Privacy Policy

Introduction

1. This Privacy Policy governs the website https://sqn.lucroranalytics.com ("Site") owned and operated by Lucror Analytics Pte. Ltd. For the purposes of this Privacy Policy, the terms "Lucror", "We", "Us" and "Our" means Lucror Analytics Pte. Ltd. For more information about Us, see Section 13 below.
2. We are committed to safeguarding the privacy of the visitors of the Site, service users and all other persons who access the Site (herein referred to as “You” and “Your” as the context may require). This Privacy Policy describes the manner in which We collect, store, process, use, transmit, transfer and disclose the information that You disclose to Us or information that We collect, through Your access and/or use of the Site and/or the Services (“ Your Information ”). By accessing and/or using the Site and the Services, You signify Your acceptance of this Privacy Policy and of Us processing Your Information in accordance with the terms of this Privacy Policy. If You do not agree with this Privacy Policy, You should not continue access and/or use of the Site and/or the Services.
3. The Privacy Policy is hereby incorporated into Our Terms of Use and by visiting, accessing and/or using the Site and/or Services, You accept and consent to the terms of this Privacy Policy.
4. We reserve the right to change the terms of this Privacy Policy without notice. You are requested to review this page periodically, to remain aware of any changes. Please refer to Section 6 below for details relating to Our right to amend and/or modify this Privacy Policy.
5. This Privacy Policy applies where We are acting as a data controller with respect to Your Information and does not apply to any third party applications or software that integrate with the Services, or any other third party products, services or businesses, where We are not the controller of Your Information.
6. Lucror aims to comply with the requirements of Singapore’s Personal Data Protection Act 2012 ("PDPA") and the EU’s General Data Protection Regulation (“GDPR”) and respects Your choices in respect of Your Information. Should You have any feedback or enquiries relating to Your Information or if You wish to stop receiving promotional or marketing messages from Us, please contact Us using the contact details provided in Section 13 below.
7. For more information about the PDPA generally, please visit the Personal Data Protection Commission's Website at http://www.pdpc.gov.sg For more information about the GDPR generally, please visit the European Commission’s Website at https://ec.europa.eu/info/law/law-topic/data-protection_en.
8. Please note that all capitalised terms not defined hereunder shall have the meaning ascribed to such term in the Terms of Use.

Collection of Your Information

Our access and/or collection of Your Information depends on how You use Our Services. We have set out below the Information which We may access, collect, handle, transfer, transmit, store, use, deal with and/or disclose.

