Privacy Policy

FDV ECOM SAS LLC is the controller of the personal data collected through the LUCRA platform (ecomlucra.com). This policy complies with applicable international regulations, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) and equivalent data protection laws in Latin America.

We collect the following types of personal data:

• Account data: name, email, country, phone (optional), billing details.
• Profile data: store name, avatar, gender, and any optional data you choose to share.
• Usage data: history of generated landings, analyzed products, produced creatives, community interactions, credit-consumption metrics.
• Technical data: IP address, browser type, operating system, pages visited, session identifiers.
• Payment data: processed directly by Stripe (direct users) or by the Shopify Billing API (Shopify merchants). We never store card numbers on our servers.
• Biometric data (optional): voice samples if you choose to use the Voice Cloning feature. These are processed solely to generate your personal voice model and are never shared with third parties without your consent.
• Optional data: connections to Dropi, Shopify, Meta (Facebook/Instagram) Ads or other logistics, e-commerce or advertising platforms you choose to integrate.
• WhatsApp data (optional): if you use the WhatsApp automation of the Personal plans, we process your WhatsApp number and the content of the messages for that purpose (expenses and goals you log, report commands). If you also agree to receive LUCRA news and announcements via WhatsApp, we store the date and channel of that consent.
• WhatsApp sales CRM data (optional, for businesses): if you connect your WhatsApp Business number to LUCRA's sales CRM, we process, on your behalf, the messages your customers send and the replies sent from LUCRA (by you, your team or the AI assistant), their phone number and name, and the order data they give (address, city, products, quantities and value). If you connected Dropi, that order data is sent to Dropi to create the shipment. If your number also uses the WhatsApp Business app (coexistence), Meta sends us, on your behalf, the messages you send from the app, the changes to your app contacts and, if you allow it when connecting, the chat history of the last 180 days, so the CRM shows each full conversation. If you don't share the history, the CRM starts from the moment you connect.

We use your data for the following purposes:

• Provide and operate the Service.
• Process payments and manage your subscription.
• Generate AI content per your instructions (landings, creatives, audio, video).
• Send you transactional notifications (confirmations, trial alerts, payment reminders).
• Send you LUCRA news and announcements via WhatsApp, only if you gave your explicit consent (checkbox at signup or a message from you requesting it). You can revoke it at any time by replying STOP to any message — we immediately stop sending this type of communication.
• Improve the Service and develop new features.
• Detect fraud, abuse and violations of the Terms.
• Comply with applicable legal obligations.

We never sell your personal data to third parties under any circumstances.

To deliver LUCRA's features, we rely on third-party service providers that process data on our behalf, under confidentiality agreements and compliance equivalent to or stronger than this policy. These are our current sub-processors:

• Generative AI providers — AI image, video, text and voice generation. They process the prompts and files you generate under confidentiality and data-processing agreements; they do not use your content to train their models. A detailed list is available on request via Support.
• Stripe, Inc. — card payment processing and subscription management for direct users.
• Wise (Wise Payments Ltd. and its affiliates) — payment of commissions to the bank account of affiliates, leaders and partners. It receives only the account details and the amount of each payment.
• Shopify Inc. — for Shopify merchants, billing of plans and credit purchases is processed through the Shopify Billing API (within Shopify).
• Supabase, Inc. — database storage, authentication and file storage.
• Vercel, Inc. — web application hosting and content delivery (CDN).
• Resend (Drift, Inc.) — transactional email delivery (verification codes, notifications).
• WhatsApp Business Platform (Meta Platforms, Inc.) — messaging channel for the optional automation of the Personal plans (logging expenses/goals and receiving reports via WhatsApp) and for the optional sales CRM of businesses that connect their own WhatsApp Business number (their customers' messages and orders, processed on their behalf). We process the WhatsApp numbers and the content of the messages sent/received for these purposes.
• TikTok (ByteDance Ltd.) — for the optional TikTok Ads integration, we access your advertising report data (metrics and spend) via the TikTok Business API to record it in your accounting. See section 13.

Each of these providers has its own robust privacy policies and complies with international regulations. We may update this list as the platform evolves; significant changes will be notified via email.

We use cookies and similar technologies (localStorage, sessionStorage) to:

• Keep your session active after you log in.
• Remember UI preferences (light/dark mode, language).
• Persist state across payment redirects.
• Measure aggregate usage and performance (without direct personal identification).

