Privacy Policy

Lukkio is operated by Property Raptor UK Limited, a company registered in England and Wales under company number 14043258, whose registered office is at Zeeta House, 200 Upper Richmond Road, London SW15 2SH ("we", "us"). This policy explains how we collect and use personal data through our website (lukkio.com), the Lukkio web app and the Lukkio mobile apps. For the personal data described in it, we are the controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For your account. When you visit our website, sign up, pay or contact us, we decide how your personal data is used, and this policy applies in full.

For your clients' data. Agencies use Lukkio to keep records about their own clients and prospects. For those records, the agency is the controller and decides how the data is used, and we are its processor: we process the data only on the agency's instructions, under the Data Processing Schedule in our Licensing Agreement. If you are a client of an agency that uses Lukkio and want to see, correct or delete your data, please contact that agency. If you contact us, we will pass your request to them.

• Account details: your name, work email, phone number, company name, market, role, team size, and a secure hash of your password.
• Billing details: billing address, plan, seats, add-ons, invoices and payment status. Card details are entered directly with Adyen, our payment provider. We keep only the card brand, last four digits, expiry and a payment token.
• Records you create: listings, contacts, deals, viewings, activities, campaigns, notes and files, which include personal data about your own clients.
• Lukkio Assistant: the questions you ask, the answers it gives, and your voice input when you use dictation or Talk. Voice input is converted to text to answer you [confirm whether audio is stored, and for how long].
• Connected accounts: if you connect WhatsApp, an email account or a property portal, the messages, leads and contact details that pass through that connection.
• Usage and device data: pages and features used, times, IP address, browser and device type, app version, push notification tokens, crash reports and error logs.
• Website data: information about your visit to lukkio.com, collected through cookies and analytics tools as described in section 10.
• Messages to us: anything you send us by email, chat or through the app.

You must give us your account and billing details to use Lukkio. If you do not, we cannot open or run your account. Everything else is optional or depends on the features you use.

• To provide Lukkio, show you your records, and run the features you use, including the AI features.
• To take payment, issue invoices and manage your subscription.
• To send service messages, such as trial reminders, renewal and payment notices, security alerts and changes to our terms.
• To answer your questions and provide support.
• To keep Lukkio secure, prevent fraud and abuse, and find and fix faults.
• To understand how Lukkio and our website are used, and to improve and develop our products, using aggregated or de-identified data where we can.
• To send direct marketing, only with your consent (section 5).
• To comply with the law and enforce our agreements.

Our legal bases under the UK GDPR are:

• Contract: to provide Lukkio, run your account and take payment.
• Legitimate interests: to keep Lukkio secure, prevent fraud and abuse, find and fix faults, understand how our products are used and improve them, and answer your messages, where those interests are not outweighed by your rights.
• Legal obligation: to keep billing and tax records and to respond to lawful requests from authorities.
• Consent: to send direct marketing and to use analytics and marketing cookies. You can withdraw consent at any time.

We would like to use your name, email address, phone number and company name to send you news, offers, events and invitations about Lukkio and other property technology products and services offered by Property Raptor UK Limited. We will not do this unless you have given your consent, separately from accepting our terms, for example by ticking the marketing box when you sign up. We do not give your data to anyone else for their own marketing.

You can withdraw your consent at any time, free of charge, by using the unsubscribe link in any marketing email or by writing to hello@lukkio.com. Service messages about your account are not marketing and will continue while you have an account.

• Service providers who run parts of Lukkio for us: cloud hosting and infrastructure, AI model providers, email delivery, payment processing (Adyen), customer support tools and, on our website, analytics. AI model providers receive only the text needed to produce a result, and we use them under business terms that do not allow them to use it to train their models.
• Services you choose to connect, such as property portals, Meta for WhatsApp, and your email provider. They receive what you send through them.
• Our affiliates in the IMS group, to help us run, support and develop Lukkio.
• Professional advisers, such as lawyers, auditors and insurers, where needed.
• A buyer or successor, if all or part of our business is sold or reorganised, under the same protections.
• Authorities, courts and regulators, where the law requires or to protect our rights.

We do not sell personal data.

We and our service providers may process personal data outside the United Kingdom. When personal data leaves the UK, we send it only to countries the UK recognises as giving adequate protection, or we protect it with the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

We keep account and workspace data while your subscription is active. When a subscription is cancelled or ends unpaid, the workspace is suspended and its data is archived for 180 days, then deleted unless you reactivate. Billing and tax records are kept for as long as tax and accounting laws require, which in the UK is normally six years. Logs are kept for up to 12 months. Marketing consent records are kept for as long as we need to show that you consented. Deleted data is removed from backups on our normal backup cycle.

We protect personal data with measures appropriate to the risk, including encryption in transit and at rest [confirm at rest], access controls, and limited, logged access by our staff [confirm logging]. No system is completely secure. If we become aware of a breach that is likely to affect you, we will tell you without undue delay, and we will report it to the Information Commissioner's Office (ICO) within 72 hours where the law requires.

Cookies are small files stored on your device. We use them, and similar technologies such as local storage, as follows.

Before we use analytics or marketing cookies, we will ask for your consent, as the Privacy and Electronic Communications Regulations (PECR) require. A cookie banner lets you accept or refuse them, and a cookie settings link lets you change your choice later. You can also block or delete cookies in your browser settings, although parts of the app may then stop working. Google explains how it uses data from sites that use its services at policies.google.com/technologies/partner-sites.

You can see, correct, export or delete most of your data in the app at any time. Under the UK GDPR you also have the right to ask us for a copy of the personal data we hold about you, to have it corrected or erased, to restrict or object to how we use it, to receive it in a portable format, and to withdraw any consent you have given.

To make a request, write to the Data Protection Officer at the address below. We will reply within one month, as the UK GDPR requires. If a request is complex, or you send us several, we may extend this by up to two further months, and we will tell you within the first month if we do. We may ask you to confirm your identity. Making a request is free, unless it is manifestly unfounded or excessive. If you are not satisfied with our answer, you can complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk, or to the data protection authority where you live.

Lukkio is a business service for people aged 18 and over. We do not knowingly collect personal data from children.

We will post any change to this policy on this page and update the date at the top. If a change is material, we will email account owners before it takes effect.

Data Protection Officer, Property Raptor UK Limited, registered in England and Wales, company number 14043258. Registered office: Zeeta House, 200 Upper Richmond Road, London SW15 2SH. Email hello@lukkio.com.