Privacy Policy

Last revised: February 3rd, 2026

Lema Labs, Inc. ("Lema") respects the privacy of all visitors and users of its online services and is dedicated to maintaining the accessibility, confidentiality, and integrity of all such information. This Privacy Policy (“Policy”) applies to all visitors and users of the Lema website www.lema.ai and all other Lema-owned websites, domains, website services, applications, and products (“Lema.AI platform”).

In connection with the use of the Lema.AI platform and the processing of Personal Information, your employer ("Customer") is the controller under applicable privacy laws, and we act as a processor with regards to the processing of employees' Personal Information. We process such Personal Information only as instructed by the Customer and in accordance with a data processing agreement between our Customers and us.

Please take the time to read this Policy carefully to understand what personal information we collect when you use Lema.AI platform, why we collect it, how we use it, and your choices related to your information. 

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We may collect Personal Information about you when you provide it to us, when you interact with Lema.AI platform, and when other sources provide it to us.

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Personal Information and What We Collect

  1. Information You Provide to Us Through our Website

Direct identifiers, such as your name, address, email address, telephone number.

Other Personal Information, you choose to provide, such as when you participate in a survey, register for an event, or when you request technical or consumer support.

  1. Information You Provide to Us When You Use of Lema.AI Platform 

Direct Identifiers such as your full name, email address, as well as your password, and any other personal information that you decide to provide us with. We also collect the contact and billing information of our customers.  

  1. Information We Automatically Collect When You Use of Lema.AI Platform or Website

When accessing or using Lema.AI platform, we may automatically collect:

Internet activity, Log Information, and Service usage information, such as operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on Lema.AI platform.

Location information, such as information used to locate the device you use to access Lema.AI platform. Location information may include: (i) the location of the device derived from GPS or WiFi use; (ii) the location derived from the IP address of the device or internet service used to access Lema.AI platform, and (iii) other information made available by a user or others that indicates the current or prior location of the user.

Profile and Inference Information, such as information about your preferences and characteristics.

We also use third-party session recording tools to record and obtain analytics on your session either on our website or on our platform (or both). 

  1. Personal information from Other Sources. 

Lema also may obtain personal information about you from other sources, including publicly - or commercially- available information, and through third-party data platforms, partners and service providers.

  1. Personal information you provide to us in person. 

For example, when you visit one of our exhibition booths or attend one of our events and you provide us with your contact details. 

  1. Personal information we collect from online interactions. 

For example, if you attend a webinar, contact us via social media or otherwise interact with our business, including as a representative of a current / prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other personal information that you decide to provide us with. 

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The purposes for which we process your Personal Information

  1. To Provide and Manage Lema.AI platform. This includes, for example, enabling you to participate in features provided by Lema.AI platform, performing our contracts with you or your employer or business. We also may use information we gather to better understand and serve users and to improve Lema.AI platform.
  2. To Communicate with You. We may use your Personal Information to respond to questions you submit via Lema.AI platform. 
  3. To Market our services to You. We may use your Personal Information to communicate with you regarding news, updates, or educational and marketing materials. You may opt-out of receiving commercial email messages from us by following the instructions in those messages.
  4. To allow you to make use of our Website. We will use your personal information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal information to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us (e.g., by using the Website chat); (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience.
  5. Security purposes. Some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. 
  6. Cookies and Similar Technologies. We use Technologies to automatically collect information through the Website and Services, which in certain cases could be considered personal information. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services.
  7. As Required or Permitted by Law. We may use your Personal Information to comply with any applicable legal or regulatory obligations or for any other purpose permitted by law or with your lawful consent. 
  8. To create de-identified or anonymized information. We may deidentify, pseudonymize, or anonymize your Personal Information, which means that information that can be reasonably used to identify you will be removed. We may aggregate the deidentified information into a multi-modal real-world dataset to empower research and improve patient care. We create and use such de-identified information as permitted by law or with your consent.

The lawful bases we rely on for processing personal information are (if and when applicable).

  1. The data subject has given consent to the processing of his or her personal information;
  2. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; 
  3. Processing is necessary for compliance with a legal obligation to which the controller is subject; and/or
  1. Processing is necessary for the purposes of  legitimate interest.

Customer Information 

For the avoidance of doubt, Lema is processing Customer Information (as defined below) on behalf of the applicable customer. Therefore, the customer is the party responsible for the security, integrity and authorized usage of Customer Information in the context of the services and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Customer Information. The customer is the sole responsible to ensure that the use of the Services is permitted under the applicable laws and jurisdictions. 

Lema has a contractual relationship with its customers. In the context of the Lema.AI Platform, the customer can decide which information, including names, emails, addresses  (“Customer Information”) the customer will allow Lema  access to. Customer Information is not regulated by this Privacy Policy, and this paragraph is provided only for transparency purposes, since Lema is a data processor/service provider of the Customer Information. If you have any questions related to the Customer Information, please contact the customer directly.

Tracking Technologies

When you visit or access Lema.AI platform and website, we use cookies, pixels, beacons, local storage and similar technologies, that allows us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in Lema.AI platform.

You can manage your cookie preferences, including opting out of non-essential cookies, via our cookie consent banner.