1. We may process information contained in any enquiry You submit to Us regarding Our Services (" enquiry data "). The enquiry data may be processed for the purposes of offering, marketing and selling relevant Services to You, and to allow You to participate in interactive features of Our Services, if you choose to do so.
2. We may process data about Your use of Our Site and Services ("usage data"). This usage data may include Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and Site navigation paths, as well as information about the timing, frequency and pattern of Your Service use. The source of the usage data is Our Site analytics tracking system. Usage data may be processed for the purposes of analysing the use of the Site and Services, for reporting purposes, and to ensure that content from our Site is presented in the most effective manner for You and for Your computer, tablet, mobile device or other devices.
3. We may process or collect information including, without limitation, operating system, hardware and software versions, , browser type, app and file names and types, unique identifiers, ISP and plugins, from and about the computers, tablets, phones, and other Web-connected devices You use that integrate with Our Services, and We combine this information across different devices that You use.
4. We may process Your account data ("account data") when You register as a Registered User and subscribe to Our Services. Account data may include without limitation, Your name, job title, business email address, Your preferences, business phone number, User Details, and the name of Your employer. The source of the account data is You or your employer, or information publicly available on Your Bloomberg profile or other such service. The account data may be processed for the purposes of operating the Site, providing Our Services, ensuring the security of our Site and Services, maintaining back-ups of our databases, and communicating with You. The legal basis for this processing is Our legitimate business interests, namely the proper administration of Our Site and business, and the performance of a contract between You/Your employer and Us, and/or taking steps to enter into such a contract.
5. We may process information relating to Our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include Your name, job title, business email address, business phone number, the name of Your employer, and information contained in communications between Us and You/Your employer. The source of the customer relationship data is You or Your employer. The customer relationship data may be processed for the purposes of managing Our relationships with customers, communicating with customers, keeping records of those communications, and promoting Our Services to customers.
6. We may process the information that is provided in the course of the use of Our Services (" service data "). This service data may include the portfolios You created and/or uploaded on the Site, financial data, name, job title, business email address, business phone number, and the name of Your employer. The source of the service data is You or Your employer. The service data may be processed for the purposes of operating Our Site, providing You with information, Services that You request from Us or which We feel may interest You, carrying out Our obligations arising from any contracts entered into between You/Your employer and Us, ensuring the security of Our Site and Services, maintaining back-ups of Our databases and communicating with You.
7. We may process information that you provide to Us for the purpose of subscribing to our email notifications ("notification data"). The notification data may be processed for the purpose of sending You relevant notifications regarding Our Services.
8. We may process information contained in, or relating to, any communication that You send to Us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our Site will generate the metadata associated with communications made using the Site contact forms or directed at email addresses in Our domain. The correspondence data may be processed for the purposes of communicating with you, record-keeping and reporting.
9. We may process information that You provide by filling in applications, forms or questionnaires or agreements You or Your employer enter into with Us or in the course of Your establishing or maintaining a customer relationship with Us. We may also ask You to complete surveys that We use for research purposes, although You do not have to respond to them.

Please do not provide or make available any other person's data or information to Us without their express consent.

You have the right to instruct Lucror at any time not to use Your Information covered by this Privacy Policy to provide You with offers and promotions by writing to Us at the address mentioned in Section 13. If You exercise such choice, You will continue to receive communications concerning Your subscription and Services You requested. Note, that the process for opting-out may take time to process.

Providing Your Information to others

1. We store Your Information in Singapore and the United States of America. The hosting facilities for Our Site are situated in the United States of America. We have set out below information about the circumstances in which Your Information may be transferred to countries other than Singapore and the United States of America. Such transfers are necessary to provide the Services set forth in theTerms of Use and to globally operate and provide Our Services. We may disclose Your Information to any member of Our group of companies (this means our subsidiaries, affiliates, our ultimate holding company and all its subsidiaries), including their respective employees, directors, officers, consultants, contractors, agents, and/or representatives and to each of Our respective employees, directors, officers, consultants, contractors, agents, and/or representatives, insofar as reasonably necessary for the purposes and on the legal bases, set out in this Privacy Policy.
2. We may disclose Your Information to Our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. We may disclose Your Information to Our suppliers or subcontractors insofar as reasonably necessary for the purposes of operating Our Site, providing Our Services, ensuring the security of Our Site and Services, maintaining back-ups of our databases, and communicating with You.
4. We may also disclose Your Information to third parties if We either: (a) sell, transfer, merge, amalgamate, consolidate or re-organise any part(s) of Our business, or merge with, acquire or form a joint venture with, any other business, or if there is a change in control or ownership of Lucror, in which case We may disclose Your Information to any prospective buyer, new owner, or other third party involved in such change to Our business; or (b) sell or transfer any of our assets, in which case the information We hold about You may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
5. We may transfer Your information, to third parties if We are under a duty to disclose or share such information in order to comply with any legal obligation, or where We believe in good faith that the law requires it, or at the request of Governmental authorities conducting an investigation or in order to enforce, verify or apply Our Terms of Use and other agreements or policies, or to protect Our rights, property, or safety and the rights, property or safety of Our users, customers or others or to respond to an emergency. Such disclosure may be carried out with or without notice to You.

