Privacy Policy

Last updated: 2026-02-13

This Privacy Policy explains how Edencrew Inc. (“Edencrew,” “we,” “us”) collects, uses, and shares personal data across our ecosystem, including the Lucy Studio web platform and the Lucy Player mobile application (collectively, the “Services”).

1. Controller and Contact

Controller: Edencrew Inc.
Address: 1015, Building A, Saenggakgongjang Dangsan, 150 Yeongdeungpo-ro, Yeongdeungpo-gu, Seoul, Republic of Korea
Email: contact@edencrew.com

2. EU/EEA Users and EU Representative

Edencrew is not established in the EU/EEA. Where required under applicable law (Article 27 GDPR), Edencrew will appoint an EU representative and update this Policy with their contact details.

3. Personal Data We Collect

We collect data through two primary channels: Direct Account Interaction and Mobile Hardware Permissions.

A) Account and Identity Data (Lucy Studio & Player)

Required: Email, Password (stored in hashed form).
Optional: Name, Company (depending on your signup flow).

B) Mobile Device Permissions (Lucy Player Specific)

Camera Access: Lucy Player requests access to your device’s camera.
Purpose: To scan QR codes provided by Lucy Studio to establish a real-time development link.
Data Handling: Camera processing is performed locally and ephemerally on your device. We do not record, store, or transmit images, videos, or facial data to our servers.
Device Data: We may collect IP addresses, timestamps, and device/browser information for security events and abuse prevention.

C) Support Communications

Records of messages and information sent to our support team.

4. How We Use Personal Data and Legal Bases

We process personal data under the following legal bases:

Contractual Necessity: To provide core features, account management, and real-time syncing between Studio and Player.
Legitimate Interests: To secure our Services, prevent fraud, and maintain app stability.
Consent: For non-essential cookies or analytics (e.g., Google Analytics).
Legal Obligation: To comply with law enforcement or regulatory requests.

5. Cookies and Analytics

We use Google Analytics for usage measurement. Where required by law, we will request your explicit consent before enabling non-essential trackers. If you do not consent, analytics will remain disabled.

6. Sharing and Processors

We share data with trusted processors to operate our services:

Cloud Hosting: To store account data and host Lucy Studio.
Email Providers: For password resets and service notices.
Analytics: Google Analytics (if consent is provided).

We do not sell your personal data to third parties.

7. International Transfers

As a South Korean company, data may be processed in the Republic of Korea. We intend to host EU user data primarily in the EU. For any cross-border transfers, we rely on valid transfer mechanisms such as Standard Contractual Clauses (SCCs).

8. Data Retention

Account Data: Retained while your account is active.
Deletion: Upon a verified request, data is deleted or anonymized within 30 days.
Exceptions: Backups are cleared within 90 days; security logs are kept for up to 12 months for fraud prevention.

9. Your Rights (GDPR / AEPD)

You have the right to access, rectify, delete, and port your data, as well as the right to object to or restrict processing. To exercise these rights, contact