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We do not provide or guarantee, and we expressly disclaim, any value, cash or otherwise, attributed to any data residing on the servers running the service.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20The%20Service%20contains,servers%20running%20the%20service.","structural_citation":"§ 5.6 (Luel Property)","citation_basis":"section_number","char_start":21940,"char_end":23479}},{"pattern_key":"broad_content_license","pattern_family":"ip_license","risk_rating":"medium","confidence":"medium","stance_key":"content_license","stance_value":"broad_license","evidence":"To use any App, you must have a mobile device that is compatible with such App. Luel does not warrant that any App will be compatible with your mobile device. You may use mobile data in connection with an App and may incur additional charges from your wireless provider in connection with such App. You understand and acknowledge that you are solely responsible for any such charges. 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The foregoing license grant is not a sale of any App or of any copy thereof. You may not: (a) modify, disassemble, decompile, or reverse engineer any App, except to the extent that such restriction is expressly prohibited by Applicable Law; (b) rent, lease, loan, resell, sublicense, distribute, or otherwise transfer any App to any third party, or use any App to provide time sharing or similar services for any third party; (c) make any copies of any App; (d) remove, circumvent, disable, damage, or otherwise interfere with security-related features of any App, features that prevent or restrict use or copying of any content accessible through any App, or features that enforce limitations on use of the Apps; or (e) delete the copyright or other proprietary rights notices on any App.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20To%20use%20any,on%20any%20App.%20","structural_citation":"§ 10.1 (General)","citation_basis":"section_number","char_start":33355,"char_end":34902}},{"pattern_key":"platform_claims_ownership","pattern_family":"ip_ownership","risk_rating":"high","confidence":"medium","stance_key":"content_ownership","stance_value":"platform_claims_or_reserves_rights","evidence":"These Terms of Service (these “Terms”) describe the terms and conditions by which you may access and/or use the website(s), including https://www.luel.ai , the companion mobile applications for Apple and/or Google (as each of those terms is defined below) devices (the “Apps”), and any and all related software, documentation, and online, mobile-enabled, and/or digital services (collectively, the “Service”) provided...","reason":"The clause appears to reserve or claim ownership rights for the platform.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"governing_law_disputes","quote":"These Terms of Service (these “Terms”) describe the terms and conditions by which you may access and/or use the website(s), including https://www.luel.ai , the companion mobile applications for Apple and/or Google (as each of those terms is defined below) devices (the “Apps”), and any and all related software, documentation, and online, mobile-enabled, and/or digital services (collectively, the “Service”) provided by Luel Inc. 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THESE TERMS CONTAIN A MANDATORY INDIVIDUAL ARBITRATION PROVISION IN SECTION 16.3 (THE “ARBITRATION AGREEMENT”) AND A CLASS ACTION/JURY TRIAL WAIVER PROVISION IN SECTION 16.4 (THE “CLASS ACTION/JURY TRIAL WAIVER”) THAT REQUIRE, UNLESS YOU OPT OUT PURSUANT TO THE INSTRUCTIONS IN THE ARBITRATION AGREEMENT, THE EXCLUSIVE USE OF FINAL AND BINDING ARBITRATION ON AN INDIVIDUAL BASIS TO RESOLVE DISPUTES BETWEEN YOU AND US, INCLUDING ANY CLAIMS THAT AROSE OR WERE ASSERTED BEFORE YOU AGREED TO THESE TERMS.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20These%20Terms%20of,TO%20THESE%20TERMS.%20","structural_citation":"AI Addendum › “Last Modified: May 7, 2026”","citation_basis":"heading_path","char_start":107,"char_end":1644}},{"pattern_key":"platform_claims_ownership","pattern_family":"ip_ownership","risk_rating":"high","confidence":"medium","stance_key":"content_ownership","stance_value":"platform_claims_or_reserves_rights","evidence":"YOU ARE SOLELY RESPONSIBLE FOR YOUR INTERACTIONS, INCLUDING SHARING OF INFORMATION, WITH OTHER USERS. 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You further grant, and you represent and warrant that you have all rights necessary to grant, to us, under all of your intellectual property rights, a non-exclusive and royalty-free right and license to use, copy, store, modify, distribute, reproduce, publish, list, make derivative works of, and display your User Content and Output: (i) to maintain and provide the Service; (ii) to improve our products and the Service and for our other business purposes; and (iii) to perform such other actions as described in our Privacy Notice or as authorized by you in connection with your use of the Service.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20We%20claim%20no,use%20of%20the%20Service.","structural_citation":"§ 4.1 (General)","citation_basis":"section_number","char_start":9108,"char_end":10662}},{"pattern_key":"platform_claims_ownership","pattern_family":"ip_ownership","risk_rating":"high","confidence":"medium","stance_key":"content_ownership","stance_value":"platform_claims_or_reserves_rights","evidence":"The Service contains data, information, and/or other content, such as reputational or status indicators, in-world currency, and/or fictional property representing virtual achievements (for instance, badges, trophies, and/or powers) (collectively, “Luel Property”). 