Privacy policy
Last updated: 10 October 2026
This page explains what personal data LUCA collects, why, where it is kept, which other companies handle it, and the rights you have under India’s Digital Personal Data Protection Act, 2023. It covers this website, lucatwin.com, and the LUCA app at app.lucatwin.com (the app shows the name LUCA OS when you sign in). It describes only what LUCA does today. When that changes, this page changes first.
Who we are
LUCA is made by LUCAVERSE PRIVATE LIMITED, Hyderabad, India (CIN U62099TS2026PTC211908; registered office: 7-2-1795/C-10, Street No. 2, CEZH Colony, Sanath Nagar, Hyderabad, Telangana 500018). For your personal data, LUCAVERSE is the “Data Fiduciary” under the Act. The one exception is the work data a company puts into its own twin: there the company decides, and LUCAVERSE handles the data for it under a written agreement (see If you use LUCA through a company).
For questions, requests and complaints, write to grievance@lucatwin.com. The founder, Uma Mahesh Rajanala, reads this mailbox and answers for LUCAVERSE.
What we collect, and why
| What | When | Why |
|---|---|---|
| Your name and age; if you choose to give them, your gender, occupation and area PIN code | When you create a personal twin. You need an invite code; without one you can join a waiting list with your name and age. | To set up your twin, and to check that you are 18 or older |
| Your sign-in details | When you sign in | To keep your account yours |
| What you tell your twin and what it answers: messages, voice messages, and the pictures and documents you share | When you use LUCA | So your twin can answer you and remember what matters to you |
| Accounts you choose to connect, such as Gmail or WhatsApp | Only if you connect them | So your twin can read them and help with them. You can disconnect them at any time. |
| Work records, if you use LUCA through a company: the bookings, quotes and messages you handle | When you work in your company’s twin | So the company’s twin can do its job. The company decides this. |
| Visit details on this website: the page, the time, the page you came from, your browser and device, and your approximate city, region and internet provider | When you visit the website | To see how the website is used. Our server turns your IP address into a coded name and does not store the IP address itself. |
| What you write in the website’s contact form | When you send it | To answer you |
| The e-mails you send us | When you write to us | To answer you |
We do not sell personal data, and we do not use it for advertising.
How LUCA’s AI uses your data
LUCA writes its answers with the help of AI models run by other companies. When your twin answers, it sends the text it needs (your question, the notes it recalls for the answer, and a picture if you sent one) to OpenRouter (United States). OpenRouter passes the request to an AI model company: today Google, OpenAI, Perplexity (for a personal twin’s web searches), or DeepSeek and Qwen models run by hosts outside China. Every request asks the model’s host to keep no copy and not to use the data (zero data retention).
Before sending, LUCA hides e-mail addresses, phone numbers, card-like numbers, Aadhaar and PAN numbers and IP addresses. Names are not hidden. If those services do not answer, a personal twin may be answered by a small AI model on our own server in India.
To check and improve the quality of answers, we keep a record of the questions and answers of personal twins on our own server. It is not given to any other company. A company seat’s conversations are not added to it.
If you use voice, your voice messages, and the answers read aloud to you, go to ElevenLabs (United States), which turns speech into text and text into speech. ElevenLabs may keep this data for a time under its own terms.
Your private notes
Your private notes are kept on LUCA’s server in Mumbai, India, not only on your phone or computer. LUCA shows them only to you. Your twin can use them when it answers you, and then the text it needs goes to the AI service described above. People at LUCAVERSE can reach the server to keep LUCA running, so we do not promise that no one at LUCAVERSE could ever see stored data.
If you use LUCA through a company
When a company (for example, a business that uses LUCA for its bookings) invites you to its twin:
- The company decides what its twin is used for and is responsible for the work data. LUCAVERSE handles that data for the company under a written agreement.
- The company’s admin can see the company’s records. Each person’s own private notes are walled off from the other staff.
- A company seat always uses paid AI models that keep no copy: never a free model, and never the model on our own server.
- LUCAVERSE’s central system learns only anonymous patterns from a company’s twin, such as counts and what works. It never takes the twin’s content, names or numbers.
- To be deleted when you leave, see Delete my data: your own private notes are erased; your work chats are the company’s records and stay with the company.
Where your data is kept
On LUCA’s server and its backup copies at Amazon Web Services, Mumbai, in India. Some data goes outside India to the companies listed below, only for the purposes given.
Other companies that handle personal data for LUCA
| Company | What it does | Where |
|---|---|---|
| Amazon Web Services | Runs LUCA’s server and keeps its backup copies | India (Mumbai) |
| Cloudflare | Delivers this website and the app, carries the traffic between your browser and our server, and forwards e-mail sent to us | Its worldwide network (a US company) |
| OpenRouter, and the AI model companies named above | Writes the answers | The United States and other countries outside India, never China. Each is asked to keep no copy. |
| ElevenLabs | Voice, only if you use it | United States |
| Telegram | Notices and alerts, if you use LUCA on Telegram; and alerts to us about visits to this website (your approximate city, internet provider and device, and the pages you saw) | Outside India |
| E-mail you send us arrives in our Gmail. This website loads its fonts from Google, which sees your IP address. Your Gmail, only if you connect it. | United States | |
| Composio | Keeps the connection to accounts you choose to connect, such as Gmail | United States |
| WhatsApp (Meta) | Only if you link your WhatsApp to your twin | Outside India |
Each of them handles data under its own terms. When we add a company, we add it to this list first.
How long we keep data
- While your account is open, we keep what your twin needs to work for you.
- When you ask us to delete your data, it is hidden at once and deleted after 30 days, unless you cancel. See Delete my data.
- Our backup copies are kept for a period we are setting now. When it is set, this page will say how long.
- We keep a short record that a deletion was asked for and done, with none of your content, so that we can show we did it.
Your rights
Under the Act you can:
- Get a summary of your personal data, and of whom we shared it with: write to grievance@lucatwin.com and we send you a copy in a common file format.
- Correct or complete it: in the app’s profile, or by writing to us.
- Delete it: see Delete my data.
- Withdraw your consent at any time: with the Privacy link at the bottom of the app, or by writing to us. From then on we stop processing that data and delete it, unless the law requires us to keep it. Withdrawing does not undo what was done before.
- Nominate someone to act for you if you die or cannot act: write to us with their name and contact.
- Complain: write to grievance@lucatwin.com. We acknowledge within 72 hours and answer within 30 days. If you are not satisfied with our answer, you can complain to the Data Protection Board of India.
Children
LUCA is for people aged 18 and over. Sign-up asks your age and refuses anyone under 18. If you think a child has given us personal data, write to us and we will delete it.
Security
We use encrypted connections (HTTPS) everywhere. The keys LUCA uses for connected accounts are kept in an encrypted vault. Each person’s records in a company’s twin are walled off from the other staff. Only LUCAVERSE’s operators can reach the server. No system is perfectly safe: if a breach affects your personal data, we will tell you and the Data Protection Board of India as the law requires.
This website and your browser
This website uses no advertising and no outside analytics service. It keeps a random visitor code in your browser’s storage so that we can count return visits; you can clear it at any time in your browser’s settings. The app keeps your sign-in in your browser’s storage so that you stay signed in.
Changes to this policy
When we change this policy, we update this page and the date at the top. If a change affects how we use your personal data, we tell you before it applies.
Contact
grievance@lucatwin.com · LUCAVERSE PRIVATE LIMITED, Hyderabad, Telangana, India.