International transfers of Your Information

1. We have set out below information about the circumstances in which Your Information may be transferred to countries other than Singapore and the United States of America. Such transfers are necessary to provide the Services set forth in theTerms of Use and to globally operate and provide Our Services.
2. Lucror has offices and/or facilities in Singapore, the European Union, and the United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of the European Union and the United States of America (limited to the Privacy Shield framework). Transfers to the European Union and the United States of America will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the Website of the European commission. If You are located in other regions with laws governing data collection and use that may differ from Singapore law and laws of the United States of America, please note that We may transfer Your Information, including Your personal and sensitive information, to a country and jurisdiction that does not have the same data-protection laws as Your jurisdiction.
3. The European Commission has made an "adequacy decision" with respect to the data protection laws of the United States (limited to the Privacy Shield framework). Transfers to the United States will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the Website of the European commission.

Retaining and deleting Your Information

1. This Section 6 sets out Our data retention policies and procedure, which are designed to help ensure that We comply with Our legal obligations in relation to the retention and deletion of Your Information.
2. Your Information that We process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. You Information in relation to the provision of Our services will be retained for a minimum period of five years following the creation of records in Our systems containing said data, and for a maximum period of ten years or until it is reasonable to assume that the purpose for which that Your Information was collected is no longer being served by retention of Your Information and retention is no longer necessary for legal or business purposes.
4. In some cases, it is not possible for Us to specify in advance the periods for which Your Information will be retained. In such cases, We will determine the period of retention based on whether it is reasonable to assume that the purpose for which Your Information was collected is still being served by retention of Your Information and whether retention is still necessary for legal or business purposes.
5. Notwithstanding the other provisions of this Section 6, We may retain Your Information for an extended period when it is the subject of a legal request or obligation, governmental investigation or investigations of possible violations of our terms or policies, or otherwise to prevent harm to any person, including You. We also retain information from accounts disabled for term breaches for at least a year to prevent repeat abuse or other term breaches.
6. Our Site may contain links to Websites of Our affiliates or of other unaffiliated third parties for Your convenience and information. If You access a link to any of these websites, please note that these Websites have their own privacy policies and that We do not accept any responsibility or liability in relation to Your access or use of such third party Websites. Please check these policies before You access and/or submit Your Information to these Websites. Further, We do not make any warranties and expressly disclaim all warranties express or implied, including without limitation, those of merchantability and fitness for a particular purpose, title or non-infringement with respect to any information or services or products that are available or advertised or sold through these third-party Websites.

Amendments

1. We reserve the right, at Our sole discretion, to change, modify, add or remove any or all portions of these Privacy Policy, at any time without any prior written notice to You and such revisions shall be binding on You. Some of the provisions contained in the Privacy Policy may also be superseded by provisions or notices published elsewhere on the Site. It is Your responsibility to review the Privacy Policy and the Site periodically for updates / changes. Your continued use of the Site following the posting of changes will mean that You accept and agree to the revisions.
2. Without prejudice to the foregoing right under provision 7.1 above, We may choose to notify You of significant changes to this Privacy Policy by email on Your registered email ID or through the notification system on the Site.

Your rights

1. When We process Your Information, We do so with Your consent and/or as necessary to provide the Site and Services that You use, operate Our business, meet Our contractual and legal obligations, protect the security of our systems and Our customers, or fulfil other legitimate interests of Lucror, as described in this Privacy Policy. In this Section 8, We have summarised the key rights that You have under data protection law. Some of the rights are complex, and not all of the details have been included in Our summaries under this Privacy Policy. Accordingly, You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. In relation to Your Information, Your principal rights under data protection law are as follows:
   1. the right to access;
   2. the right to rectification;
   3. the right to erasure;
   4. the right to restrict processing;
   5. the right to object to processing;
   6. the right to data portability;
   7. the right to complain to a supervisory authority; and
   8. the right to withdraw consent.

