Privacy Policy

1. Who we are

LXMN is operated by Fixerra Private Limited, a company incorporated in India (“Fixerra”, “we”, “us”). For account data of the firm's users and for security and usage logs, Fixerra is the data fiduciary. For client data that a firm enters into LXMN, the firm is the data fiduciary and Fixerra acts as its data processor, only on the firm's documented instructions.

2. Data we process

• Account data of firm users: name, work email address, role, the firm they belong to, and sign-in records.
• Client data entered or uploaded by the firm: client names and contact details, holdings, portfolio statements, notes, meeting minutes, tasks and documents. The firm decides what it enters.
• Connected mail and calendar data. When a user connects a Google or Microsoft mailbox or calendar, LXMN reads messages, calendar events and the related contact details live from the provider, to show them inside LXMN and to send mail or create events that the user asks for. This data is not copied into LXMN's database.
• Usage and security logs: sign-in events, requests, errors, IP address and device information, and actions taken in the product, kept for security, support and an audit trail for the firm.

3. How we use it

We use personal data only to:

• provide, operate and support LXMN and the features the firm and its users ask for;
• authenticate users and keep accounts and client data secure;
• keep the audit trail that the firm and its regulators may require;
• diagnose faults and improve reliability and performance;
• comply with law and respond to lawful requests.

We do not sell personal data and we do not use it for advertising.

4. Google user data

LXMN'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. In particular:

• We use data received from Google APIs only to provide and improve the user-facing features the user has asked for inside LXMN, such as showing their mail and calendar and sending mail or creating events on their request.
• We do not use this data for serving advertisements, including retargeting, personalised or interest-based advertising.
• We do not transfer this data to others except as necessary to provide or improve those user-facing features, to comply with applicable law, for security purposes such as investigating abuse, or as part of a merger or sale where the user is notified.
• We do not allow humans to read this data unless we have the user's affirmative consent for specific messages, it is necessary for security purposes such as investigating abuse, or it is required to comply with applicable law.
• We do not use this data to develop, improve or train generalised AI or machine-learning models.

5. Microsoft user data

Data received from Microsoft Graph (Outlook mail, calendar and profile) is treated on the same terms: it is read live with the permissions the user grants, used only to provide the features the user asks for, not used for advertising, not transferred except as needed to provide those features, for security or by law, and not read by our staff except with the user's consent, for security or by law. It is not used to train AI models.

6. AI processing

Some LXMN features, such as briefs, summaries, drafting and document reading, send the relevant content to AI models operated by our AI model provider so that the feature can respond. Content is sent only for the request being made, is processed under terms that do not allow our provider to train its models on it, and is not used by Fixerra to train models. AI output is generated text for the user to review; see our Terms of Service.

7. Where data is stored, and security

Data is stored in Amazon Web Services in the Asia Pacific (Mumbai) region, ap-south-1, in India. Data is encrypted in transit with TLS and at rest. Sensitive client fields, such as phone numbers and dates of birth, are additionally encrypted at field level. Each firm's data is held in its own database, and access is limited to authorised users of that firm and to a small number of Fixerra staff who need it to operate the service, with access logged. We review our controls regularly; no system is perfectly secure, and we will notify affected firms and, where required, the Data Protection Board of India of a personal data breach.

8. Sharing and subprocessors

We share personal data only with service providers that help us run LXMN, under written terms:

• Amazon Web Services: hosting, storage, email delivery and monitoring.
• Our AI model provider: processing of content for the AI features described above.
• Google and Microsoft: only as the user's own mail and calendar provider, when the user connects an account.
• Market-data and fund-data providers: LXMN receives data from them; client personal data is not sent to them.

We disclose data to authorities only where the law requires it.

9. Retention and deletion

Account and client data are kept while the firm's agreement with us is in force and are deleted or returned within a reasonable period after it ends, except where the law requires us to keep a record. Logs are kept for a limited period for security and audit. A user can disconnect a Google or Microsoft account in LXMN at any time; this revokes LXMN's access and stops all reading of that mailbox. Mail content is not stored by LXMN, so there is nothing further to delete for it. A user can also remove LXMN's access from their Google or Microsoft account settings.

10. Your rights

Under India's Digital Personal Data Protection Act, 2023, a person whose data we process has the right to obtain a summary of the personal data processed and the processing activities, to ask for correction, completion, updating and erasure of personal data, to have a grievance redressed, and to nominate another person to exercise these rights in the event of death or incapacity. To exercise a right, write to admin@lxmn.ai. If your data was entered into LXMN by a firm, we may refer the request to that firm, which decides the purpose of the processing.

11. Grievance officer

Our Grievance Officer can be reached at admin@lxmn.ai. We acknowledge complaints promptly and aim to resolve them within the time the law prescribes. If you are not satisfied, you may complain to the Data Protection Board of India.

12. Changes

We may update this policy. The date at the top shows when it last changed, and we will notify firms of material changes in advance where practicable.

13. Contact

Privacy questions, requests and legal notices: admin@lxmn.ai. Fixerra Private Limited, India.