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You represent and warrant that: (i) the account, order, and Payment Method information you supply to us and/or to Payment Processor, as applicable, is true, accurate, correct, and complete; (ii) you are duly authorized to use the Payment Method(s); (iii) you will pay any and all charges incurred by users of your Payment Method in connection with the Service, including any applicable Fees (at the prices in effect when such charges are incurred) and Taxes; (iv) charges incurred by you will be honored by your Payment Method company; and (v) you will report to us any unauthorized or prohibited access to or use of your Subscription and/or password(s) or other authentication credentials.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20General.%20To%20make,other%20authentication%20credentials.%20","structural_citation":"§ 8.5 (Your Payment Method)","citation_basis":"section_number","char_start":30280,"char_end":32063}},{"pattern_key":"platform_claims_ownership","pattern_family":"ip_ownership","risk_rating":"high","confidence":"medium","stance_key":"content_ownership","stance_value":"platform_claims_or_reserves_rights","evidence":"You acknowledge that we may, from time to time, issue upgraded versions of the Apps, and may automatically electronically upgrade the version of the App that you are using on your mobile device. You consent to such automatic upgrading on your mobile device, and you understand and acknowledge that the terms and conditions of these Terms will apply to all such upgrades. Any third-party code that may be incorporated ...","reason":"The clause appears to reserve or claim ownership rights for the platform.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"output_ownership","quote":"You acknowledge that we may, from time to time, issue upgraded versions of the Apps, and may automatically electronically upgrade the version of the App that you are using on your mobile device. You consent to such automatic upgrading on your mobile device, and you understand and acknowledge that the terms and conditions of these Terms will apply to all such upgrades. Any third-party code that may be incorporated into an App is covered by the applicable open source or third-party license, if any, authorizing use of such code. We or our third-party partners or suppliers retain all right, title, and interest in and to the Apps (and any copies thereof). Any attempt by you to transfer or delegate any of the rights, duties, or obligations hereunder, except as expressly provided for in these Terms, is void. We reserve all rights not expressly granted under these Terms.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=You%20acknowledge%20that%20we,granted%20under%20these%20Terms.","structural_citation":"§ 10.1 (General)","citation_basis":"section_number","char_start":34902,"char_end":35777}},{"pattern_key":"platform_claims_ownership","pattern_family":"ip_ownership","risk_rating":"high","confidence":"medium","stance_key":"content_ownership","stance_value":"platform_claims_or_reserves_rights","evidence":"These Terms will be governed by the laws of the State of California, without respect to its conflict of laws principles. 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WE EXPRESSLY DISCLAIM ALL LIABILITY IN RESPECT OF ACTIONS TAKEN OR NOT TAKEN BASED ON ANY CONTENT OBTAINED IN CONNECTION WITH THE SERVICE.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20THE%20CONTENT%20PROVIDED,CONNECTION%20WITH%20THE%20SERVICE.","structural_citation":"§ 14 (No Professional Advice)","citation_basis":"section_number","char_start":41862,"char_end":42573}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. 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Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing us at privacy@luel.ai .","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20If%20you%20are,us%20at%20privacy%40luel.ai%20.","structural_citation":"Privacy Policy › “Nevada Residents”","citation_basis":"heading_path","char_start":29931,"char_end":30268}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal ...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual&#x27;s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws: Ad networks and advertising partners: IP address. Business customers: Content Data (as described above). Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below). Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20We%20disclose%20all,for%20targeted%20advertising%20purposes.","structural_citation":"Privacy Policy › “Personal Data Disclosures, Sales and Targeted Advertising”","citation_basis":"heading_path","char_start":30659,"char_end":31920}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Health data, including information regarding an individual&#x27;s medical history, mental or physical health condition, or medical treatment or diagnosis Information about an individual&#x27;s sexual orientation, sex life or status as transgender or non-binary We only use or disclose sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services ...