1. You have the right to confirmation as to whether or not We process Your Information and, where We do, access to the Your information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of Your Information concerned and the recipients of Your Information. Provided that the rights and freedoms of others are not affected, We will supply to You a copy of Your Information. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. Where We are legally permitted to do so, We may refuse Your request of access to Your Information. If We refuse Your request, We will tell you the reasons why.
2. You have the right to have any inaccuracies in Your Information rectified and, taking into account the purposes of the processing, to have Your Information which is incomplete, completed.
3. In some circumstances You have the right to the erasure or delete Your Information without undue delay. Those circumstances include without limitation: Your Information is no longer necessary in relation to the purposes for which they were collected or otherwise processed; You withdraw consent to consent-based processing; You object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and/or Your Information has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
4. In some circumstances You have the right to restrict the processing of Your Information. Those circumstances are: You contest the accuracy of Your Information; processing is unlawfol but You oppose erasure; We no longer need Your Information for the purposes of Our processing, but You require Your Information for the establishment, exercise or defence of legal claims; and/or You have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, We may continue to store Your Information. However, We will only otherwise process it: with Your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5. You may be entitled to request copies of Your Information that You have provided to Us in a structured, commonly used, and machine-readable format and/or request Us to transmit this information to another service provider (where technically feasible). This right only applies where We use Your Information on the basis of Your consent or performance of a contract; and where Our use of Your information is carried out by automated means.
6. You have the right to object to Our processing of Your Information on grounds relating to Your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in Us; or the purposes of the legitimate interests pursued by Us or by a third party. If You make such an objection, We will cease to process Your Information unless We can demonstrate compelling legitimate grounds for the processing which override Your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7. You have the right to object to Our processing of Your Information for direct marketing purposes (including profiling for direct marketing purposes). If You make such an objection, We will cease to process Your Information for this purpose.
8. To the extent that the legal basis for Our processing of Your Information is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which You are party or in order to take steps at Your request prior to entering into a contract, and such processing is carried out by automated means,

You have the right to receive Your Information from Us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

1. If You consider that Our processing of Your Information infringes data protection laws, You have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
2. To the extent that the legal basis for Our processing of Your Information is consent, You have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. However, in such event We reserve the right to refuse or limit Your access and use of Our Site, and its features, including Services offered on Our Site.
3. You may exercise any of Your rights in relation to Your Information by written notice to Us, in addition to the other methods specified in this Section 8.

About cookies

1. Cookies are small files or texts used to store information on Web browsers. Cookies are used to store and receive identifiers and other information on computers, phones and other devices. Other technologies, including data that We store on Your Web browser or device, identifiers associated with Your device and other software, are used for similar purposes. Cookies enable Us to offer Services to You and to understand the information that We receive about You, including information about Your use of other websites and apps, whether or not You are registered or logged-in.
   
2. This policy explains how We use cookies and the choices You have.
3. Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a Web browser and will remain valid until its set expiry date, unless deleted by the Registered User before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the Web browser is closed. The cookies that We use may change from time to time as We improve and update the Site and Services:
4. Cookies do not typically contain any information that personally identifies a Registered User, but personal information that We store about You may be linked to the information stored in and obtained from cookies.

Cookies that We use

1. We and our service providers may use cookies for the following purposes:
   1. authentication – Cookies may be used to identify You when You visit Our Site and as You navigate Our Site and Services;
   2. status – Cookies may be used to help us to determine if You are logged into our Site;
   3. personalisation – Cookies may be used to store information about Your preferences and to personalise the Site and Services for You;
   4. security – Cookies may be used as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect Our Site and Services generally;
   5. access – Cookies may be used to save Your User Details, if You login to Our Site, so that We can process the saved information and quickly log You into the Site;
   6. analysis – Cookies may be used to help Us analyse traffic patterns and the use and performance of Our Site and Services;
   7. miscellaneous information – Cookies may be used to the IP address of Your computer, browser type, language, operating system, your mobile device, device ID, geolocation data, the state or country from which You accessed this Site services, the Webpages visited, the date and the time of a visit, the Websites You visited immediately before and after visiting this Site, the number of links You click within this Site, the functions You use on this Site, the databases You view and the searches You request on this Site, the types of information that You read, the data You save on or download from this Site.
   8. cookie consent – We may use cookies to store Your preferences in relation to the use of cookies generally.
   9. We may use Google Analytics or a similar service provider or technology to analyse the use of Our Site. Google Analytics gathers information about the Site use by means of cookies. The information gathered relating to Our Site is used to create reports about the use of Our Site. For more information, please review Google’s privacy policy available at: https://www.google.com/policies/privacy/. To opt out of Google Analytics please click on https://tools.google.com/dlpage/gaoptout.

