”), the manners in which we may use such information, and the options and rights available to you.

1.        Your Consent (PLEASE READ CAREFULLY!)


Please note: you are not obligated by law to provide us with any Personal Information. You hereby acknowledge and agree that you are providing us with Personal Information at your own free will, for the purpose of providing you with the Services. You hereby agree that we may retain such Personal Information pursuant to this Privacy Policy and any applicable laws and regulations.

2.        Which information we may collect on our Users?

We may collect several types of data and information from our Users:

a.     The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from which we have collected the Non-personal Information. Non-personal Information which is being gathered consists of technical information and behavioral information, and may contain, among other things, the identity and operation system and browser, smart-phone and OS’s version, User’s screen resolution, duration of usage of the website, User's 'click-stream', keyboard language, etc.

b.     Other type of information is individually identifiable information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

·       We collect information through your use of the Services. Namely, when our Users visit or use our Services, we might be aware of it and may gather, collect and record such uses, sessions and related information, including by using third party services as detailed below, and by using “cookies” and other tracking technologies, as further detailed below.

·       We collect information which you provide us voluntarily,  including; (i) details the Users provide in their account registration which requires: name, password and e-mail address; (ii) details the Users provides in his use of the Services which includes: address, phone number, date of birth, gender, and supplemental documentation as may be required by the Services, that may contain Personal Information (such as a copy of their government-issued identification card, personal bank statements or other documentation serving as proof of identity or valid address), purchase history.

c.      In addition, The Company may publish open positions in the Company via its website, Facebook or Linkedin page. In connection with this opportunity, we collect information that is provided to us by the job candidates (“Candidates”), when they apply to any of the open positions published by us, by e-mail, or otherwise. The Company may retain Candidates Information submitted to it even after the applied position has been filled or closed.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.



3.        How Do We Use Your Personal Information? 

We collect, process and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:  

With your consent: We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. For example, we ask for your consent to provide you with personalized content and ads through the use of cookies;

When Performing this Agreement: We collect and process your Personal Information in order to provide you with the Service, following your acceptance of this Terms; to maintain and improve our Services; to develop new services and features for our Users; and to personalize the Services in order for you to get a better user experience.

Legitimate interests: We process your information for our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for things like detecting, preventing, or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our services, protecting against harm to the rights, property or safety of our properties, or our users, or the public as required or permitted by law; Enforcing legal claims, including investigation of potential violations of this Privacy Policy; in order to comply and/or fulfil our obligation under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request, as well as our Terms of Service.

4.        What are the Purposes of the Collection of Information? 

We may use information that we collect about you for the following purposes:

a.      To facilitate, operate, and provide our Services;

b.      To verify the identity of our Users including through an industry-standard KYC process;

c.      To further develop, customize and improve our Services, and to provide you with any such enhanced Services;

d.      To provide our Users with ongoing customer assistance and technical support;

e.      To be able to contact our visitors and Users with general and personalized service-related notices, surveys and promotional messages (as further detailed in Section 13 below);

f.      To create cumulative statistical data and other cumulative information and/or other conclusive information that is non-personal, in which we and/or our business partners might make use of in order to operate and improve our Website and provide related services;

g.      To manage and assess risk, enhance our data security and fraud prevention capabilities, and help protect against error, fraud or any illegal or prohibited activity;

h.      To act as permitted by, and to comply with, any legal or regulatory requirements; and

i.       To conduct any additional activities that may require the use of your Personal Information, for which we will request your consent in advance.

5.        Where Do We Store Personal Information?

Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in the United States and in Israel, and as necessary, in secured cloud storage, provided by our third party service provider.

While the data protection laws in the above jurisdictions may be different than the laws of your residence or location, please know that the Company, its affiliates and service providers that store or process your Personal Information on the Company's behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

You hereby accept the place of storage and the transfer of information as described above.

6.        Non-Personal and Personal Information of Third Parties

To the extent Lucy processes any Personal Information on Your behalf when performing of the Services, You shall be deemed the data controller and Lucy shall be deemed a data processor, and in any such case: (i) You will collect, use, transfer and otherwise process any Personal Information collected by or through the Services in compliance with all applicable laws, enactments, regulations, orders, standards and other similar instruments, including but not limited to the data protection laws and employment laws; (ii) You shall be responsible for providing appropriate information and obtaining any required consent from End Users, including notice and consent allowing it to own, control and transfer all Personal Information that is provided by End Users; and (iii) You have provided such information and obtained such consent to any processing of Personal Information by and through the Platform and Services in accordance with any and all applicable laws.

You shall ensure that each of its websites contains a privacy policy that: (a) discloses the usage of third-party technology and the data collection and usage resulting from the Services; (b) contains a conspicuous live hyperlink to an opt-out website that provides the End User the ability to opt out of interest-based advertising through the Services; and (c) complies with all applicable privacy laws, rules and regulation, including in connection with the communication of commercial advertisements (including anti-spam). You shall provide Company, with respect to the provision of the Services, a copy of Your privacy policy consistent with the foregoing requirements.


