Legal

Privacy Policy

Last updated: 4 July 2026

This Privacy Policy explains how we collect, use, and protect personal data on lukeni.io — the Lukeni platform and institutional site, including Discovery Ground, self-serve partner page creation, and pages published under /p/.

This policy does not cover stinmnimi.gr or the stinmnimi application, which is a separate consumer product with its own Privacy Policy governing family submissions, memorial content, and payment for a memorial biography. If you are a family creating a memorial, please refer to stinmnimi.gr's own Privacy Policy instead.

1. Data Controller

For the purposes of the GDPR, the data controller for lukeni.io is:

ThemisNexus OÜ, a company registered in Estonia.
Contact: hello@lukeni.io

2. Who This Applies To

• Visitors browsing lukeni.io
• Community-organisation representatives using Discovery Ground
• Organisations creating a self-serve page (community organisations, funeral homes)
• Anyone contacting us directly

3. Personal Data We Collect

Discovery Ground

The community and generation you select to preview our historical record are not personal data. If you request the full portrait, we collect the name, organisation, role, and email address you provide, along with any optional town or region of origin you type in, and only with your explicit consent.

Creating a page

To create and secure a self-serve partner account, we collect an email address and password; your organisation's name, city, country, and type; an optional logo image you upload; draft tagline and about-page text (initially AI-drafted, then edited by you); and the page address you choose. If you connect an account to receive donations, we store a reference to that connected account. Your banking and identity details are entered directly with our payment and payout provider and never reach our servers.

General enquiries

Anything you choose to send to hello@lukeni.io.

Collected automatically

Standard web request logs — IP address, browser and device information, pages requested — collected by our hosting provider for security and operational purposes.

Public memorial information shown on partner pages

A partner page may display the name, birth and death year, and place of a deceased person whose family has separately chosen, on stinmnimi.gr, to make that memorial public. That choice, and how it is handled, is governed by stinmnimi.gr's own Privacy Policy; we display only what a family has already elected to make public.

4. Legal Bases for Processing

• Consent — Discovery Ground lead details, and any follow-up about the partner programme
• Contractual necessity — creating and operating your partner account and page, connecting a payout account
• Legitimate interests — security, fraud prevention, keeping the site running, responding to enquiries
• Legal obligation — where record-keeping or disclosure is required by law

5. How AI Is Used

We use a third-party AI language-processing service to assemble the historical passage shown by Discovery Ground and to draft an initial tagline and about-paragraph for new partner pages. Only the inputs you provide for that specific request — such as community, generation, organisation name, city, and type — are sent for that purpose. The underlying research corpus, prompts, and analytical methodology behind Lukeni are proprietary and are not disclosed as part of this processing.

6. Who We Share Data With

We share data, as needed to run the service, with the following categories of provider — never with data brokers or third-party advertisers:

• A database and authentication infrastructure provider, to store account and page data securely
• An AI language-processing provider, as described above
• A payment and payout processing provider, to operate donation transfers to partner organisations — your use of this feature is additionally governed by that provider's own terms, since they hold your banking details directly
• A web hosting provider, to serve the site and retain basic security logs

We do not sell personal data.

7. International Data Transfers

Some of the providers above may process data outside the EU/EEA. Where that happens, we rely on providers that offer appropriate contractual and security safeguards.

8. Data Retention

• Discovery Ground leads are kept while we may reasonably follow up on your enquiry, or until you ask us to delete them
• Partner accounts and pages are kept for as long as the account is active, plus a reasonable period afterward for accounting and fraud-prevention purposes
• Automatically collected logs are kept for a limited operational period

9. Security Measures

We apply technical and organisational measures — access controls, encrypted transport, and limiting who can reach production data — appropriate to the data involved. No system is completely secure, and we do not promise more than we can honour.

10. Your GDPR Rights

If you are located in the EU/EEA, you have the right to access your personal data, request rectification of inaccurate data, request erasure, restrict or object to processing, request data portability, and withdraw consent at any time. To exercise any of these rights, email hello@lukeni.io.

11. Complaints

You have the right to lodge a complaint with your local data protection authority, or with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), if you believe your rights have been infringed.

12. Cookies

lukeni.io does not currently use advertising or third-party tracking cookies. Signing in to create a page relies on strictly necessary browser storage to keep you signed in. If this changes, this policy will be updated first.

13. Children

lukeni.io is not directed at children. Partner accounts are intended for adults representing an organisation.

14. Changes to This Policy

We may update this Privacy Policy from time to time. The date at the top reflects the most recent revision; material changes will be noted here.

15. Contact

For privacy-related questions or requests: hello@lukeni.io