You can disable cookies in your browser settings, though some features may stop working correctly.

You have the following rights over your personal data (in accordance with GDPR, CCPA and equivalent local laws):

• Access: request a copy of the personal data we hold about you.
• Rectification: correct inaccurate or incomplete data.
• Erasure: request deletion of your account and associated data (available directly in the app under Settings → Delete account).
• Portability: receive your data in a structured, machine-readable format.
• Objection: object to certain processing of your data.
• Withdrawal of consent: revoke consents granted at any time.

To exercise any of these rights, contact us at support@ecomlucra.com. We respond within 30 days.

We keep your personal data for as long as necessary to provide the Service and comply with legal obligations:

• Account data: while your account is active, plus 30 days after deletion.
• Billing data: up to 7 years for tax compliance.
• Technical logs: up to 90 days for troubleshooting and security.
• Cloned voice: while your account is active or until you delete it manually from the app.
• Community messages: subject to a specific, configurable chat retention policy.

We implement technical and organizational measures to protect your data:

• TLS 1.3 encryption in transit.
• Encryption of sensitive data at rest (integration tokens via AES).
• Secure authentication with Supabase Auth.
• Row-Level Security (RLS) in the database.
• Rate limiting and monitoring against abuse.
• Automated daily backups.
• Security headers: HSTS, X-Frame-Options, Permissions-Policy.

No system is 100% secure, however. In the event of a security breach affecting your data, we will notify you without undue delay.

Some sub-processors have servers outside your country of residence (mainly the United States and the European Union). These transfers are carried out under recognized legal mechanisms (Standard Contractual Clauses, Data Processing Agreements) to ensure equivalent protection.

LUCRA is not directed to anyone under 18. We do not knowingly collect data from minors. If you discover that a minor has created an account without parental consent, contact us to delete it.

When you connect your Shopify store to LUCRA, we act as an "App Developer" under the Shopify Platform. Here we detail exactly what we do with your store's data:

Shopify data we collect:

• OAuth access token: stored encrypted (AES-256) in our database. Required to publish products on your behalf.
• Product list: we read your products (title, price, images, variants) when you manually import them from the Products section. We do NOT read products without your explicit action.
• Active theme: we read which theme you have active to publish landings as native sections (image-banner). We do NOT modify your theme; we only create separate templates.
• Store domain: we store yourstore.myshopify.com to associate it with your LUCRA account.

Shopify data we do NOT collect:

• Your store's end-customer data (names, emails, addresses, purchase history).
• Order, payment or payment-method information.
• Store analytics data (sessions, conversions, etc.).
• Inventory or stock levels.

OAuth scopes we request and why:

• read_products: read your catalog to import it into LUCRA (user-initiated action).
• write_products: publish the landings generated in LUCRA as products in your store.
• write_files: upload the optimized landing images to Shopify's native CDN (Files).
• read_themes: detect whether your theme supports image-banner sections (to use the PRO or LEGACY flow).
• write_themes: create the landing JSON templates (templates/product.lucra-{productId}.json). We do NOT modify the rest of the theme.

GDPR compliance webhooks (Shopify mandatory):

• app/uninstalled: when you uninstall the app, we delete your access token and the integration row within 24 hours.
• customers/data_request: if a customer of your store requests their data, we respond confirming that LUCRA does not store customer data.
• customers/redact: same — we do not store customer data, so there is nothing to erase.
• shop/redact: 48 hours after your store closes, we delete all integration information within 30 days.

Pricing model: LUCRA is free to install. For merchants who install LUCRA from the Shopify App Store (or whose account is in Shopify context), both the plans (Starter, Pro, Empire, Business) and credit purchases are charged through the Shopify Billing API — within Shopify, on the merchant's Shopify invoice. We do NOT charge Shopify merchants outside the Shopify Billing API. Users who sign up directly at ecomlucra.com (outside Shopify) are charged via our payment processor (Stripe).

When you connect your Meta advertising account to LUCRA (optional feature), we access your campaign data to show you your metrics and automatically record your ad spend in your accounting, and — if you enable it — to build and create campaigns, ad sets and ads in your account. Everything LUCRA creates is ALWAYS paused: it is never activated and never spends your budget without an explicit action from you.

