Privacy policy
Last updated: 7 October 2026
1. Who we are
The controller is SIA “LuceneX”, a limited liability company established in Latvia.
- Registration number: 40203713932
- Registered address: Siguldas iela 2-68, Vangaži, Ropažu novads, LV-2136, Latvia
- Privacy contact: info@lucenex.eu
This notice covers browsing lucenex.lv, booking a discovery consultation through the Google Calendar appointment page we link to, and email to info@lucenex.eu. When lucenex.eu offers a public website, this notice will cover that site as well. Today lucenex.eu is used for email, not as a separate public website.
2. Scope
This notice explains how we process personal data when you browse lucenex.lv, email us, or book a discovery consultation via our Google Calendar appointment schedule.
It does not replace the contract for a client engagement. Depending on the engagement, LuceneX may act as controller, processor, or independent controller for project data. Where we process personal data on a client’s behalf and Article 28 of Regulation (EU) 2016/679 (the GDPR) requires a data processing agreement, that processing is governed by the contract and that agreement — not by this website notice alone. Not every engagement involves LuceneX acting as a processor or requires a separate DPA.
Our services are aimed at businesses and at adults acting in a professional capacity. We do not offer the public site as a service for children.
We currently do not transfer website consultation enquiries into a dedicated CRM system. We handle follow-up manually in Google Workspace (email and calendar).
3. How data moves
| Stage | Typical data | Purpose | Legal basis | Who receives it | How long (summary) |
|---|---|---|---|---|---|
| Browse lucenex.lv | Connection data needed to deliver the page (for example IP address and request metadata) | Deliver and secure the site | Art. 6(1)(f) — operate a usable, secure site | Cloudflare (hosting / CDN) | See section 6 |
| Book via our Google Calendar link | First and last name, email address, phone number, company name, preferred meeting address, any optional notes you add, and the time you choose; confirmation or invite content | Arrange an in-person discovery consultation and create the calendar event | Art. 6(1)(b) — steps at your request prior to a contract | Google (as our service provider for Workspace Calendar; see section 4.1 for what Google does on its booking page); we receive the booking details in our Google Calendar | Unsuccessful bookings: 12 months (our policy) — see section 6 |
| Email to info@lucenex.eu | Your address, name if present, and message content | Reply and arrange next steps | Art. 6(1)(b); or Art. 6(1)(f) for ordinary business follow-up where no contract follows | Google Workspace (Gmail) as our service provider; we as controller | 12 months if no contract (our policy), unless a longer legal duty applies after you become a client |
We do not make solely automated decisions that produce legal or similarly significant effects for you (GDPR Article 22).
4. What we process
4.1 Discovery consultation booking
lucenex.lv links you (by an ordinary link) to a Google-hosted appointment booking page. You enter your details on Google’s page. We do not run our own booking form on lucenex.lv, and the booking page is not embedded in our site.
Google’s booking page asks for your first name, last name, email address, phone number, company name and preferred meeting address. All of these are required. The page also offers one optional field, “Anything we should know before we meet?”. You choose a time slot. The discovery consultation is an in-person meeting, which is why the page asks for your preferred meeting address. A Google Account is not always required to book.
Google provides the booking page. On that page Google uses reCAPTCHA to protect the booking form against abuse and sets its own cookies (see section 7). Google handles the booking and the calendar invitation, and the appointment is added to our Google Calendar. LuceneX receives the booking details you submit so that we can arrange the meeting.
Purpose: arrange an in-person discovery consultation (time and meeting place) and record it in our calendar.
Legal basis: Article 6(1)(b) GDPR — necessary to take steps at your request prior to entering a contract. We do not rely on consent for this necessary booking processing.
If you do not provide the details Google’s booking page requires, that booking channel cannot be completed. You may email info@lucenex.eu instead.
We do not ask for payment cards on lucenex.lv. Please do not send special-category data (for example health data) in booking answers (including the optional notes field) or email.
Google Workspace: we use Google Workspace (Gmail and Google Calendar). Google processes relevant data as our service provider (processor) under the agreement for those services. When you interact directly with Google-controlled services — for example the booking page on Google’s site, or while signed in to your own Google Account — Google may also process information independently under its own terms and privacy policy.
Optional marketing: we do not run a newsletter on the public site. If we later offer optional marketing, we will use Article 6(1)(a) consent where required, and you may withdraw it at any time.
4.2 Email
You can email info@lucenex.eu (including via a mailto link on the site). We process your address, your name if present, and the message content to correspond with you. Mail is provided through Google Workspace (Gmail).