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Health data, including information regarding an individual&#x27;s medical history, mental or physical health condition, or medical treatment or diagnosis Information about an individual&#x27;s sexual orientation, sex life or status as transgender or non-binary We only use or disclose sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal data without the purpose of inferring characteristics about the relevant individual, and we do not sell sensitive personal data or process or otherwise share sensitive personal data for the purpose of targeted advertising.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Health%20data%2C%20including,purpose%20of%20targeted%20advertising.","structural_citation":"Privacy Policy › “Biometric data”","citation_basis":"heading_path","char_start":32155,"char_end":33115}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including: the categories of personal data colle...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including: the categories of personal data collected; the categories of sources of the personal data; the purposes for which the personal data were collected; the categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed; the categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and the categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold. Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Depending%20on%20your,the%20personal%20data.%20","structural_citation":"Privacy Policy › “Your Additional U.S. Privacy Choices”","citation_basis":"heading_path","char_start":33983,"char_end":35481}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data. Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes. Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain ta...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"data_retention","quote":"Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data. Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes. Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes. Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties. Right to Deletion: The right to have us delete personal data we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party). Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Right%20to%20Control,otherwise%20permitted%20by%20law.","structural_citation":"Privacy Policy › “Your Additional U.S. Privacy Choices”","citation_basis":"heading_path","char_start":35481,"char_end":36942}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"If you are a Contributor, you hereby grant to Luel a perpetual, irrevocable, worldwide, sublicensable, transferable, and non-exclusive license to use, reproduce, modify, adapt, publish, distribute, publicly perform, publicly display, sell, sublicense, and create derivative works of your User Content, including any and all personal information, biometric data (including face geometry, voiceprints, and voice charact...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"If you are a Contributor, you hereby grant to Luel a perpetual, irrevocable, worldwide, sublicensable, transferable, and non-exclusive license to use, reproduce, modify, adapt, publish, distribute, publicly perform, publicly display, sell, sublicense, and create derivative works of your User Content, including any and all personal information, biometric data (including face geometry, voiceprints, and voice characteristics), voice, likeness, image, and other identifying attributes embedded therein (collectively, “Contributor Data”), for the purpose of operating the Service, including selling, licensing, and transferring your User Content and Contributor Data to Enterprises. You expressly acknowledge and agree that the rights granted herein include the creation, training, and use of synthetic, digital, or simulated representations of your User Content, including but not limited to your Contributor Data (“Digital Replicas”), whether generated or reproduced by artificial intelligence or other technologies now known or hereafter developed. You grant Luel the unrestricted right to develop, train, reproduce, display, perform, distribute, publish, transmit, and otherwise exploit such Digital Replicas for the purpose of operating the Service. All Digital Replicas and any derivative works or outputs created therefrom shall be deemed derivative works owned exclusively by Luel, including all associated intellectual property and proprietary rights, and you hereby irrevocably assign any and all such rights to Luel.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20If%20you%20are,such%20rights%20to%20Luel.","structural_citation":"§ 4.2 (Contributors)","citation_basis":"section_number","char_start":10692,"char_end":12219}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal ...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual&#x27;s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws: Ad networks and advertising partners: IP address. Business customers: Content Data (as described above). Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below). Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20We%20disclose%20all,for%20targeted%20advertising%20purposes.","structural_citation":"Privacy Policy › “Personal Data Disclosures, Sales and Targeted Advertising”","citation_basis":"heading_path","char_start":32423,"char_end":33684}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Health data, including information regarding an individual&#x27;s medical history, mental or physical health condition, or medical treatment or diagnosis Information about an individual&#x27;s sexual orientation, sex life or status as transgender or non-binary We only use or disclose sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services ...