7.        To whom we share personal information

Lucy may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

a.      Third Party Services: Lucy has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server services, data and cyber security services, data analytics services( including Google Analytics and MixPanel), payment processors, e-mail distribution and monitoring services, and our business, legal and financial advisors (collectively, “Third Party Services”). Such Third Party Services may receive or otherwise have access to our Users’ Personal Information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Lucy remains responsible and liable for any Personal Information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.

b.      Law enforcement, legal proceedings, and as authorized by law: We may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.

c.      Protecting Rights and Safety: We may share your Personal Information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Lucy, any of our Users, or any member of the general public

d.      Lucy Subsidiaries and Affiliated Companies: We may share Personal Information internally within our family of companies, for the purposes described in this Privacy Policy and in accordance with Section 5 above. In addition, should Lucy or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Information may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have you via e-mail and/or prominent notice on our Website or Services.

For the avoidance of doubt, Lucy may share your Personal Information in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so. Additionally, we may transfer, share or otherwise use Non-personal Information in our sole discretion and without the need for further approval. Additionally, Lucy may transfer and disclose Non-personal Information to third parties at its own discretion.

8.     Use of Cookies and Other Tracking Technologies  

For detailed information on our use of monitoring and tracking technologies, please visit our

We use certain monitoring and tracking technologies, including ones offered by third party service providers. These technologies are used in order to maintain, provide and improve our website on an ongoing basis, and in order to provide a better experience to our Users. For example, these technologies enable us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our website by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our website, (iv) create and monitor analytics, and (v) deliver you targeted advertisements that are more tailored to you based on your browsing activities and inferred interests and track ad performance (For more information about this practice, click here:

Learn more about your choices and how to opt-out of tracking technologies:

In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or You may also opt out of third party tracking technologies by following the instructions provided by each third party service provider in its privacy policy listed above or visiting Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Website, or may otherwise adversely affect your user experience. Please note however that we do not respond to the ‘Do Not Track’ setting on your browser.

9.        Updating, Obtaining a copy of, or Deleting your Personal Information  

If the law applicable to you grants you such rights, you may ask to access, correct, or delete your Personal Information that is stored in our systems. You may also ask for our confirmation as to whether or not we process your Personal Information.

Subject to the limitations in law, you may request that we update, correct, or delete inaccurate or outdated information. You may also request that we suspend the use of any Personal Information whose accuracy you contest while we verify the status of that data.

Subject the limitations in law, you may also be entitled to obtain the Personal Information you directly provided us (excluding data we obtained from other sources) in a structured, commonly used, and machine-readable format and may have the right to transmit such data to another party.

If you wish to exercise any of these rights, contact us at: [email protected]. When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates

To find out whether these rights apply to you and on any other privacy related matter, you can contact your local data protection authority if you have concerns regarding your rights under local law.


10.     Minors

To use our Services, you must be over the age of sixteen (16). Therefore, Lucy does not knowingly collect Personal Information from minors under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.

11.     Security and Data Retention

We employ industry standard procedures and policies to ensure the safety of its Users’ Personal Information, reduce the risks stemming from loss of information and prevent unauthorized use of any such information.  However, no measure can provide absolute information security.

We retain the Personal Information we collect only for as long as needed in order to provide you with our services and to comply with applicable laws and regulations. We then either delete from our systems or anonymize it without further notice to you.

If you withdraw your consent to us processing your Personal Information, we will delete your Personal Information from our systems (except to the extent such data in whole or in part to comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates).

12.     Direct Marketing

You hereby agree that we may use your contact details provided during the filling of a contact form, for the purpose of informing you regarding our products and services which may interest you, and to send to you other marketing material. You may withdraw your consent via sending us written notice by email to the following address: [email protected] or by pressing the “Unsubscribe” button in the mail.

Please note that the Company may also contact you with important information regarding our Website. For example, we may notify you (through any of the means available to us) of changes or updates to our Website, payment issues, service maintenance, etc. You will not be able to opt-out of receive such service messages.

13.     Changes to the Privacy Policy

We reserve the right to change this policy at any time, so please re-visit this page frequently. We will notify you regarding substantial changes of this Privacy Policy by changing the link to the Privacy Policy in the Service and/or by sending you an e-mail regarding such changes to the e-mail address that you provided during registration. Such substantial changes will take effect seven (7) days after such notice was provided on our Website or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Website after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

14.     General

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of the State of Israel, without respect to its criminal law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in Tel Aviv, Israel.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices, and encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit. This Privacy Policy does not apply to such linked third-party websites and services

15.     Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: [email protected] and we will make an effort to reply within a reasonable timeframe.

By contacting the Company you warrant and agree that you are free to do so, and that you do not provide Lucy with information which violate any third party intellectual rights (the “Information”). Without degrading from the aforesaid, all rights, including intellectual property, arising from the communication will be owned by the Company and will be considered as Lucy’s confidential material. It is clarified that any use of the Information, will be done in the sole discretion of the Company, and the Company is not obligated to use all or part of this Information.




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