Meta data we collect:

• OAuth access token: stored encrypted (AES-256) in our database. Required to query your advertising data on your behalf.
• Ad accounts: identifier, name and currency of the ad accounts you manage, so you can choose which to connect.
• Campaign data: name, identifier, status and daily spend of your campaigns, ad sets and ads, along with aggregate performance metrics (impressions, clicks, CPM, CTR).

Meta data we do NOT collect:

• Personal data of people who view your ads. If you turn on the optional Instagram and Messenger inbox, LUCRA processes the comments people leave on your posts (which may include posts you promote as ads), as described in section 12.1.
• The organic posts, followers or insights of your Facebook Pages or Instagram profiles. Messages and comments are processed only if you turn on the optional Instagram and Messenger inbox (section 12.1).
• Your friends list, contacts, or any personal profile data beyond the identifier needed for the connection.
• Custom audiences or customer lists.

OAuth scopes we request and why:

• ads_read: read your campaign metrics and spend to record them in your accounting and give you recommendations.
• ads_management: create and manage campaigns, ad sets and ads in your account when you ask (always created PAUSED), and apply the actions you trigger: turn off/on, adjust budget, duplicate.
• business_management: list the ad accounts in your business portfolio so you can select which to connect.
• pages_show_list: list your Facebook Pages to associate the created ad with the Page you choose (Meta requires this to create ads).
• pages_read_engagement: Meta requires this as a dependency of ads_management to create and manage ads associated with your Page. We do not read or store your Page's organic posts, photos or follower data beyond what is needed to associate the ad with the Page you choose.

Disconnection and deletion: you can disconnect the integration at any time from Settings → Integrations inside LUCRA (we delete your token immediately), or revoke access from your Facebook account's app settings. When you delete your LUCRA account, all integration tokens and data are deleted with it. We also respond automatically to Meta's callbacks: if you remove the app from your Facebook (deauthorize) or request deletion of your data (data deletion request), we delete your access token and the information obtained from Meta (ad account data and change log) with no further action needed from you.

When you connect a Facebook Page and, if it has one, its linked Instagram professional account to LUCRA's sales CRM (Integrations → Instagram · Messenger), LUCRA processes the following on your behalf, only to run that inbox for you:

• Page and Instagram account data: Page ID, name and picture; Instagram account ID, username and profile picture; and a Page access token, stored encrypted (AES-256). We also store the identifier of the Facebook user who connected the account, so we can find and delete it when Meta tells us that person removed LUCRA or requested the deletion of their data.
• Messages: the direct messages people send to your Page (Messenger) or to your Instagram account, the replies sent from LUCRA (by you, your team or the AI assistant), links to attachments, timestamps, and the sender's Page-scoped or Instagram-scoped ID, name and profile picture.
• Comments: the comments people leave on your Page's and Instagram account's posts (text, author ID and name, link to the post), the AI classification (question, purchase, positive, negative, spam or neutral), the reply, and the action taken (reply, hide or delete) according to your settings.

Purpose: to show these conversations and comments in your CRM so that you, your team and — if you turn it on — the AI assistant can answer your customers, reply to comments with your product link, and hide or delete negative or spam comments according to your settings.

AI processing: when the AI assistant is on, the text of the message or comment, the recent messages of that conversation and your product catalog are sent to OpenAI to write the reply or the classification. If you use your own OpenAI key, they are sent with your key.

Automated replies: the AI assistant only replies within 24 hours of the customer's message. It tells customers it is the store's virtual assistant when the conversation starts, after a long pause or when it takes over again after you or your team replied from LUCRA, and it answers truthfully if they ask whether they are talking to a person or a bot. If a customer asks for a person, it hands the chat over to you, notifies you and stops replying in that chat. Between 24 hours and 7 days only a person can reply, with Meta's Human Agent tag; after 7 days LUCRA does not send messages until the customer writes again.

Retention and deletion: this data is kept while the integration exists; there is no automatic expiry. Removing a connected account from Integrations stops LUCRA from handling it (and unsubscribes LUCRA from the Page if no other connected account uses it) and deletes its access token, but keeps its conversations so they come back if you connect it again. The data is deleted: (a) when you delete your LUCRA account; (b) automatically, when you remove LUCRA from your Facebook settings or request the deletion of your data through Meta — we then delete the Pages and Instagram accounts you connected with that Facebook profile, together with their conversations, messages and comments; or (c) on request to support@ecomlucra.com, as described in section 6.