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Health data, including information regarding an individual&#x27;s medical history, mental or physical health condition, or medical treatment or diagnosis Information about an individual&#x27;s sexual orientation, sex life or status as transgender or non-binary We only use or disclose sensitive personal data where reasonably necessary and proportionate for the purposes of providing products and performing services you have requested, verifying and improving the products and services we provide, detecting security incidents, fraud, and other illegal actions, ensuring the physical safety of natural persons, performing services on behalf of the business, or short-term transient use. We only collect and process sensitive personal data without the purpose of inferring characteristics about the relevant individual. Where you submit Content Data through the Service, the sensitive personal data embedded in it — including biometric data such as voice characteristics — is licensed and transferred to business customers as part of the marketplace transaction you consented to when you submitted that content, and that transfer is treated as a sale of sensitive personal data under certain privacy laws. Apart from that licensed marketplace transaction, we do not sell sensitive personal data, and we do not process or otherwise share sensitive personal data for the purpose of targeted advertising.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Health%20data%2C%20including,purpose%20of%20targeted%20advertising.","structural_citation":"Privacy Policy › “Biometric data”","citation_basis":"heading_path","char_start":33919,"char_end":35324}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including: the categories of personal data colle...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights: Right to Know: The right to confirm whether we are processing personal data about you and, under California law only, to obtain certain personalized details about the personal data we have collected about you, including: the categories of personal data collected; the categories of sources of the personal data; the purposes for which the personal data were collected; the categories of personal data disclosed to third parties (if any), and the categories of recipients to whom this personal data were disclosed; the categories of personal data shared for targeted advertising purposes (if any), and the categories of recipients to whom the personal data were disclosed for these purposes; and the categories of personal data sold (if any) and the categories of third parties to whom the personal data were sold. Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Depending%20on%20your,the%20personal%20data.%20","structural_citation":"Privacy Policy › “Your Additional U.S. Privacy Choices”","citation_basis":"heading_path","char_start":36192,"char_end":37690}},{"pattern_key":"personal_data_sale","pattern_family":"privacy_sharing","risk_rating":"high","confidence":"medium","stance_key":"data_sharing","stance_value":"sale_or_sell","evidence":"Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data. Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes. Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain ta...","reason":"The clause permits sale of personal data or information.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data. Right to Control Over Automated Decision-Making / Profiling: The right to direct us not to use automated decision-making or profiling for certain purposes. Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes. Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties. Right to Deletion: The right to have us delete personal data we maintain about you. If you are a resident of the State of California under the age of 18, you may also request and obtain removal of user-generated content you have posted on our platform (though please note that such a request does not ensure complete or comprehensive removal of all user-generated content, particularly where user-generated content has been republished or reposted by another user or third party). For content you have submitted that has already been licensed to a business customer , the limit is precise and we would rather state it than imply more: we stop offering that content for further licensing, revoke the access of business customers who still hold it, and delete the copies we control; we cannot retrieve a copy already downloaded by a business customer or remove your data from a model already trained on it.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Right%20to%20Control,trained%20on%20it.%20","structural_citation":"Privacy Policy › “Your Additional U.S. Privacy Choices”","citation_basis":"heading_path","char_start":37690,"char_end":39140}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller&#x27;s instructions. This Privacy Notice describes our privacy practices...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller&#x27;s instructions. This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. However, this Privacy Notice does not cover or address how marketplace companies may process personal data when they use our services, or how we may process personal data on their behalf in accordance with their instructions where we are acting as their processor. As a result, we recommend referring to the privacy notice of the marketplace company with which you have a relationship for information on how they engage processors, like us, to process personal data on their behalf. In addition, we are generally not permitted to respond to individual requests relating to personal data we process on behalf of marketplace companies, so we recommend directing any requests to the relevant entity.