1. Introduction

1.1 This Privacy Policy governs the website www.lucroranalytics.com ("Site") operated by Lucror Analytics Pte. Ltd. For the purposes of this Privacy Policy, "Lucror", "We", "Us" and "Our" means Lucror Analytics Pte. Ltd. For more information about us, see Section 12 below.

1.2 This Privacy Policy (together with our Terms and Conditions, and any other documents referred to in it) sets out the basis on which any personal data will be processed by us, and the choices you can make about the way your information is collected and used.

1.3 We are committed to safeguarding the privacy of our website visitors and service users. Please read the following carefully to understand our views and practices regarding your personal data, and how we will treat it. By using the Site, you signify your acceptance of this Privacy Policy and of us processing your personal data in accordance with the terms of this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Site.

1.4 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.5 Lucror Analytics 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 personal data. Should you have any feedback or enquiries relating to your personal data or if you wish to stop receiving promotional or marketing messages from us, please contact us using the contact details provided in Section 12 below.

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

2. How we use your personal data

2.1 In this Section 2 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

2.2 We may process data about your use of our website 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 website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our website analytics tracking system. Usage data may be processed for the purposes of analysing the use of the website 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 or mobile device. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.3 We may process your account data ("account data"). Account data may include your name, job title, office email address, office phone number, 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 website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.4 We may process the information included in your personal profile on our website ("profile data"). This profile data may include your name, job title, office email address, office phone number, and the name of your employer. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). This service data may include your name, job title, office email address, office phone number, 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 service data may be processed for the purposes of operating our website, providing you with information, products or 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 website 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 website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.6 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 service, if you choose to do so. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.7 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, office email address, office 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 products and services to customers. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.8 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 purposes of sending you the relevant notifications regarding our services. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract.

2.9 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 website will generate the metadata associated with communications made using the website 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. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and the performance of a contract between you/your employer and us, and/or taking steps to enter into such a contract, and communication with users.

2.10 We may process information that you provide by filling in applications, forms or questionnaires you may complete 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.

2.11 If you use the password-protected portions or the contact forms on our Site, or if you communicate with us via email, we may process your data to verify your identity and eligibility to receive certain products and services, to provide information to you about products and services that we believe may be of interest to you, to record your interest in products and services that we offer, and to respond to your requests for information.

2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

2.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.14 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.15 Please do not supply any other person's personal data to us, unless we prompt you to do so or unless it is necessary to do so for the performance of a contract between you/your employer and us.

3. Providing your personal data to others

3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

3.2 We may disclose your personal data 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.

3.3 We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, and communicating with you.

3.4 In the event that Lucror sells or buys any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

3.5 In the event that Lucror or substantially all of its assets are acquired by a third party, personal data held by us about its customers may be one of the transferred assets.

3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may also disclose your personal data in order to enforce or apply our Terms and Conditions, and other Agreements, or to protect the rights, property, or safety of Lucror, our customers or others.

4. International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries other than Singapore.

4.2 Lucror has offices and/or facilities in Singapore, the European Union, and the United States. The European Commission has made an "adequacy decision" with respect to the data protection laws of the European Union and the United States (limited to the Privacy Shield framework). Transfers to the European Union and 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.

4.3 The hosting facilities for our website are situated in the United States. 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.

5. Retaining and deleting personal data

5.1 This Section 5 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 personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

Usage data, account data, profile data, service data, enquiry data, customer relationship data, notification data, correspondence data, and other personal data 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 personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes.

5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data 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 that personal data was collected is still being served by retention of the personal data and whether retention is still necessary for legal or business purposes.

5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.6 Our Site may contain links to websites of our affiliates or of third parties. If you follow 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 for these policies. Please check these policies before you submit any personal data to these websites.

6. Amendments

6.1 We may revise this Privacy Policy at any time by amending this page. You should check this page from time to time to take notice of any changes we made, as they are binding for you.

6.2 Some of the provisions contained in this Privacy Policy may be superseded by provisions or notices published elsewhere on our Site. Your continued use of our Site following the revisions, updates, amendments or changes to this Privacy Policy will mean that you accept those changes.

6.3 We may notify you of significant changes to this policy by email or through the notification system on the Site.

7. Your rights

7.1 In this Section 7, we have summarised the 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. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

You have the right to ask us not to process and/or to delete your personal data. You can exercise this right at any time by contacting us using the contact details provided in Section 12 of this document.

7.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are 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 the personal data have 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.

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and 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 personal data. 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.

7.7 You have the right to object to our processing of your personal data 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 the personal 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.

7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.9 To the extent that the legal basis for our processing of your personal data 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 personal data 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.

7.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

7.11 To the extent that the legal basis for our processing of your personal 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.

7.12 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.

8. About cookies

Details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and login status may be stored in a "cookie" on your computer, for the provision of our services or otherwise.

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2 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 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.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9. Cookies that we use

9.1 We may use cookies for the following purposes:

(a) authentication - we may use cookies to identify you when you visit our website and as you navigate our website;

(b) status - we may use cookies to help us to determine if you are logged into our website;

(c) personalisation - we may use cookies to store information about your preferences and to personalise the website for you;

(d) security - we may use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;

(e) analysis - we may use cookies to help us analyse the use and performance of our website and services; and

(f) cookie consent - we may use cookies to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/ .

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1 This website is owned and operated by Lucror Analytics Pte Ltd.

12.2 We are registered in Singapore under registration number 201005735Z, and our registered office is at 20 Cross Street, #02-13 China Square Central, 048422 Singapore.

12.3 Our principal place of business is at the above address.

12.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website; or

(d) by email, using general@lucroranalytics.com.

13. Data protection officer

13.1 Our data protection officer is Mr Stefan Tzschentke. He can be contacted using the contact methods stated in section 12.4 above.

14. Jurisdiction and applicable law

14.1 The Singapore courts shall have exclusive jurisdiction over any claim arising from, or related to, this Privacy Policy or use of the Site, although we retain the right to bring proceedings against you for breach of the Privacy Policy in your country of residence or any other appropriate forum.

14.2 This Privacy Policy and any dispute or claim arising out of or in connection with them or subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of Singapore.