Privacy Policy

1. Introduction

This Privacy Policy describes how Lube Software Sdn. Bhd. (Registration No. 202401053113) (“Company,” “Lube,” “we,” “us,” or “our”) collects, uses, discloses, and protects your personal information when you visit our website at https://lube.gg (the “Website”) or use our software-as-a-service platform and related services (collectively, the “Service”).

We are committed to protecting your privacy and handling your personal information in accordance with applicable data protection laws, including Malaysia's Personal Data Protection Act 2010 (PDPA).

By accessing or using the Service, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Service.

2. Information We Collect

We collect information in several ways depending on how you interact with our Service.

2.1 Information You Provide Directly

2.2 Information Collected Automatically

When you use the Service, we automatically collect certain information about your device and usage:

For more information about cookies, please see our Cookie Policy.

2.3 Information from Third-Party Services

If you connect third-party services to your lube account, we may receive information from those services:

You control which third-party services you connect, and you can disconnect them at any time through your account settings.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Maintain the Service

• Creating and managing your account
• Processing transactions and sending related information
• Providing customer support
• Enabling features and integrations you request

3.2 To Improve and Develop the Service

• Understanding how users interact with the Service
• Identifying and fixing bugs and issues
• Developing new features and functionality
• Conducting research and analysis

3.3 To Communicate with You

• Sending transactional emails (account verification, password resets, billing notifications)
• Sending product updates and announcements
• Sending marketing communications (with your consent, where required)
• Responding to your inquiries and support requests

3.4 To Ensure Security and Prevent Fraud

• Detecting, preventing, and addressing technical issues
• Protecting against unauthorized access, fraud, and abuse
• Enforcing our Terms of Service and other policies

3.5 To Comply with Legal Obligations

• Responding to lawful requests from public authorities
• Complying with applicable laws and regulations
• Protecting our legal rights and interests

4. AI-Powered Features

The Service includes AI-powered features that use large language models (LLMs) provided by OpenAI.

4.1 How AI Features Work

When you use AI-powered features (such as our product discovery module), information you provide—including domain information, prompts, and context—may be sent to OpenAI for processing.

4.2 Data Handling for AI Features

4.3 OpenAI

Provider: OpenAI, L.L.C.
Privacy Policy: https://openai.com/privacy

5. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

5.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

These providers are contractually obligated to protect your information and may only use it for the purposes we specify.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.3 Business Transfers

If lube is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.

5.4 With Your Consent

We may share your information for other purposes with your explicit consent.

6. Data Storage and International Transfers

6.1 Storage Location

Your data is stored on servers located in the United States using Google Cloud Platform infrastructure.

6.2 International Transfers

If you are located outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States. By using the Service, you consent to this transfer. We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy when transferred internationally.

7. Data Retention

We retain your information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy.

After the applicable retention period, we will delete or anonymize your information, unless retention is required by law.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction.

Our security measures include:

• Encryption of data in transit using TLS/SSL
• Encryption of data at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Employee training on data protection

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you become aware of any unauthorized access to your account, please contact us immediately at privacy@lube.gg.

9. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information.

9.1 Access and Portability

You have the right to request access to the personal information we hold about you. You may also request a copy of your data in a portable format.

9.2 Correction

You can update most of your personal information directly through your account settings. If you need assistance correcting information you cannot update yourself, please contact us.

9.3 Deletion

You have the right to request deletion of your personal information. Upon receiving a valid deletion request, we will delete your information within 90 days, except where retention is required by law or for legitimate business purposes.

9.4 Objection and Restriction

You may have the right to object to certain processing of your information or request that we restrict processing in certain circumstances.

9.5 Withdrawal of Consent

Where we rely on your consent to process your information, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing conducted prior to withdrawal.

9.6 Communication Preferences

You can opt out of marketing communications at any time by:

• Clicking the “unsubscribe” link in any marketing email
• Updating your notification preferences in your account settings
• Contacting us at privacy@lube.gg

Please note that you may still receive transactional emails related to your account and the Service.

9.7 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: privacy@lube.gg

We will respond to your request within a reasonable timeframe and in accordance with applicable law. We may need to verify your identity before processing your request.

10. Children's Privacy

The Service is intended for business use and is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at privacy@lube.gg. If we become aware that we have collected personal information from a child under 13 without verification of parental consent, we will take steps to delete that information.

11. Third-Party Links and Services

The Service may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party services.

We encourage you to review the privacy policies of any third-party services you access through the Service.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

When we make changes, we will:

• Update the “Last Updated” date at the top of this policy
• Post the updated policy on our website
• For material changes, notify you by email or through the Service

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. Data Protection Officer

While not legally required under Malaysian law, we have designated a privacy contact to handle data protection matters and respond to inquiries:

Privacy Contact: privacy@lube.gg

14. Additional Information for Specific Jurisdictions

14.1 European Economic Area (EEA) and United Kingdom

If you are located in the EEA or UK, you have additional rights under the General Data Protection Regulation (GDPR) or UK GDPR, including the right to lodge a complaint with your local data protection authority.

Legal Basis for Processing: We process your personal data based on:

• Contract: To perform our contract with you (providing the Service)
• Legitimate Interests: For our legitimate business interests (improving the Service, security)
• Consent: Where you have given consent (marketing communications)
• Legal Obligation: To comply with applicable laws

14.2 California

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect and how we use it, the right to request deletion, and the right to opt out of the “sale” of personal information.

We do not sell your personal information as defined by the CCPA.

14.3 Malaysia

If you are located in Malaysia, your personal data is protected under the Personal Data Protection Act 2010 (PDPA). You have the right to access and correct your personal data, and to limit the processing of your personal data for marketing purposes.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at: