The Legal Area

Usability rules about LutinX’ websites

Privacy Statement

Our Legal office is at your service. Here you can find legal documents regarding the usability of our website and our products. Privacy Statement

Last Update: 
January 03, 2023

1. Overview

LutinX and its agents (“LutinX”) are committed to data security and the fair and transparent processing of personal data. This privacy policy describes how LutinX treats the information you provide to us or that we otherwise collect. This Privacy Policy also describes your choices regarding use, access and correction of your personal information. “You” refers to the person or entity using the Service. The “Service” is the digital credentialing and certification functionality, associated insights and connection to relevant career, education and training opportunities provided through any website or application offered by LutinX. “Personal Data” includes the data we collect directly from you as well as personal data from Issuers (defined below) and Third-Party Services (defined below). This Privacy Policy sets out how we will treat the personal data which you provide to us in compliance with Applicable Data Protection Laws. LutinX owns and operates This Policy, together with our website terms of use and any other documents referred to in them, sets out the basis on which LutinX processes Personal Data.

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities in the event that you would like to report a concern about the way in which we process your data.

This Privacy Policy describes our broadest potential use of your Personal Data, although we may actually make far less use. The basis for our processing of your Personal Data is your informed consent. No law requires you to provide us with your Personal Data. You may withdraw your consent for us to process your Personal Data at any time, but that may preclude you thereafter from using the Website and the Service. We will delete your Personal Data following the withdrawal of your consent, however, such withdrawal will not affect the lawfulness of processing prior to withdrawal.

LutinX collects Personal Data when you choose to submit it through e-mail, an online form, or other method. We also collect information through cookies.

LutinX also maintains a log of certain information concerning visitors to our websites, including but not limited to, internet protocol (“IP”) address (a computer’s numerical Internet address), third party websites from which visitors access our website, type of web browsers used, and pages viewed. Such information may include Personal Data.

By your use of the Service you consent to our use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. Who are we?

LutinX is a Delaware corporation with offices in New York City. LutinX works in Europe with SGT Media SA, a Switzerland based company, with legal offices in via Frigerio 3, Val Mara.

The LutinX Service is an internet-based, hosted platform designed to enable subscribers to the Service (“Issuers”) to issue digital badges and credentials (“Credentials”) and store and archive data inside the Blockchain Network, to individuals who meet prescribed requirements (“Earners”), and for those Earners to display the Credentials online on the Service or on third party sites, as elected by Earners.

We may provide your information to trusted partners who work on behalf of, or with, LutinX under confidentiality agreements to help LutinX provide the Service. They may also assist LutinX in communicating with you about the Service and about offers from LutinX and our partners, where you have provided us consent to do so.

For the purposes of the GDPR, LutinX is the ‘processor’ of certain types of Personally Identifiable Data provided by Issuers and the ‘controller’ of other types of Personally Identifiable Data provided directly to us by Earners. LutinX offers a Data Protection Addendum (DPA) for qualifying organizations, which you can find online at

You may contact our Primary Point of Contact for data privacy and security with any questions, comments or concerns about this policy by sending an email to

3. What personal data do we collect?

We may collect and process the following personal data:


To register for or use the Service, you will be prompted to give us certain required information about yourself, such as your name and email address. When you configure your account settings, you may enter additional, optional information about yourself. You may, at times, also send us an e-mail which may contain not only your e-mail address, but other information about you, including home or business addresses, telephone numbers, or account details. The information you give us may also include statements you make on the Service such as testimonials, services reviews, or other statements that may identify you personally.
When an Issuer issues you a Credential or share a notarized document, we will provide you with a user ID (the e-mail address provided by the Issuer) and account activation e-mail for you to access the Service and create a user “profile” for use as described below. Alternatively, you may directly create an account on the Service by entering your email address, name, and country. When you first sign onto the Service, you will be presented with your profile, which contains the information supplied to us by you or the Issuer. In addition to the information required to establish your account, including your name, email, password and country, you may provide some or all of the following information, including but not limited to, a photograph of yourself, a short biographical blurb, your state/province, your city, your zip code, your current employer, your current job title, your birth year, and your website URL. You will be able to update or correct any of the contact information in your profile at any time. You may receive certain e-mails relating to your use of the Service. If you receive another Credential from other Issuers, your user ID will be authorized to access the Service, and your contact information will be added to the participant list for that Issuer.
If you have consented or opted in to receiving news and updates from LutinX on professional growth or further education opportunities, you have the right at any time to prevent us from further contacting you by following the unsubscribe or opt-out instructions included in the relevant email or through the privacy tools provided to you through the Service.
We may use your Personal Data to contact you regarding your use of the Service, for customer support purposes, and to inform you of updates, modifications and other matters relating to the Service, and information about others services that we offer in accordance with your subscription preferences. You may decline to receive mail or e-mail from us that does not relate directly to your access to or use of the Service by selecting the opt-out link contained in any such e-mail or by contacting us at
You may request that LutinX provide third-parties access to your publicly accessible personal information. LutinX will not provide your personal information to a third-party without your consent.


LutinX also will maintain a history of your access to the Service, and certain actions taken by you while accessing the Service, a log of users’ IP addresses, the third-party Website from which users access the Service, the type of web browsers used to access the Service and the browser’s settings that may affect Service performance (collectively, “Usage Log Information”). For purposes of maintaining and enhancing Service performance and security, LutinX may use Usage Log Information, information about your browser, and other local computer settings. We also may use Usage Log Information to tailor our communications to you about the Service, and contact you in relation to providing support. We also may aggregate Usage Log Information to create or publish statistical analyses and reports about Service usage. We will not authorize the publication of Personal Information about any user without the prior written consent of such person.


Issuers provide Personal Information to us, including first name, last name, email address, and Credential. The use of information collected from Issuers shall be limited to the purpose of providing the service for which these Organizations have engaged LutinX.
LutinX collects information directly from the Issuer or directly from the Earner. If you would no longer like to be contacted by one of the Issuers that use our service, please contact the Issuer that you interact with directly.
An individual who seeks access, or who seeks to correct or amend inaccurate Credentials should direct their query to the Issuer. We retain Personal Information we process on behalf of the Issuers for as long as needed to provide services to the Issuers and the Earners and in compliance with all applicable personal information retention laws. Individual Credentials and an Earner’s entire account may be deleted by the Earner at any time directly through the Service. LutinX will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


We may statistically aggregate in non-person-specific form information collected to improve our websites, our quality controls, operations management, security processes, future marketing and promotional efforts, and the overall Service in attempt to better understand our users’ interests and preferences. In some cases, we may transfer this information to our third-party service providers. By using this Site, you consent to this non-personally identifiable data aggregation and the use and transmission of this aggregated statistical data as outlined above.

4. How do we use your personal data?


In addition to the uses described above of the information received in connection with your use of the Service, LutinX uses and, where specified, shares your information:

o   To display Credentials. LutinX may use your information to display Credentials that you receive through the Service or through Third-Party Services on the LutinX website or on third party websites or applications that you choose to share your personal information to.

o   To provide support or other services that you have requested, and to respond to your inquiries.

o   To engage in transactions with you, including contacting you about your account or transactions.

o   To notify you of relevant opportunities such as new product releases and service developments, related facts or programming that may be relevant to you.

o   To improve quality and facilitate use of the Service.

o   To operate the Service through the assistance of third parties. LutinX may use services from third-party service providers, such as hosting services and software developers, in support of its operation of the Service. When doing so, we will take steps to ensure that such service providers implement appropriate privacy and security measures consistent with this Privacy Policy to safeguard against the unauthorized use or disclosure of your information. These companies are authorized to use your personal information only as necessary to provide these services to us.

o   To comply with legal requirements. In addition, we may also disclose information about you as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is reasonably necessary to enforce our rights or protect our operations or users or others investigate fraud, or in response to legal processes or governmental investigations in accordance with our internal policy on access by governmental authorities, or under exigent circumstances in response to a perceived significant threat to a person’s health or property.

5. Privacy Preferences

The Service allows you to customize the information about yourself that is made accessible to others. When you establish an account, the Service applies default settings. Default settings also apply to new features introduced on the Service. Credentials issued to you will default to the “public” setting. You may activate a “private” setting such that the Credential will no longer be publicly accessed at any time, on a Credential-by-Credential basis. Until you terminate your use of the Service, the fact that you are a user, as indicated by the public display of your full name and avatar, is available to others on the Service. Review your privacy settings regularly to ensure that they match your preferences.

6. Security

LutinX takes appropriate and reasonable precautions to implement appropriate administrative and technical procedures to protect the security of Personal Information provided or generated through the Service. We permit persons working for us to access and use your information only in a manner consistent with this Privacy Policy.

LutinX and all subsidiaries would like to assist you with a better experience. If you have a specific question about the terms of use or the privacy regulation, you can contact us, pressing the close button.