Permissions we request for this feature and why:

• pages_show_list: list your Pages so you choose which one to connect.
• pages_manage_metadata: subscribe your Page to message and comment notifications.
• pages_messaging: receive and answer the messages people send to your Page.
• pages_read_engagement: read your Page's basic data; Meta requires it to receive Instagram messages and comments.
• pages_read_user_content: read the comments people leave on your Page.
• pages_manage_engagement: reply to, hide or delete those comments.
• instagram_basic: identify the linked Instagram account and the post a comment belongs to.
• instagram_manage_messages: receive and answer Instagram direct messages.
• instagram_manage_comments: read, reply to, hide or delete comments on your Instagram posts.
• business_management: Meta lists it as a dependency of the messaging permissions above.
• Meta's Human Agent feature (manual replies up to 7 days) and Business Asset User Profile Access (the customer's name and profile picture in your inbox).

You can revoke these permissions at any time from your Facebook settings.

If you turn them on, LUCRA sends Meta the sales events of your business so you can measure and optimize your ads. LUCRA does this on your behalf; inform your buyers in your store's own privacy notice.

• WhatsApp sales (Meta · WhatsApp sales, permission whatsapp_business_manage_events): when a customer who came from a click-to-WhatsApp ad places an order, LUCRA sends Meta the event (for example, a lead or a purchase) with your WhatsApp Business Account ID, the ad click identifier, the customer's phone number, first name, last name and country (hashed with SHA-256 before sending), the order value, currency and order number, and an event ID that prevents duplicates. If the conversation did not come from an ad, nothing is sent.
• Product pages (Meta Pixel and Conversions API): when you add your Meta Pixel to a LUCRA product page, LUCRA sends Meta the page events (visits, product views, checkout steps and purchases) from its server with the visitor's IP address and browser user agent (unhashed, as Meta requires), the Meta cookies _fbp and _fbc and an anonymous visitor ID (hashed). For a purchase it also sends the buyer's phone number, first name, last name, email (if given), city and country, hashed with SHA-256, plus the value, currency, product and quantity. In the pixel settings you choose how visitors are informed or asked for consent.

LUCRA keeps a log of each event (name, time and whether Meta accepted it) so you can review it. You can turn these events off at any time, and the data is deleted with your account.

When you connect your TikTok Ads account to LUCRA (optional feature), we access your advertising report data to show you your metrics and automatically record your ad spend in your accounting. LUCRA reads this data only — it does not create, modify or activate campaigns on TikTok.

OAuth scopes we request and why:

• user.info.basic: identify your TikTok Business account to associate the connection.
• advertiser.read: list your advertiser accounts so you can choose which to connect.
• ad.report: read your campaigns' performance reports and spend to record them in your accounting.

We do NOT collect your videos' organic content, your followers, or personal data of people who view your ads. Disconnection and deletion: you can disconnect the integration at any time from Settings → Integrations inside LUCRA (we delete your token immediately). When you delete your LUCRA account, all integration tokens and data are deleted with it.

LUCRA MCP is optional: it connects your LUCRA account to the AI you use (Anthropic's Claude, OpenAI's ChatGPT or another compatible one) so it can help you run your business. It only works if you authorize it on LUCRA's consent screen, choosing what it may do: view your business, create with AI, edit your catalog or message your customers (each send, with your confirmation).

What your AI receives: what you ask for, within what you authorized: figures and data about your business (sales, orders, catalog, Profit, campaigns, Dropi deliveries, Tu Winner). Your buyers' data is trimmed (short name, city and the last digits of the phone). It never receives passwords, tokens of your integrations, payment data or full addresses.

Who processes it: the company behind the AI you connect (Anthropic, OpenAI or another) receives those answers and handles them under its own privacy policy. LUCRA gives it nothing else.

What LUCRA receives from your AI: only the inputs of each tool you use (for example, a product, a date, the text of a reminder or which customers to message). Never your conversation with the AI, its memory or your files. They are used only to do what you asked: quotes are deleted 1 day after they expire; what is prepared for publishing or for messaging your customers (the full recipient list stays only on LUCRA's servers), 7 days after it expires; reminders, 90 days after their date, once sent or canceled. What you create (studies, pages, images, videos) stays in your account like anything you create in the app.