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Data%20protection%20laws,to%20the%20relevant%20entity.","structural_citation":"Privacy Policy › “Our Role in Processing Personal Data”","citation_basis":"heading_path","char_start":1501,"char_end":2673}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"Important: As a data marketplace, we facilitate the sale of your content to AI companies. That is the core function of our platform. We disclose or otherwise make available personal data in the following ways: To Business Customers: We license access to your uploaded content to AI companies for their internal training, evaluation, and model-development purposes. Business customers receive use rights subject to con...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"training_use","quote":"Important: As a data marketplace, we facilitate the sale of your content to AI companies. That is the core function of our platform. We disclose or otherwise make available personal data in the following ways: To Business Customers: We license access to your uploaded content to AI companies for their internal training, evaluation, and model-development purposes. Business customers receive use rights subject to contractual restrictions and are not permitted to redistribute the content. Under certain U.S. state privacy laws, this exchange of personal data for value may be classified as a “sale” or “sharing” regardless of how the underlying intellectual property rights are structured — see the Additional U.S. Privacy Disclosures section. To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20Important%3A%20As%20a,the%20sections%20above.%20","structural_citation":"Privacy Policy › “Our Disclosure of Personal Data”","citation_basis":"heading_path","char_start":14083,"char_end":15595}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf. To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services. In Con...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf. To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services. In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets. To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use; to detect, suppress, or prevent fraud; to reduce credit risk and collect debts owed to us; to protect the health and safety of us, our customers, or any person; or as otherwise required by applicable law.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=Depending%20on%20the%20applicable,required%20by%20applicable%20law.","structural_citation":"Privacy Policy › “Our Disclosure of Personal Data”","citation_basis":"heading_path","char_start":15595,"char_end":17294}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction.","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20With%20Your%20Consent,your%20consent%20or%20direction.","structural_citation":"Privacy Policy › “Our Disclosure of Personal Data”","citation_basis":"heading_path","char_start":17297,"char_end":17439}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform. In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example: Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt-out of ads personalization feature).","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20We%20engage%20third,ads%20personalization%20feature).%20","structural_citation":"Privacy Policy › “Targeted Advertising Preferences”","citation_basis":"heading_path","char_start":20324,"char_end":21949}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual&#x27;s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws: Ad networks and advertising partners: IP address. Business customers: Content Data (as described above). Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below). Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20We%20disclose%20all,for%20targeted%20advertising%20purposes.","structural_citation":"Privacy Policy › “Personal Data Disclosures, Sales and Targeted Advertising”","citation_basis":"heading_path","char_start":30659,"char_end":31920}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"California&#x27;s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. It is company policy that we do not disclose personal information to third parties for their direct marketing purposes ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"California&#x27;s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. It is company policy that we do not disclose personal information to third parties for their direct marketing purposes if a consumer has exercised their right to opt out. To opt out of having your personal information disclosed to third parties for their direct marketing purposes, please follow the instructions for opting out of targeted advertising and personal data sales.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20California%26%23x27%3Bs%20%E2%80%9CShine%20the,and%20personal%20data%20sales.","structural_citation":"Privacy Policy › “Shine the Light”","citation_basis":"heading_path","char_start":41824,"char_end":42499}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"The EU-U.S. Data Privacy Framework was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for personal data transferred to a company participating in the EU-U.S. Data Privacy Framework. If we transfer any personal data about you from the EEA to a third party outside the EEA who is participating in the EU-U.S. Data Privacy Framework, we may rely on their participat...