Managing cookies

1. Most browsers and devices allow You to prevent them from accepting new cookies or alert You when cookies are being sent or disable cookies altogether. Each browser and device is different and manufacturers may change both the settings they make available and how they work at any time; so check the ‘help’ menu of Your browser or device to learn how to change Your cookie preferences or read the additional information about the controls offered by popular browsers at the links below:

   Google chrome: https://support.google.com/chrome/ansWer/95647;

   Internet explorer: https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

   Firefox: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop

   Safari: https://support.apple.com/en-ie/guide/safari/sfri11471/mac

   Opera: https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/

   Microsoft edge browser: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

   Your cookie preferences will be required to be set on each browser or device that You use to surf the internet, including Our Site. Additional cookie management tools and solutions may be available in Your jurisdiction. Since cookies allow You to take advantage of some of the Site’s essential features, We recommend that You leave them turned on.

2. Blocking all cookies will have a negative impact upon the usability of many Websites, including the Site.
3. If You block cookies, You may not be able to use all the features on Our Site, including those related to the Services.

Security Practices

1. We strive to ensure the security, integrity and privacy of Your information and to protect Your information against unauthorised access or unauthorised alteration, disclosure or destruction. While We have adopted measures to protect the privacy of Your Information that We have access to and possess in Our records, no security system is impenetrable, and unanticipated system failures or the efforts of malicious actors are an unfortunate reality on the internet. Therefore, We cannot guarantee that Your Information, whether during transmission through the Internet or while stored on Our systems or otherwise in Our care will be absolutely safe.
2. For the above purpose, We have adopted internal reviews of the data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorised access to systems where Your information is stored.
3. In order to facilitate more effective data protection, We urge You to take steps to keep Your Information safe, by memorising Your passwords, or keeping them in a safe place (separate from Your account information), logging out of user accounts, and closing Your Web browser.

Our details

1. This Site is owned and operated by Lucror Analytics Pte Ltd.
2. We are registered in Singapore under registration number 201005735Z, and our registered office is at Marina One East Tower, 7 Straits View, #05-01, Singapore 018936.
3. Our principal place of business is at the above address.
4. You can contact Us:
   1. by post, to the postal address given above;
   2. using Our Site contact form;
   3. by telephone, on the contact number published on Our Site; or
   4. by email, using general@lucroranalytics.com.

Data protection officer

1. Our data protection officer may be contacted with respect to any complaints or concerns including those pertaining to breach of Privacy Policy or feedback or complaints. Our data protection officer is Mr Stefan Tzschentke. He can be contacted using the contact methods stated in section 13.4 above.

Jurisdiction and applicable law

1. The Privacy Policy shall be governed and construed in accordance with the laws of Singapore, without giving effect to conflicts-of-law principles thereof. With respect to any disputes or claims, You agree to submit to the Singapore courts which shall have exclusive jurisdiction with respect to any legal proceedings that may arise from, in connection with or related to the use of the Site and the Service or from a dispute as to the interpretation or breach of the Privacy Policy.
2. Notwithstanding anything to the contrary in the Privacy Policy, We retain the right to commence proceedings against You for breach of this Privacy Policy in Your country of residence or any other relevant country.