Privacy Policy

Last updated: July 2026

1. Introduction

This Privacy Policy describes how thinking oracle inc ("thinking oracle," "we," "us," or "our") collects, uses, and shares information about you when you access or use our websites, applications, and related services (collectively, the "Services").

By using the Services, you agree to the collection and use of information in accordance with this Policy. If you do not agree, you should not use the Services.

2. Information we collect

We may collect the following categories of information:

Information you provide

• Account data (name, email address, password, profile details)
• Optional demographic or preference information you choose to share
• Content you submit (applications, forms, messages, feedback)

Information collected automatically

• Log data (IP address, browser type, device identifiers, pages viewed, timestamps)
• Usage data (features you use, clicks, time on page, session metadata)
• Cookies and similar technologies used for authentication, preferences, analytics, and security

Information from third parties

• If you connect a third-party account (e.g., OAuth provider), we may receive identifiers and basic profile information as permitted by that service
• Service providers may provide aggregated or pseudonymous data about your interactions

We do not knowingly collect information from children under the age required by applicable law.

3. How we use information

We use the information we collect for purposes including:

• Providing the Services: Creating and managing accounts, delivering features and functionality
• Improving the Services: Monitoring usage and performance, debugging, preventing fraud
• Communicating with you: Sending transactional messages, responding to support requests
• Research and development: Understanding how users interact with the Services, developing new features
• Legal and compliance: Complying with applicable laws and regulations

4. How we share information

We may share information in the following ways:

• Service providers: Third parties that perform services on our behalf (hosting, analytics, email delivery)
• Legal and safety: When disclosure is reasonably necessary to comply with the law or protect rights and safety
• Corporate events: In connection with a merger, acquisition, or similar transaction

We do not sell your personal information for monetary consideration.

5. Cookies and similar technologies

We use cookies, web beacons, and similar technologies to:

• Authenticate users and maintain sessions
• Remember preferences and settings
• Analyze usage and performance

You can configure your browser to refuse cookies, but some features may not function properly without them. See our Cookie Policy for more detail.

6. Data retention

We retain personal information for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce agreements.

When information is no longer needed, we may delete, anonymize, or aggregate it.

7. Data security

We use reasonable technical, organizational, and administrative measures to protect personal information against loss, misuse, and unauthorized access.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8. Your rights and choices

Depending on your location and applicable law, you may have rights such as:

• Accessing and obtaining a copy of your personal information
• Requesting correction or deletion of your information
• Objecting to or restricting certain processing
• Withdrawing consent where processing is based on consent

Contact us at privacy@thinkingoracle.com to exercise these rights.

9. Additional information for EU/EEA and UK users

For users in the European Economic Area, Switzerland, or the United Kingdom, we are the "controller" of your personal data.

We process personal data on the following legal bases:

• Your consent (Article 6(1)(a) GDPR)
• Performance of a contract (Article 6(1)(b))
• Compliance with legal obligations (Article 6(1)(c))
• Our legitimate interests (Article 6(1)(f))

You may also lodge a complaint with a supervisory authority in your country of residence.

10. International data transfers

Your information may be transferred and processed in jurisdictions with different data protection laws. When we transfer personal data from the EEA, Switzerland, or UK, we implement appropriate safeguards such as Standard Contractual Clauses.

11. Google Workspace API data

If you connect a Google account to Luke, Luke uses Google Workspace API data only to provide user-facing features that you request or enable, such as reading recent Gmail inbox snippets and summarizing them inside Luke. Luke's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Luke does not sell Google Workspace API data, use it for advertising, or use raw, aggregated, anonymized, or derived Google Workspace API data to create, train, or improve generalized or foundational AI or machine learning models. When a Gmail-connected feature uses an AI model to generate a user-requested answer or summary, the relevant Gmail snippets are used only for that visible feature and are not provided for model training or other secondary purposes.

12. Third-party sites and services

The Services may link to third-party websites or services not controlled by us. This Policy does not apply to those third parties. Review their privacy policies separately. Our Terms of Use and Cookie Policy govern other aspects of your use of the Services.

13. Changes to this Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by updating the "Last updated" date or through other means.

14. Contact us

For questions regarding this Privacy Policy, contact us at:

• Email: privacy@thinkingoracle.com