Privacy Policy

1. Introduction

Welcome to the Privacy and Data Protection Policy ("Privacy Policy") of Raylight Solutions, Inc. ("Raylight", "we", "us", or "our"). We are a U.S. company and are committed to protecting and respecting your privacy and personal information in compliance with applicable U.S. federal and state laws (including California’s CCPA/CPRA) and, where relevant, the EU/UK GDPR for individuals located in the EEA or UK.

This Privacy Policy explains how we collect, process, and keep your information safe; your privacy rights and how the law protects you; and the obligations of our employees and service providers when processing personal information.

The individuals from whom we may gather and use personal information include customers, suppliers, and other people with whom we have a relationship or may need to contact. This Privacy Policy applies to all personal information processed by Raylight at any time.

1.1 Your Data Controller / Business

Raylight Solutions, Inc. is responsible for your personal information. For GDPR purposes, Raylight is the "data controller". For California residents, Raylight acts as a "business" under the CCPA/CPRA.

If you have questions about this Privacy Policy or our practices, please contact us at info@lucentchat.com.

If you are in the UK, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk. We would appreciate the chance to address your concerns before you contact a regulator, so please reach out to us first.

1.2 Processors and our responsibilities

In discharging our responsibilities as a controller/business, we may engage employees and third parties ("processors" or "service providers") to process data on our behalf. We and our processors will:

• Ensure processing is governed by an appropriate legal basis (see Section 2.2).
• Ensure authorized personnel are subject to confidentiality obligations.
• Implement appropriate technical and organizational measures for security.
• Obtain proper authorization before engaging any sub-processor/service provider.
• Assist with data subject rights requests where applicable.
• Maintain records of processing activities and cooperate with regulators where required.
• Notify the controller/business without undue delay upon becoming aware of a personal data breach.

2. Legal basis and scope of data we collect

2.1 Types of data

"Personal data" or "personal information" means any information that identifies, relates to, describes, or could reasonably be linked with an identifiable individual. We may collect, use, store, and transfer the following categories of information (not all categories apply to every user):

• Profile/Identity Data: first name, last name, gender, date of birth.
• Contact Data: email address, phone number, billing/shipping address.
• Marketing and Communications Data: your preferences for receiving communications.
• Technical Data: IP address, browser type/version, time zone and location, operating system and platform, device identifiers, and similar information.
• Customer Support Data: feedback, survey responses, and support interactions.
• Usage Data: information about how you use our website, products, and services.
• Aggregated Data: usage patterns, feature adoption rates, and anonymized performance statistics—e.g., how often users generate videos vs. images, or which AI models are most frequently used. Aggregated data does not identify you. If we combine or connect aggregated data with your personal data in a way that could identify you, we treat the combined data as personal data.
• Sensitive Data: We do not intentionally collect sensitive personal information unless necessary and disclosed to you (e.g., for fraud prevention). We do not collect criminal conviction data.

2.2 Legal bases (GDPR) and U.S. compliance

Where GDPR applies, we rely on the following lawful bases: (i) consent, (ii) contractual necessity, (iii) legal obligations, and (iv) legitimate interests (where your rights and interests do not override ours). In the U.S., we process personal information as permitted by applicable federal and state laws (including CCPA/CPRA).

3. How we use your personal information

We use your information to provide and improve services, personalize experiences, communicate with you, process payments and subscriptions, maintain safety and integrity, comply with legal obligations, and develop new features.

3.1 Marketing and content updates

If you opt in, we may send you marketing or product update communications. You may opt out at any time.

3.2 Change of purpose

We only use personal information for the purposes collected unless we reasonably determine we need to use it for another compatible purpose. If we need to use it for an unrelated purpose, we will notify you and explain the legal basis.

4. Your rights

Depending on your location, you may have rights under applicable data protection laws, including the right to be informed, access, rectification, erasure, objection, restriction, and data portability. To exercise rights, contact info@lucentchat.com.

If you are a California resident, you also have rights under the CCPA/CPRA, including the right to know, delete, correct, opt out of the sale or sharing of personal information, and limit the use and disclosure of sensitive personal information.

4.1 Your control over Raylight’s use of your data

You may delete your account at any time—this will remove your account page from our systems and related software. We guarantee this will delete all stored data. You can access information associated with your account by logging in.

Your account information is protected by a password. Please prevent unauthorized access by safeguarding your credentials and signing off after use.

California Privacy Rights: Under California Civil Code sections 1798.83–1798.84, California residents may request a notice identifying the categories of personal customer information that we share with affiliates and/or third parties for marketing purposes and the contact information for such entities. Please email info@lucentchat.com.

4.2 Data security

We implement technical and organizational measures to protect your information, including encryption in transit and at rest, HTTPS/TLS, access controls with role-based permissions, and infrastructure monitoring. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

4.3 Opting out of marketing

You can stop receiving marketing messages at any time by clicking "unsubscribe" in our emails. We may continue to send non-marketing communications related to your account or transactions.

4.4 How to request your data

You will not be charged for exercising your rights unless a request is manifestly unfounded. We may request information to verify your identity and may contact you for more details to expedite responses.

5. Your data and third parties

We may share personal information with service providers, contractors, and affiliates who support our services, and with interested parties in the event of a change in control, acquisition, or licensing of our technology. We may share information if required by law or to enforce our terms.

6. Data retention

We retain personal information only as long as reasonably necessary to fulfil the purposes we collected it for, including satisfying legal, regulatory, tax, accounting, or reporting requirements. We may retain it longer in case of a complaint or if litigation is reasonably anticipated.

7. International transfers

Your information may be stored and processed in the United States and other countries where we or our service providers operate. Where required, we use appropriate safeguards for international transfers.

8. Changes to this policy

We keep this Privacy Policy under review and will post updates here. This version is dated October 20, 2025. By using our services, you consent to the collection and use of your data as set out in this Privacy Policy. Continued access or use will constitute your acceptance of any modifications.

9. Interpretation

All uses of the word "including" mean "including but not limited to." Any email addresses set out in this policy may be used solely for their stated purpose. Unless otherwise required by law, we reserve the right not to respond to emails even if they relate to a legitimate subject matter. Our staff are not authorized to contract on behalf of Raylight Solutions, Inc., waive rights, or make representations unless expressly stated by our legal department.

10. Terms of Use

Please also see our Terms of Use (/terms) which set out the terms, disclaimers, and limitations of liability governing your use of Raylight Solutions, Inc.