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"The EU-U.S. Data Privacy Framework was designed by the U.S. Department of Commerce and the European Commission to ensure adequate protection for personal data transferred to a company participating in the EU-U.S. Data Privacy Framework. If we transfer any personal data about you from the EEA to a third party outside the EEA who is participating in the EU-U.S. Data Privacy Framework, we may rely on their participation in the Framework to ensure adequate protection for personal data so transferred.","source_url":"https://www.luel.ai/privacy","deep_link":"https://www.luel.ai/privacy#:~:text=%20The%20EU-U.S.%20Data,personal%20data%20so%20transferred.","structural_citation":"Privacy Policy › “EU-U.S. Data Privacy Framework”","citation_basis":"heading_path","char_start":52606,"char_end":53108}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"You affirm, represent, and warrant the following: (a) you have obtained, and are solely responsible for obtaining, all necessary rights, licenses, consents, and permissions required by Applicable Law to provide User Content relating to third parties and grant the license set forth in this Section; (b) your User Content and Output and our use thereof as contemplated by these Terms and the Service will not violate a...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"output_ownership","quote":"You affirm, represent, and warrant the following: (a) you have obtained, and are solely responsible for obtaining, all necessary rights, licenses, consents, and permissions required by Applicable Law to provide User Content relating to third parties and grant the license set forth in this Section; (b) your User Content and Output and our use thereof as contemplated by these Terms and the Service will not violate any Applicable Law or infringe any rights of any third party, including, but not limited to, any intellectual property rights, privacy rights and confidentiality rights; (c) you will not upload or make available through the Service, either directly or by other means, any personal information of children under 13 or the applicable age of digital consent; (d) your User Content does not include sexually suggestive content; hate speech or direct attacks on an individual or group; content that is abusive, harassing, defamatory, vulgar, libelous, or invasive of another&#x27;s privacy; sexist or racially, ethnically, or otherwise discriminatory content; content that contains self-harm or excessive violence; impostor profiles; content in furtherance of harmful or illegal activities; malicious programs or code; any person&#x27;s personal information without such person&#x27;s consent; spam messages; and/or otherwise objectionable content; and (e) your content does not include any third-party images or audio.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20You%20affirm%2C%20represent%2C,third-party%20images%20or%20audio.","structural_citation":"§ 4.4 (Representations and Warranties)","citation_basis":"section_number","char_start":12435,"char_end":13866}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"We may collect, or you may provide to us, diagnostic, technical, usage, and/or related information, including information about your computers, mobile devices, systems, and software (collectively, “Usage Data”). All Usage Data is and will be owned solely and exclusively by us, and, to the extent any ownership rights in or to the Usage Data vest in you, you hereby assign to us all rights (including intellectual pro...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"privacy_data_use","quote":"We may collect, or you may provide to us, diagnostic, technical, usage, and/or related information, including information about your computers, mobile devices, systems, and software (collectively, “Usage Data”). All Usage Data is and will be owned solely and exclusively by us, and, to the extent any ownership rights in or to the Usage Data vest in you, you hereby assign to us all rights (including intellectual property rights), title, and interest in and to same. Accordingly, we may use, maintain, and/or process the Usage Data or any portion thereof for any lawful purpose, including, without limitation: (a) to provide and maintain the Service; (b) to improve our products and services (including the Service), and to develop new products, services, and/or features; (c) to monitor your usage of the Service; (d) for research and analytics, including, without limitation, data analysis, identifying usage trends, and/or customer research; and (e) to share analytics and other derived Usage Data with third parties, solely in de-identified or aggregated form. The Service may contain technological measures designed to prevent unauthorized or illegal use of the Service; you understand and acknowledge that we may use these and other lawful measures to verify your compliance with these Terms and to enforce our rights, including intellectual property rights, in and to the Service.