legal

Privacy policy.

We want to be straightforward about what data we collect, why we collect it, and what we do with it. This policy covers everyone who uses loocy — students, companies, and visitors to our website.

This is a working draft. loocy is in pilot phase and this policy will be reviewed by a qualified solicitor before the platform launches publicly. If you have questions in the meantime, email hello@loocy.io.
01

Who we are

loocy is operated by [Loocy Ltd], a company registered in England and Wales. We are the data controller for personal information collected through the loocy platform and website.

Registered address: [to be confirmed on incorporation]
ICO registration: [to be confirmed]
Contact: hello@loocy.io

This policy applies to the loocy website at loocy.io and all services provided through the platform, including student accounts, company accounts, problem submissions, portfolio tools, and the loocy AI assistant.


02

What we collect

For students, we collect:

DataHow collectedWhy
Name and email addressAt signupAccount creation and communication
University, degree, graduation yearDuring onboarding or profile setupTo show on your profile to companies
Career path and specialism preferencesDuring onboardingTo recommend problems and track your progress
Problem submissions and written responsesWhen you submitFor AI scoring; shared with a company only if you choose to
AI scoring resultsGenerated automaticallyTo populate your portfolio and provide feedback
CV and work experienceOptionally uploaded by youTo display on your loocy profile
loocy AI chat conversationsWhen you use the AI thinking partnerTo provide the service and improve AI responses
Usage data (pages visited, time on site)Automatically via cookiesTo understand how the platform is used and improve it

For companies, we collect:

DataHow collectedWhy
Company name, industry, size, websiteDuring onboardingCompany profile and matching
Contact name, job title, work emailDuring onboardingAccount management and communication
Problem briefs and rubric session answersWhen posting a problemTo score submissions and generate shortlists
Shortlist decisions (contacted, declined)When reviewing the shortlistTo operate the platform
Usage dataAutomatically via cookiesPlatform improvement

We do not collect sensitive personal data (race, ethnicity, health, religion, sexual orientation) and our platform is not designed to capture it. If you include such information in a problem submission, CV, or message, it will be stored as part of that content.


03

How we use it

We use the personal data we collect for the following purposes:

To operate the platform — creating and managing accounts, processing problem submissions, running AI scoring, generating shortlists, and enabling company-to-student contact.

To provide feedback to students — sharing scored responses, criteria breakdowns, and AI-generated scoring notes with the student who submitted them.

To show companies shortlisted candidates — when a hiring manager reviews a shortlist, they can see a student's name, university, career path, scores, the strengths and weaknesses of their answer, capability graph, and loocy profile. A student's full answer is never shared unless they choose to share it, and contact details are only shared once they accept an invitation.

To improve the platform — we use aggregated, anonymised usage data to understand how loocy is used and make it better. We do not use individual submissions or responses to train AI models without explicit consent.

To communicate with you — account notifications, shortlist alerts, submission confirmations, and product updates. We will not send marketing communications without your consent.

To comply with our legal obligations — record keeping, fraud prevention, and responding to lawful requests.

A note on AI scoring. loocy uses the OpenAI API to score student submissions against company rubrics. Your submission is processed by a third-party AI model. It is not stored by OpenAI for training purposes under our current agreement. The scoring output (criteria scores and notes) is stored by loocy and shown to both the student and the company.


05

Who we share it with

Companies using loocy — when a company posts a problem you respond to, they receive your scores, the strengths and weaknesses of your answer, your capability graph, and your profile (name, university, career path, portfolio entries, specialism). Your full answer is shared only if you choose to share it, and your email address is not shared until you accept their invitation.

Technology providers — we use the following third-party services to operate the platform. Each is bound by data processing agreements:

ProviderPurposeLocation
SupabaseDatabase, authentication, and server functionsEU / UK
OpenAIAI scoring and loocy AI chatUSA (Standard Contractual Clauses apply)
VercelWebsite hostingEU / USA (SCC apply)

We do not sell personal data. We do not share personal data with advertisers or data brokers. We do not use your data for targeted advertising.

Legal requirements — we may disclose personal data if required to do so by law, regulation, court order, or to protect the rights and safety of our users.

Business transfers — if loocy is acquired or merged with another company, personal data may be transferred as part of that transaction. We will notify users before any such transfer takes effect.


06

How long we keep it

We keep personal data for as long as it is needed to provide the service and for the periods set out below:

Data typeRetention period
Student account dataFor the duration of the account, plus 2 years after deletion request
Problem submissions and scoresFor the duration of the account. Removed on account deletion.
Company account and problem dataFor the duration of the account, plus 6 years (legal record-keeping)
loocy AI chat logs90 days, then automatically deleted
Usage and analytics data24 months, then aggregated and anonymised
Email communications3 years from last contact

You can request deletion of your account and personal data at any time. See Your Rights below.


07

Security

We take reasonable technical and organisational measures to protect your personal data against loss, misuse, and unauthorised access. These include:

Encryption of data in transit (TLS) and at rest. Access controls ensuring only authorised personnel can access personal data. Authentication requirements for all platform accounts. Regular review of our data handling practices.

No method of electronic transmission or storage is 100% secure. If you believe your account has been compromised, contact us immediately at hello@loocy.io.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and affected individuals without undue delay, as required by UK GDPR.


08

Your rights

Under UK GDPR, you have the following rights in relation to your personal data:

Right of access
You can request a copy of the personal data we hold about you.
Right to rectification
You can ask us to correct inaccurate or incomplete personal data.
Right to erasure
You can ask us to delete your personal data. We will comply unless we have a legal obligation to retain it.
Right to restrict processing
You can ask us to pause processing your data in certain circumstances.
Right to data portability
You can request your data in a structured, machine-readable format.
Right to object
You can object to processing based on legitimate interests or for direct marketing.
Right to withdraw consent
Where we process data on the basis of consent, you can withdraw that consent at any time.

To exercise any of these rights, email hello@loocy.io with your name, email address, and what you are requesting. We will respond within one month.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.


09

Cookies

We use cookies and similar technologies to operate the platform and understand how it is used. The cookies we use fall into the following categories:

CategoryPurposeCan you opt out?
EssentialLogin sessions, security, platform functionalityNo — the platform cannot function without these
AnalyticsUnderstanding how the platform is used (page views, session length)Yes — via cookie preferences
PreferencesRemembering your settings and preferencesYes

We do not use advertising or tracking cookies. We do not use your browsing behaviour to serve you targeted ads.

A full cookie notice will be added before the platform launches publicly.


10

Children

loocy is not directed at children under the age of 16. We do not knowingly collect personal data from anyone under 16. If you believe a person under 16 has provided us with personal data, please contact us at hello@loocy.io and we will delete it promptly.


11

Changes to this policy

We may update this privacy policy from time to time. When we make changes, we will update the "last updated" date at the top of the page. If the changes are significant, we will notify you by email or by a prominent notice on the platform before the changes take effect.

The most current version of this policy is always available at loocy.io/privacy.


12

Contact us

If you have any questions about this privacy policy or how we handle your personal data, please contact us:

Email: hello@loocy.io
Subject line: Privacy enquiry
Address: [Loocy Ltd, registered address — to be confirmed]

We will respond to all privacy enquiries within one month.