Legal

Privacy Policy

Last updated: 3 August 2026

Cold by LUCA ("Cold", "we", "us" or "our") is an independent commercial intelligence and consultancy practice.

This Privacy Policy explains what information we collect, how we use it and how you may contact us regarding your information.

01

Information collected through our website

Our website contains an inquiry form. When you submit the form, we collect:

  • your name;
  • your company email address; and
  • your company website.

We use this information to understand your inquiry, review your company and contact you regarding Cold by LUCA's services.

Please do not submit passwords, payment information, identification documents, health information or other sensitive personal information through the form.

02

Information processed through our internal system

Cold by LUCA operates an internal commercial intelligence and data-storage system. When a user explicitly approves saving a completed company diagnosis, the system may store:

  • company name and website;
  • industry and business model;
  • diagnosis date;
  • commercial findings and interpretations;
  • what company leadership may be reading incorrectly;
  • where the company may need to focus first;
  • identified commercial consequences;
  • supporting facts, calculations and benchmarks;
  • source links;
  • confidence and internal-validation requirements; and
  • a report link, where applicable.

This information generally concerns companies and publicly available commercial information rather than private information about individuals.

A diagnosis is only saved after the user approves the saving action.

03

How we use information

We may use collected information to:

  • respond to inquiries;
  • contact potential or existing clients;
  • provide commercial diagnosis and consultancy services;
  • maintain records of completed diagnoses;
  • preserve the evidence supporting each diagnosis;
  • identify and compare commercial patterns across companies;
  • develop commercial benchmarks;
  • improve Cold by LUCA's methodology;
  • conduct commercial intelligence research; and
  • develop and improve our products and services.

We may use aggregated, anonymised or company-level commercial insights in future research, reports, benchmarks and intelligence products.

We will not knowingly publish confidential information submitted by a user without authorisation.

04

Service providers

We use third-party AI, automation, website-hosting and cloud-storage providers to operate our website and internal systems.

These providers may process information on our behalf where necessary to provide their services.

We do not sell personal information.

05

When information may be shared

We may share information:

  • with service providers required to operate our systems;
  • with authorised Cold by LUCA personnel, advisers or contractors;
  • where required by law or legal process;
  • in connection with an investment, acquisition, restructuring or sale of the business; or
  • where necessary to protect our rights, systems or users.
06

Data retention

We retain inquiry information for as long as reasonably necessary to respond to the inquiry, maintain business records and manage potential or existing client relationships.

Company diagnoses may be retained for as long as they remain useful for Cold by LUCA's research, benchmarking, commercial intelligence and business purposes.

Aggregated or anonymised information that no longer identifies an individual may be retained.

07

Security

We use reasonable administrative and technical measures to protect the information under our control.

However, no method of electronic transmission or storage can be guaranteed to be completely secure.

08

International processing

Our service providers may store or process information in countries outside the country where you are located.

09

Your rights and choices

Depending on where you are located, you may have the right to request access to, correction of or deletion of personal information held about you.

Please provide enough information for us to identify the relevant inquiry, company or diagnosis.

10

External websites

Our website, reports or internal systems may contain links to external websites and public data sources.

We are not responsible for the privacy practices, security or content of those external websites.

11

Changes to this policy

We may update this Privacy Policy when our services, systems or data practices change.

The latest revision date will appear at the top of this page.

12

Contact

Questions about this Privacy Policy, or requests to access, correct or delete personal information, may be submitted through our LinkedIn page:

Cold by LUCA on LinkedIn