Privacy Policy

Effective Date: December 16, 2025 Last Updated: December 16, 2025

1. Introduction

This Privacy Policy describes how Luther Systems collects, uses, and protects personal information. It applies to:

Luther Systems US Incorporated ("Luther US"), located in the United States.
Luther Systems Limited ("Luther UK"), located in the United Kingdom.

Unless otherwise stated, references to "Luther Systems," "we," "us," or "our" refer to both Luther US and Luther UK.

2. Scope

This policy applies to personal information collected when you:

Visit our websites, including luthersystems.com
Use our platform or services
Contact us, request information, or interact with us as a customer, partner, or vendor

This policy does not apply to third-party websites that may be linked from our site. It also does not cover data that we process solely as a service provider on behalf of our customers, which is governed by our customer agreements.

3. Personal Information We Collect

We may collect the following categories of personal information:

Contact Information: Name, email address, mailing address, phone number, job title, company name
Account Information: Username, password, account preferences
Usage Data: IP address, browser type, device information, pages visited, referring URLs
Communications: Information you provide through support inquiries, contact forms, or other communications

We do not collect biometric data.

4. How We Use Personal Information

We use personal information for the following purposes:

Providing, operating, and maintaining our services
Improving user experience and website functionality
Communicating with you, including responding to inquiries
Complying with legal obligations and enforcing our terms

We do not sell personal information, and we do not share personal information with advertisers for advertising purposes.

We may share personal information with:

Service Providers: Third-party vendors who assist us with business operations, subject to confidentiality obligations
Legal Authorities: When required by law, regulation, or legal process
Business Transfers: In connection with a merger, acquisition, or sale of assets

6. Data Privacy Framework (DPF) Notice

Luther Systems US Incorporated complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce.

Types of Data Collected: As described in Section 3
Purposes of Processing: As described in Section 4
Onward Transfers: Luther Systems remains liable under the DPF Principles if agents process personal data in a manner inconsistent with the Principles, unless we prove we are not responsible for the event giving rise to the damage
Government Access: We may be required to disclose personal information in response to lawful requests by public authorities, including national security or law enforcement requirements
Enforcement: Luther Systems US Incorporated is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)

7. Your Rights and Choices

Access, Correction, and Deletion: You have the right to access, correct, amend, or delete your personal information. To make a request, contact privacy@luthersystems.com.

Choice (Limiting Use and Disclosure): You may opt out of:

Disclosure of your personal information to third parties (other than our service providers)
Use of your personal information for a purpose that is materially different from the purpose for which it was originally collected

To exercise these choices, email privacy@luthersystems.com.

8. Complaints and Dispute Resolution

EU and UK individuals with inquiries or complaints regarding our handling of personal data should first contact Luther Systems US Incorporated at:

Email: privacy@luthersystems.com

Mail: Sam Wood, Luther Systems US Incorporated, 1875 S Bascom Ave, #2400, Campbell, CA 95008-2356

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.bbbprograms.org/dpf-complaints.

Under certain conditions, more fully described on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

9. Contact Us

Email: contact@luthersystems.com or privacy@luthersystems.com

US Office: 1875 S Bascom Ave, #2400, Campbell, CA 95008-2356

UK Office: Office 122, Epworth House, 25 City Road, EC1Y 1AA, London, United Kingdom