Legal basis: Article 6(1)(b) where the message concerns a contract or steps prior to one; otherwise Article 6(1)(f) — handling genuine business correspondence. You may object under Article 21.
4.3 Client records
If you become a client, we process contact and billing details needed to perform the contract and to meet accounting and tax duties.
Legal basis: Article 6(1)(b) for the contract; Article 6(1)(c) where Latvian law requires us to keep accounting records (see section 6).
4.4 Website delivery
The public site is served through Cloudflare’s network so pages load securely and reliably.
Legal basis: Article 6(1)(f) — keeping the site available and secure.
4.5 What we do not do
We do not sell personal data. We currently do not transfer website consultation enquiries into a dedicated CRM system. We do not intentionally use analytics, advertising or other non-essential cookies or browser storage on lucenex.lv.
5. Recipients and transfers
5.1 Who we use
| Provider | Role | Typical data | Purpose |
|---|---|---|---|
| Cloudflare | Hosting / CDN for lucenex.lv | Connection and request data needed to deliver the site | Host and protect the website |
| Google Workspace (Gmail) | Email for info@lucenex.eu | Enquiry emails and replies | Business correspondence |
| Google Workspace (Google Calendar) | Appointment booking page, calendar invitations and calendar events | Booking details (name, email, phone, company name, preferred meeting address, optional notes) and event content | Discovery consultations |
| Public authorities | Where the law requires | As required | Legal obligation |
We do not give enquiry data to advertisers or data brokers.
Google processes Workspace data as our service provider (processor) under the agreement for those services. Cloudflare processes edge delivery data under Cloudflare’s applicable Data Processing Addendum and appropriate GDPR transfer safeguards.
5.2 Transfers outside the EEA
Some providers (including Cloudflare and Google) may process personal data outside the European Economic Area. Where that happens, we rely on an applicable adequacy decision (for example for certified US recipients under the EU–US Data Privacy Framework) or appropriate safeguards such as Standard Contractual Clauses, as required by GDPR Chapter V.
6. How long we keep personal data
- Unsuccessful enquiry or consultation that does not become a contract (including related Gmail threads and Google Calendar events): 12 months after the last message about that enquiry or after the session, if one was held, whichever is later. After that period, we delete or anonymise the data from the systems we control, subject to any applicable legal retention requirement and technical backup or retention mechanisms. This is LuceneX’s own retention policy, not a period fixed by statute. We carry it out through a monthly review of Gmail and Google Calendar.
- Client and accounting records: for the life of the contract and afterwards as required by Latvian accounting law (supporting documents are generally kept for at least five years).
- Website delivery (Cloudflare): we do not keep a separate LuceneX archive of CDN logs. Cloudflare may process connection data as needed to deliver and secure the site, for as long as its service and our enabled products require.
7. Cookies and similar technologies
We do not intentionally use analytics, advertising or other non-essential cookies or browser storage on lucenex.lv. Cloudflare may use strictly necessary technologies where required to deliver or protect the site.
When you open our Google Calendar booking link, you leave lucenex.lv and use a page on Google’s domain. Cookies or similar technologies on that page are Google’s: for example, Google sets its own cookies and loads Google reCAPTCHA with the booking form, under Google’s own policies. See Google’s Privacy Policy.
If we later add a non-essential cookie on lucenex.lv, we will ask for consent where the law requires it and update this notice.
8. Your rights
You may ask us to:
- access your personal data (Article 15)
- rectify it (Article 16)
- erase it (Article 17)
- restrict processing (Article 18)
- receive data you provided to us, in a portable form, where the basis is consent or contract and processing is automated (Article 20)
- object to processing based on legitimate interests (Article 21), including any direct marketing
- withdraw consent, where we rely on consent (for example future optional marketing)
Write to info@lucenex.eu. We may ask you to confirm your identity. We respond within one month. If the request is complex or numerous, the law allows an extension of up to two further months, and we will tell you if we use it.
Providing data is not a statutory requirement, but: to complete a booking through Google’s page you need to give the details that page requires; to email us you need to send a message we can reply to. Without contact details we cannot respond or book through those channels.
You may lodge a complaint with a supervisory authority, in particular where you live, work, or where you believe an infringement occurred (GDPR Article 77).
Our lead authority is:
Datu valsts inspekcija
Elijas iela 17, Rīga, LV-1050, Latvia
pasts@dvi.gov.lv
+371 67223131
You may complain to them without contacting us first. We would still like the chance to put things right.
9. Changes
If we start using personal data for a new purpose, we will inform you before we do so where Article 13(3) requires it. The date at the top of this page is the date of the current text.