Last modified: Tue, 21 October, 2023

1. INTRODUCTION

Diagonalslash Inc. (“Diagonalslash,” "Luru", “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use the Luru Platform (the “Platform”) through Luru’s website at https://luru.app  (the “Website”) or Luru’s application (the “App”) or Luru’s apps for Zoom, Slack, MSTeams chat, Gchat (Luru add-ons) or Luru’s chrome extension. We provide software that helps sales professionals quickly find and share the content, knowledge, and information they need to effectively sell their product or service to customers.

Luru is committed to protecting the privacy of its Users whose information is collected and stored while using Luru’s Platform through our Website, App or add-ons. This Privacy Policy is applicable to our Website, Platform, App, add-ons and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Service, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP AND PLATFORM.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT HELLO@LURU.APP

WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

2. WHAT INFORMATION DO WE COLLECT?

When you register to use our Website, App or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, online contact information such as your email address or username, phone number, professional or employment-related information and other personal information. The information so collected will be stored on our servers. You are able to change your personal information via email by contacting us at hello@luru.app or through your profile or account settings on our Website, App or Platform.

• Geolocation and Equipment Information. We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App or Platform, and usage details.
• Financial Information. We currently do not collect or store any credit cards or bank information., as we will use a third-party payment processor. However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.

3. HOW DO WE COLLECT INFORMATION?

We collect personal information from you in the following ways:

• At registration on our Website, App or Platform;
• In email, text, and other electronic messages between you and our Website, App or Platform;
• Through desktop applications you download from our Website, App or Platform, which provides dedicated non-browser-based interaction between you and our Website, App or Platform;
• When you interact with our advertising and applications on third-party website and services, if those applications or advertising include a link to this Privacy Policy;
• From you placing an order, which includes details of transactions you carry out on our Website or Platform;
• From your responses to a survey;
• From forms filled out by you;
• From records or copies of correspondences (including email addresses) if you contact us;
• From search queries on our Website, App or Platform; and

We collect information from you automatically when you navigate through our Website, App or Platform in the following ways:

• Usage details;
• IP addresses;
• Information obtained through browser cookies;
• Information obtained through flash cookies; and
• Other tracking technologies

4. HOW DO WE USE YOUR INFORMATION?

We use the information that you provide to:

• Personalize your experience in using our Platform;
• Provide you with information, products, or services requested from us;
• Present our Website, App and Platform and their contents to you;
• Provide you with notices about account and/or subscription, including expiration and renewal notices;
• Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection;
• Notify you about changes to our Website, App and Platform and any products or services;
• Allow you to participate in interactive features on our Website and Platform;
• Improve the Website, App and Platform;
• Improve our customer service;
• Process transactions;
• Anonymize data and aggregate data for statistics;
• Contact you for other purposes with your consent;
• Contact you about our products and services that may be of interest;
• Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent; and
• Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 15, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.

5. OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”

We use Cookies on our Website and App to (a) help remember and process items in the shopping cart, (b) understand and save your preferences for future visits, (c) keep track of advertisements, (d) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (e) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not Track signals and, if one is in place, we will not track, plant cookies, or use advertising.

We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion, we may include or offer third-party products or services on our Website, App or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App or Platform and welcome any feedback about these sites. Please contact us at hello@luru.app.

6. HOW DO WE PROTECT INFORMATION WE COLLECT?

Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We will accept payment by credit card through a third-party credit card processor on our behalf. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.

7. DATA SECURITY MEASURES.

• Security Measures. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App or Platform.
• Fair Information Practice Principles. In the event of a personal data breach, we will notify you within seventy-two (72) hours via (i) email and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

8. DISCLOSURE OF PERSONAL INFORMATION

There are times when we may share Personal Information that you have shared with us may be shared by Luru with others to enable us to provide you over Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how Luru may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:

Disclosure of Personal Information.

• We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
• We may disclose personal information to our subsidiaries and affiliates.
• We may disclose personal information to contractors, services providers, and other third parties.
• We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
• We may disclose personal information in the event of a merger, sale of business, etc.
• We may disclose personal information to third parties to market their products and services if you have either consented or not opted out of these disclosures.
• We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
• We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a colleague” feature of the Platform.
• We may disclose personal information for any other purpose for which you have provided it.
• We may only disclose personal information as described in this Privacy Policy or your consent.

Other Disclosure of Personal Information.

• We will disclose personal information (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes, (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Luru, our customers or others, and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Luru, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third Party Disclosure.

• We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
• We do not provide non-personally identifiable visitor information for marketing purposes.

Choices Users Have About How Luru Uses and Discloses Information.

• Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or function properly.
• Disclosure of Users’ Information for Third-Party Advertising. Users can opt-out by (i) checking the relevant form when we collect the data; (ii) logging into the Website, App or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at hello@luru.app. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Luru for product purchases, warranty registration, or other transactions.
• Disclosure of User’s Information for Targeted Advertising. Users can opt-out by (i) checking the relevant form when we collect the data, (ii) logging into the Website, App or Platform and adjusting their preferences in their account profile by checking or unchecking the relevant boxes, or (iii) emailing us their opt-out request at hello@luru.app.
• Request for deletion of User’s Information. Users can request for their Personal Information to be deleted. Upon request, we will delete all of your Personal Information that we have collected on the user and will direct our Service Providers to also delete all of the users’ Personal Information. But note that if we do delete all of this Personal Information, the user will no longer be able to use our Services.
• Retention of User Personal Information. We will retain users’ Personal Information for a period of 36 months thereafter all the information will be deleted, permanently. If the user wishes to access, export or transfer any of this personal information , the request for the same should be made within the 36 months window.

9. GOOGLE ADSENSE AND GOOGLE ANALYTICS

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website usage data. To learn more about Google Analytics and how to opt-out, please visit https://support.google.com/analytics/answer/12938611?hl=en#optout&zippy=%2Cin-this-article

We may implement advertising features on our Website, App and Platform including: (a) remarketing with Google AdSense; (b) Google Display Network Impression Reporting; (c) Google Demographics and Interests Reporting; and (d) Google’s DoubleClick platform integration.

We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.

10.INTERNATIONAL TRANSFER

10.1. Luru processes Personal Data in the USA and other countries. If you are a resident of UK or the European Economic Area and when your Personal Data is processed outside UK or the EEA, Luru will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of Personal Data as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or Luru will ask you for your prior consent to such international data transfers.

11.RIGHTS OF THE DATA-SUBJECTS

If you are a resident of the EEA, UK, Switzerland or California you are entitled to the following rights:
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11.1. You can request Luru for access, correction, update or request deletion of your Personal Data.

11.2. You can object to the Processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.

11.3. You have the right to opt-out of marketing communications Luru sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails Luru sends you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.  

11.4. Similarly, if Luru has collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing Luru conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

11.5.You have the right to complain to a data protection authority about Luru’s collection and use of your Personal Data. For more information, please contact your local data protection authority.

11.6.If you seek access to, or wish to correct, update, modify or delete your Personal Data Luru processes, please contact us at hello@luru.app. We respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.

12. PRIVACY OF CHILDREN

12.1. Luru recognizes the importance of children's safety and privacy and is sensitive to these issues. Luru does not request, or knowingly collect, any Personal Data from children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, they should write to us at the email address provided in Clause 12.2

13. COOKIE POLICY

13.1.Cookies are text files that are placed on your computer to collect standard internet log information and visitor behaviour information by Luru. When you visit the Website(s), Luru may collect Personal Data automatically from you through cookies or similar technology.

13.2. Essential Cookies: Luru sets essential cookies that enable core functionality such as security, network management, and accessibility. you may not opt-out of these cookies. However, you may disable these by changing your browser settings, but this may affect how the Website(s) functions.

13.3. Analytics, Customisation and Advertising Cookies: Luru sets Google Analytics cookies to help it improve its Website(s) by collecting and reporting information on how you use it. The cookies collect information in a way that does not directly identify anyone. Luru also sets cookies to collect information that is used either in aggregate form to help Luru understand how our Website(s) are being used or how effective their marketing campaigns are, to help customise the Website(s) for you or to make advertising messages more relevant to you. Luru uses the following analytics, customisation and advertising cookies: 
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14. MODIFICATIONS TO OUR PRIVACY POLICY

Luru reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy. We will inform you about the modifications on our Privacy Policy page via email, on our Website, App, or Platform by posting a modified version of the Privacy Policy page, or by a comparable means within a reasonable time period. Your continued use of our Website, App, or Platform shall constitute your consent to such changes.
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15. LIST OF THIRD-PARTY SERVICE PROVIDERS

Luru uses the following third-party service providers for the provision of services as detailed under the Terms of Service

16. COPYRIGHT INFRINGEMENT/DMCA NOTICE

If you believe that any content on our Website, App or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

• Your physical or electronic signature;
• Identification of the copyrighted work(s) that you claim to have been infringed;
• Identification of the material on our Website, App or Platform that you claim is infringing and that you request us to remove;
• Sufficient information to permit us to locate such material;
• Your address, telephone number, and email address;
• A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and
• A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner.

Luru’s Copyright Agent to receive DMCA Takedown Notices is Karthikeyan Krishnamurthy at hello@luru.app and at Diagonalslash Inc. Attn: DMCA Notice, Diagonalslash Inc., 108 W. 13th Street, Suite 100, Wilmington, Delaware - 19801. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section.

Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by Luru in connection with the written notification and allegation of copyright infringement.

17. CONTACT US

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

• Karthikeyan Krishnamurthy
• Email: hello@luru.app
• Address: Diagonalslash, Inc., 108 W. 13th Street, Suite 100, Wilmington, Delaware - 19801

PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, ADD-ONS OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE OR TERMS OF SERVICE, AS APPLICABLE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, APP OR PLATFORM.

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