We use technical, physical, and administrative safeguards that are designed to improve the confidentiality, integrity and accessibility of your Personal Information and Protected Health Information. We incorporate secure storage and transmission technologies including strong encryption, firewalls, fine-grained access control and secure audit. We cannot, however, ensure or warrant the security of any information you transmit to us via Lema.AI platform, and you do so at your own risk. Additionally, we cannot guarantee that such information will not be accessed, disclosed, altered, or destroyed due to a breach of any of our technical, physical, or administrative safeguards. Security risks can never be excluded completely, and residual risks are unavoidable.

Children’s Privacy 

Lema.AI platform is not designed nor intended to be used or accessed by children under the age of 13. We do not intentionally collect Personal Information from children through Lema.AI platform. If you are under the age of 13, do not use or provide any information on or through Lema.AI platform. If we learn we have collected or received Personal Information from a child under age 13 without verification or parental consent, we will delete that information. If you believe that we may have collected any information, including Personal Information from or about a child under age 13, please contact us immediately at privacy@lema.ai.

Retention

We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

For customer accounts, once an account is voluntarily closed or enters an expired state, related data will be retained for 45 days unless a specific contract states otherwise. After this period, the account and related data will be permanently deleted. If an account is involuntarily suspended, there is a 45-day grace period during which the account may be reactivated; otherwise, data will be deleted 45 days after the account enters the expired state, except where retention is required by law.

When personal information is deleted, we use secure destruction methods designed to render the information irretrievable, in line with our Record Retention Policy.

We may archive certain records for a period of three years, or longer if required for legal, historical, or operational purposes, in accordance with our Record Retention Policy. Archived records are stored securely and are inaccessible to regular users but may be retrieved by authorized administrators if necessary.

Security

We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

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How We Share Your Personal Information 

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We may share your personal information as follows: 

  1. The personal information Lema  gathers may shared with our partners and other third parties. 
  2. We also share personal information about you with our affiliated companies . 
  3. We use third party service providers to process your personal information for the purposes outlined above, including, without limitation: 
  • With cloud service providers for hosting purposes;
  • With websites and web content creation platforms in order to help us manage our Website;
  • With email providers, marketing, CRM, other similar tool providers; 
  • With artificial intelligence tools and features; and
  • With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy.
  1. To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Lema, our Services, customers, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
  2. We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
  3. We may use or disclose the personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
  4. If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.
  5. Where you have otherwise provided your consent to us for sharing or transferring your personal information.

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Your Privacy Rights

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):

  1. You have the right to withdraw consent to the processing, where consent is the basis of processing. 
  2. You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions. You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.
  3. You have the right to object to unlawful data processing under certain conditions.
  4. You have the right to the erasure of past personal information about you (your “right to be forgotten”) under certain conditions.
  5. You have the right to demand that we restrict the processing of your personal information, under certain conditions, if you believe we have exceeded the legitimate basis for processing, the processing is no longer necessary, or if you believe your personal information is inaccurate.
  6. You have the right to data portability of personal information concerning you that you provided us in a structured, commonly used, and machine-readable format, subject to certain conditions.
  7. The personal information we collect is not used for automated decision-making and profiling, except for automated processes in the context of marketing. As stated above, you can opt out of direct marketing by contacting LEMA directly or by following the instructions through the unsubscribe options in our email messages.

You can exercise your rights by contacting us at privacy@lema.ai. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Deleting your account: Should you ever decide to delete your account, you may do so by emailing privacy@lema.ai. If you terminate your account, any association between your account and personal information we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public. 

Marketing emails – opt-out: You may choose not to receive marketing email of this type by sending a single email with the subject "BLOCK" to privacy@lema.ai. Please note that the email must come from the email account you wish to block. Alternatively, if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt. 

International Transfers of Personal Information

In order to run our business and provide our Website and Services to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by using Standard Contractual Clauses or other lawful mechanisms:

  1. making sure the destination country has been deemed by the European Commission to provide an adequate level of protection for personal information; and/or
  2. by executing data onward transfer instruments such as data processing and protection agreements.

Interaction With Third Party Products. 

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

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Analytic Tools  

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

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  • Coralogix. We may use an analytics tool offered by Coralogix Ltd. (“Coralogix”). For more information about Coralogix and how to opt out of Coralogix’s collection and processing of data, please see the Coralogix privacy policy available at https://coralogix.com/privacy-policy/

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  • PostHog. Our Website uses analytic tools offered by PostHog Inc. ("Post Hog"). For more information about Post Hog and how to opt out of their collection and processing of data, please see the Post Hog privacy policy at https://posthog.com/privacy.

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  • Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share personal information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/..

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  • We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.

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Changes to This Privacy Policy

It is our policy to post any changes that we make to our Privacy Policy on our website. If we make material changes to how we treat our users’ Personal Information, we will update this Privacy Policy. The date our Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our website and this Policy for changes. For any questions or comments regarding this Privacy Policy, please contact us at privacy@lema.ai.

Contact Us

Please contact us with any questions or comments about this Policy, your Personal Information or our Notice of Privacy Practices, or your consent choices by email at privacy@lema.ai.

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