Privacy Policy

Overview

This privacy policy (Policy) sets out how Lemoncello.AI Pty Ltd (ACN 694 814 867) (we, our, us) collects and treats your personal information. Lemoncello.ai is a Generative Engine Optimisation (GEO) platform. It enables the user to measure, monitor and improve the visibility of their brand, products and content within AI-generated answers and outputs produced by large language models.

We respect your right to privacy, are committed to safeguarding the privacy of our customers and comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).

By providing us with personal information, you consent to the terms of this Policy and the types of disclosure covered by this Policy. Where we disclose your personal information to third parties, we will request that the third party follow this Policy regarding handling your personal information.

This Policy has been updated to reflect guidance issued by the Office of the Australian Information Commissioner (OAIC) in October 2024 regarding the use of Artificial Intelligence (AI) and generative AI (GenAI) tools.

What is personal information?

Personal information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be personal information regardless of whether it is true. This includes information generated or inferred by AI systems, such as profiles, predictions, scores or images derived from your data.

What personal information do we collect and hold?

The types of personal information we collect depends on the nature of our engagement with you. Examples of personal information we may collect include, but are not limited to:

• name;
• email address;
• home or work address;
• work information (e.g. employer, your role/position);
• device and technical information when you access our platform or website; and
• any information inferred or generated about you through our use of AI or analytics tools.

We may collect additional information at other times, including when you provide feedback, when you provide information about your personal, employment or business affairs, change your content or email preference, respond to surveys and/or promotions or provide financial or credit card information. Additionally, we may also collect any other information you provide while interacting with us.

Why do we collect, hold and use your personal information?

We collect, hold and use your personal information so that we can:

• verify your identity;
• provide you with products and services, and manage our relationship with you;
• contact you, for example, to respond to your queries or complaints, or if we need to tell you something important;
• comply with our legal obligations and assist government and law enforcement agencies or regulators; and
• operate and improve our AI-powered products and services, in accordance with the purposes described in this Policy.

If you do not provide us with your personal information, we may not be able to provide you with our products or services, communicate with you or respond to your enquiries.

How do we collect your personal information?

We collect personal information from you in a variety of ways, including:

• when you interact with us electronically or in person;
• when you access our website or use our products or services;
• when we provide our products or services to you (or your employer or other organisation); and
• we may receive personal information from your employer or third parties. If we do, we will protect it as set out in this Policy.

We may collect information about how you access, use and interact with our website, including by using a range of tools such as Google Analytics or other web analytic tools.

We use cookies on the website. You may refuse to use cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of the website.

Our use of Artificial Intelligence (AI) tools

Lemoncello.ai is itself an AI-powered product. The platform interacts with large language models (LLMs) and AI search engines to measure how brands and content are represented in AI-generated outputs. As a result, AI is fundamental to how Lemoncello.ai operates.

In providing the Lemoncello.ai service, we may process information about your organisation, your brand, your content and associated individuals. We may also query AI platforms on your behalf to generate reports, benchmarks and optimisation recommendations. We are committed to handling all personal information in these processes in accordance with the Privacy Act and the Australian Privacy Principles.

Lemoncello.ai does not use client personal information to train or improve third-party AI models, and we do not share personal data with LLM providers beyond what is necessary to perform the querying functions of the platform.

AI tools we use

We may use commercially available or proprietary AI and GenAI tools in the operation of our business and products. These tools may process personal information to:

• analyse data to improve our products and services;
• generate insights, recommendations or automated outputs relevant to your use of our platform;
• assist our internal teams with business operations; and
• support customer service, document processing, or security monitoring functions.

How we handle personal information in AI systems

When using AI tools, we are committed to the following safeguards:

• We will only use or disclose personal information in AI systems for the primary purpose for which it was collected, or a secondary purpose where we have your express consent or where you would reasonably expect such use.
• We will not enter your personal information into publicly available generative AI tools unless we have your express permission to do so.
• We take steps to ensure that AI tools we use comply with the Privacy Act and APPs, and we conduct due diligence on AI vendors regarding their data handling practices.
• Where AI systems generate or infer personal information about you (including profiles, predictions or scores), that information is subject to the same protections as directly collected personal information under this Policy.
• We apply data minimisation principles — we only use the minimum amount of personal information necessary for a given AI function.

Automated decision-making

Some of our products may use automated processes or AI-assisted decision-making. Where a decision made about you relies solely or substantially on automated processing and produces a significant effect, we will:

• inform you that automated processing is being used;
• upon request, provide you with meaningful information about the logic involved; and
• provide you with the ability to request human review of any such decision.

Lemoncello.ai generates optimisation recommendations and visibility scores using automated analysis of AI-generated content. These outputs are informational and advisory in nature. All recommendations are intended to support human decision-making by your marketing, brand or content teams. Lemoncello.ai does not make binding decisions about individuals using automated processes.

AI model training

We will not use your personal information to train external AI models without your express, informed consent. Where we develop or fine-tune proprietary AI models using internal data, we take steps to de-identify or anonymise personal information before it is used for model training purposes, to the extent reasonably practicable.

How do we store personal information?

We store most personal information about you in computer systems and databases operated by either us or our external service providers.

We implement and maintain processes and security measures designed to protect personal information we hold from misuse, interference, or loss, and from unauthorised access, modification or disclosure. These processes and systems include:

• the use of identity and access management technologies to control access to systems on which personal information is processed and stored;
• requiring all employees to comply with internal personal information security policies and keep personal information secure; and
• applying security controls to AI systems and third-party AI tools used in our business, including contractual requirements around data handling and confidentiality.

We will also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

Who do we disclose your personal information to, and why?

We may disclose personal information for the purposes described in this Policy to:

• our employees and related bodies corporate;
• third party suppliers and service providers (including providers for the operation of our website and/or our business or in connection with providing our products and services to you);
• our existing or potential agents, business partners or professional advisors; and
• AI tool providers or technology platforms engaged by us to operate or improve our products and services, subject to appropriate data handling agreements.

We may also disclose personal information where (i) we are required or authorised by law to do so; (ii) you have expressly consented to the disclosure, or the consent may be reasonably inferred from the circumstances; or (iii) we are otherwise permitted to disclose the information under the Privacy Act.

If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would only disclose information in good faith and where required by any of the above circumstances.

Do we disclose personal information to overseas recipients?

We may disclose your personal information to recipients which are located outside Australia.

Those recipients are likely to be in the United States of America. Some AI tools and platforms we use may process or store data on servers located overseas, including in the United States. Before disclosing personal information to overseas recipients, we take reasonable steps to ensure those recipients handle information consistently with the APPs, or we obtain your consent to the overseas disclosure.

Do we use your personal information for marketing?

We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. These products and services may be offered by us, our related companies, our other business partners or our service providers.

Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

We do not use automated profiling or AI-driven targeting for marketing purposes without your consent.

How do you access, or ask for a correction to, your personal information?

You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate and up to date.

We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.

If you wish to access personal information held about you in any AI-generated profile, prediction or score, or to request correction of inaccurate AI-inferred information, you may exercise your access and correction rights by contacting us at the details below.

How do you make a complaint?

If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you are not satisfied we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Contact details

If you have any questions, comments, requests or concerns, please contact us at:

• privacy@lemoncello.ai
• GPO Box 2124, ACT, 2601
• www.lemoncello.ai

Changes to this Policy

We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon posting of the modifications on our website. Please check back from time to time to review our current Privacy Policy.

You may obtain a copy of our current policy from our website or by contacting us at the contact details above.