What LUCRA keeps: the authorization (which AI, which permissions and when, with a hashed fingerprint of the IP you granted it from, for security), access credentials stored as hashes (deleted 30 days after they expire or you disconnect) and a usage log without personal data (tool, result, credits and duration) for 90 days, for your activity and for security.

Your control: see and disconnect each AI in Integrations › LUCRA MCP (or Settings › Security). Disconnecting cuts access instantly and stops any work in progress.

Identity verification. To create a community or get paid as a leader or partner, you verify your identity inside LUCRA: you enter your document type, country and number and your name as it appears on it, and you take photos of the document (front and, if it has one, back) and a selfie at that moment, with the camera of your computer or your phone (through a single-use QR code that expires after 20 minutes). The photos are uploaded directly to LUCRA's private storage; they are not public and only LUCRA's authorized staff can view them, through temporary links. For each photo we also keep its digital fingerprint (SHA-256), which makes it possible to prove later that it was not altered. Your document number is stored encrypted (only its last 4 characters remain visible) and, to prevent the same document from being used in several accounts, we also keep an irreversible fingerprint of that number. If you wish, you can also add the links to your public Instagram, TikTok or YouTube profiles: this is optional, does not change the automatic result of the verification, and only LUCRA's authorized staff can see them, to confirm that you are who you say you are; LUCRA does not access those accounts or post anything on them.

Automated face comparison. LUCRA automatically compares the face in your selfie with the face in your document photo, using a face-recognition model that runs on LUCRA's servers: the photos are not sent to third parties for this. The model computes a numeric template of each face only during the comparison and discards it right away; we keep only the result (match, doubtful or no match), the similarity measure and the technical data of the comparison. If the result is clear, the verification is approved on the spot; otherwise, a person on LUCRA's team reviews it. No verification is ever rejected solely by an automated decision: if the team asks you to redo it, they tell you why, and you can always ask a person to review the result by writing to support@ecomlucra.com.

Sensitive data and consent. Photos of your face and their comparison with your document are biometric data, which the law treats as sensitive data. They are only processed if you start the verification and give your express, prior and informed authorization at that moment, which is recorded with its date, an encrypted fingerprint of your IP address and your browser. You are not required to authorize the processing of sensitive data: it is voluntary, but without the verification you cannot create a community or receive payouts as a leader or partner. They are used only to confirm your identity, prevent fraud and impersonation, and meet legal payment obligations.

Bank account. Your account details (holder, bank, number and whatever your country requires) are stored encrypted and are only seen by the payments team when paying you. They are shared with Wise, or with the bank used for the payment, only to make each transfer.

Signed agreement. When you accept the Community Leader Agreement we keep the version, the text fingerprint, the name you signed with, the date and time, a hash of your IP address, your browser or device and the identity verification you signed with, as evidence of the electronic signature.

Data the leader sees. If you join a community through its link, the leader and partners can see and export your name, email, WhatsApp, plan, stage and what you generated for the community, only to support you and communicate with you. The leader is an independent controller of the data they export and is contractually bound to comply with data protection laws. You can leave the community at any time.

Retention. Identity, agreement, commission and payment records are kept while the relationship is active and, afterwards, for the applicable legal evidentiary, accounting and tax periods. You can exercise your rights (section 6) at any time.

If you connect your own keys from an AI provider (OpenAI, Anthropic/Claude, ElevenLabs or Google AI), the calls for those features go to your account with that provider: the content you send (for example, a script, a product photo or a customer's message) is processed by that provider under its own policy and your agreement with it.

What LUCRA stores: the encrypted key (AES-256-GCM), its last 4 characters, its status (active or failed), the verification date and the last error the provider returned. We never show you the full key or share it.

Key checks: when you connect it and when you check it, LUCRA runs a minimal test against the provider to show you its real status; for OpenAI and Claude it is a request of a few tokens that the provider bills you (a fraction of a cent).

Retention: the key is kept while it is connected and deleted when you disconnect it in Integrations › Your APIs.

We may update this Privacy Policy occasionally. Substantial changes will be notified at least 30 days in advance via email to your registered address. The "last updated" date in the header indicates when it was last modified.

For privacy inquiries or to exercise your rights:

• Email: support@ecomlucra.com
• Legal entity: FDV ECOM SAS LLC