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20We%20may%20collect%2C,and%20to%20the%20Service.","structural_citation":"§ 5.3 (Usage Data)","citation_basis":"section_number","char_start":19760,"char_end":21149}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"The Service may include non-public, proprietary, or confidential information of Luel and/or of other Users (“Confidential Information”). Confidential Information includes any information that should reasonably be understood to be confidential given the nature of the information and the circumstances of disclosure, including non-public business, product, technology, and marketing information. You will: (a) protect ...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"confidentiality","quote":"The Service may include non-public, proprietary, or confidential information of Luel and/or of other Users (“Confidential Information”). Confidential Information includes any information that should reasonably be understood to be confidential given the nature of the information and the circumstances of disclosure, including non-public business, product, technology, and marketing information. You will: (a) protect and safeguard the confidentiality of all Confidential Information with at least the same degree of care as you would use to protect your own highly sensitive confidential information, but in no event with less than a reasonable degree of care; (b) not use any Confidential Information for any purpose other than to exercise your rights, or to perform your obligations, under these Terms; and (c) not disclose any Confidential Information to any person or entity, except your service providers or financial or legal advisors who/that (i) need to know the Confidential Information and (ii) are bound by non-use and non-disclosure restrictions at least as restrictive as those set forth in this Section.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20The%20Service%20may,forth%20in%20this%20Section.","structural_citation":"§ 6 (Confidential Information)","citation_basis":"section_number","char_start":23511,"char_end":24629}},{"pattern_key":"third_party_sharing","pattern_family":"privacy_sharing","risk_rating":"medium","confidence":"medium","stance_key":"data_sharing","stance_value":"third_party_or_vendor_sharing","evidence":"To use any App, you must have a mobile device that is compatible with such App. Luel does not warrant that any App will be compatible with your mobile device. You may use mobile data in connection with an App and may incur additional charges from your wireless provider in connection with such App. You understand and acknowledge that you are solely responsible for any such charges. We hereby grant you a non-exclusi...","reason":"The clause permits disclosure or sharing with third parties, affiliates, vendors, or subprocessors.","matcher_version":"clause-intelligence-2026-06-17.1","citation":{"surface":"commercial_use","quote":"To use any App, you must have a mobile device that is compatible with such App. Luel does not warrant that any App will be compatible with your mobile device. You may use mobile data in connection with an App and may incur additional charges from your wireless provider in connection with such App. You understand and acknowledge that you are solely responsible for any such charges. We hereby grant you a non-exclusive, limited, non-transferable, and freely revocable license to use a compiled code copy of the App(s) under your User Account on one (1) or more mobile devices owned or controlled solely by you (except to the extent the applicable App store platform permits any shared access and/or use of the App), solely in accordance with these Terms. The foregoing license grant is not a sale of any App or of any copy thereof. You may not: (a) modify, disassemble, decompile, or reverse engineer any App, except to the extent that such restriction is expressly prohibited by Applicable Law; (b) rent, lease, loan, resell, sublicense, distribute, or otherwise transfer any App to any third party, or use any App to provide time sharing or similar services for any third party; (c) make any copies of any App; (d) remove, circumvent, disable, damage, or otherwise interfere with security-related features of any App, features that prevent or restrict use or copying of any content accessible through any App, or features that enforce limitations on use of the Apps; or (e) delete the copyright or other proprietary rights notices on any App.","source_url":"https://www.luel.ai/terms","deep_link":"https://www.luel.ai/terms#:~:text=%20To%20use%20any,on%20any%20App.%20","structural_citation":"§ 10.1 (General)","citation_basis":"section_number","char_start":33355,"char_end":34902}}]},"tier_conditions":[],"disclaimer":"Informational only, not legal advice. Every finding is a verbatim quote from a fully-read, gate-verified document; verify via snapshot_sha256 + wayback_url. Partially-verified platforms show findings only from their verified document(s).","benchmark":{"disclaimer":"Automated assessment against a published rubric — not legal advice.","bands":[]},"@jsonld":{"@context":"https://schema.org","@type":"Dataset","name":"Luel — AI policy risk findings","description":"Verified, cited policy findings for Luel across 13 risk surfaces.","url":"https://airinetwork.com/platform/luel","creator":{"@type":"Organization","name":"AIRIN","url":"https://airinetwork.com"},"isAccessibleForFree":true,"license":"https://airinetwork.com/terms","additionalProperty":[{"@type":"PropertyValue","name":"verification","value":"partially_verified"},{"@type":"PropertyValue","name":"tier_condition_count","value":0}],"hasPart":[],"variableMeasured":[]}}