1. Controller and Contact
Controller: Edencrew Inc.
Address: 1015, Building A, Saenggakgongjang Dangsan, 150 Yeongdeungpo-ro, Yeongdeungpo-gu, Seoul, Republic of Korea
Email: contact@edencrew.com
2. EU/EEA Users and EU Representative (Article 27 GDPR)
Edencrew is not established in the EU/EEA. Where required under applicable law, Edencrew will appoint an EU representative and update this Policy with the representative's contact details.
3. Personal Data We Collect
We may collect the following categories of personal data:
Account and Identity Data
ㆍName
ㆍEmail
ㆍCompany
ㆍPassword (stored in hashed form; we do not store plaintext passwords)
Usage, Device, and Security Data
ㆍIP address, timestamps, device/browser information
ㆍAccess logs, security events, and abuse-prevention signals
Support Communications
ㆍMessages and attachments you send to support
ㆍRecords of support interactions
4. How We Use Personal Data and Legal Bases
We process personal data for the following purposes:
ㆍProvide and operate Lucy Studio (account creation, login, and core features) — Legal basis: performance of a contract / steps at your request.
ㆍSecure the Services (fraud prevention, abuse detection, incident response, stability) — Legal basis: legitimate interests in securing and operating the Services.
ㆍTransactional communications (password reset, security notices, important service notices) — Legal basis: contract and/or legitimate interests.
ㆍAnalytics and measurement (Google Analytics) — Legal basis: consent where required for non-essential cookies/trackers.
ㆍLegal compliance and enforcement — Legal basis: legal obligation and/or legitimate interests.
We do not use marketing/newsletter opt-in at sign-up today. If we introduce marketing in the future, we will use opt-in consent and provide easy withdrawal.
5. Cookies and Similar Technologies
We use cookies and similar technologies for essential functionality (where applicable) and analytics (e.g., Google Analytics). Where required, we will request consent before enabling non-essential cookies/trackers and will provide cookie settings.
6. Sharing and Processors
We may share personal data with service providers (processors) that help us operate the Services, such as:
ㆍEU-region cloud hosting and storage providers (for EU users)
ㆍEmail delivery providers (for password reset and service notices)
ㆍAnalytics providers (e.g., Google Analytics)
ㆍMonitoring and support tooling providers
We also may disclose data if required by law, to protect rights and safety, or to prevent fraud and abuse.
7. International Transfers
We intend to host EU user data primarily in the EU. However, international transfers may occur depending on operations and vendors. Analytics providers may process data outside the EU/EEA depending on their infrastructure and configurations. Where required, we will rely on valid transfer mechanisms and safeguards.
8. Data Retention
We retain personal data only as long as necessary for the purposes described above:
ㆍAccount data: while your account is active.
ㆍAfter account deletion request: we delete or anonymize personal data within a reasonable time, except:
- Backups: deleted on a rolling basis within up to 90 days.
- Security and access logs: retained for up to 12 months for security, fraud prevention, and abuse detection.
- Legal/contract records: retained as required by law or for dispute defense.
9. Your Rights (EU/Spain Users)
Where applicable, you may have rights to access, rectify, delete, restrict processing, data portability, and object, and to withdraw consent where processing is based on consent. To exercise rights, contact contact@edencrew.com. You may also lodge a complaint with a supervisory authority, including Spain's data protection authority (AEPD).
10. Security
We implement reasonable technical and organizational measures to protect personal data (e.g., access controls, encryption in transit, and security logging). If a personal data breach occurs, we will take steps consistent with applicable legal requirements.
11. Children
The Services are intended for users with legal capacity. If we learn we collected personal data from a child in a manner requiring parental consent under applicable law, we will take appropriate steps.
12. Changes to This Policy
We may update this Privacy Policy. If changes are material, we will notify you via email and/or in-product notice before they take effect.