1. Introduction
This Privacy Policy governs the website www.lucroranalytics.com and related Lucror-operated portals, including esg.lucroranalytics.com (collectively, the "Site"), operated by Lucror Analytics Pte. Ltd. ("Lucror", "we", "us", or "our").
We are committed to safeguarding the privacy of visitors to the Site, users of our services, and all other persons who interact with us through the Site (collectively, "you").
This Privacy Policy explains how we collect, use, store, transfer, disclose, and otherwise process personal data that you provide to us or that we collect through your access to or use of the Site and related services. By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data in accordance with this Privacy Policy. This Privacy Policy forms part of and is incorporated into our Terms of Use. If you do not agree with this Privacy Policy, you should not access or use the Site.
Lucror aims to comply with the requirements of Singapore's Personal Data Protection Act 2012 (PDPA) and the EU General Data Protection Regulation (GDPR) where applicable.
2. How We Use Your Personal Data
We may process your personal data for the following purposes:
- to operate and maintain the Site and related services;
- to provide access to password-protected or subscription-only areas of the Site;
- to process registrations, subscriptions, trials, and account requests;
- to communicate with you regarding our services, reports, publications, and account-related matters;
- to respond to enquiries and provide customer support;
- to manage customer and prospective customer relationships;
- to analyse use of the Site and improve the Site's functionality and performance;
- to maintain the security and integrity of the Site and our systems;
- to send service notices, updates, and administrative communications;
- to send marketing communications where permitted by law or where you have consented;
- to comply with legal and regulatory obligations; and
- for other purposes disclosed at the time the data is collected or with your consent.
Certain communications relating to account management, subscription status, security, and operation of the Site are considered necessary and you may not be able to opt out of receiving them.
3. Categories of Personal Data We Collect
The personal data we collect depends on how you interact with the Site and our services.
3.1 Usage Data
We may process data about your use of the Site and services ("usage data"). This may include:
- IP address
- geographic location
- browser type and version
- operating system
- referral source
- pages viewed
- navigation paths
- timing and frequency of visits
- login status and session activity
Usage data is used to analyse and improve the Site, support reporting, and ensure that the Site is presented effectively.
3.2 Account Data
We may process your account data ("account data"). This may include:
- name
- job title
- business email address
- business phone number
- employer name
- login credentials
- user preferences
The source of this information may be you, your employer, or in some cases publicly available professional sources or directories. Account data is used for account administration, access control, service delivery, security, and communication.
3.3 Profile Data
We may process information included in your profile on the Site ("profile data"), such as:
- name
- job title
- business email address
- business phone number
- employer name
Profile data is used to enable and monitor your use of the Site and services.
3.4 Service Data
We may process personal data provided in the course of your use of our services ("service data"). For the Credit Intelligence portal, this may include:
- your name
- job title
- business contact details
- employer details
- subscription entitlements
- report access history
- saved preferences
- information submitted through portal features or requests
Service data is processed solely for the purpose of providing and operating the services requested by you or your employer, including enabling access to subscribed content, managing research distribution, maintaining security, and communicating with users.
3.5 Enquiry Data
We may process information contained in enquiries submitted by you regarding our services ("enquiry data"). This may be used to respond to requests, offer relevant services, and manage business development communications.
3.6 Customer Relationship Data
We may process information relating to our relationships with customers and prospective customers ("customer relationship data"), including:
- names
- business contact details
- employer details
- communications and meeting notes
- subscription and relationship history
This data is used to manage customer relationships, keep records of communications, and administer our services.
3.7 Notification Data
We may process information that you provide for the purpose of receiving notifications, newsletters, or updates ("notification data").
3.8 Correspondence Data
We may process information contained in or relating to communications that you send to us ("correspondence data"), including the content of the communication and associated metadata.
3.9 Form, Survey, and Application Data
We may process information you provide through applications, forms, questionnaires, surveys, or agreements you or your employer enter into with us. Please do not provide another person's personal data to us unless you are authorised to do so and it is necessary for the relevant purpose.
4. Legal Bases for Processing
Where GDPR applies, we process personal data on one or more of the following legal bases:
- your consent;
- the performance of a contract to which you or your employer are party, or steps taken at your request before entering into such a contract;
- our legitimate interests, including the proper administration of our business, the provision of research and analytical services to institutional clients, operation of the Site, marketing of relevant services, security monitoring, record-keeping, and legal protection;
- compliance with legal and regulatory obligations; or
- where necessary to protect vital interests.
5. Disclosure of Your Personal Data
We may disclose your personal data to:
- our affiliates and group companies where reasonably necessary;
- employees, contractors, and consultants who need access for operational purposes;
- cloud hosting providers, IT service providers, analytics providers, and other technology vendors;
- professional advisers, auditors, insurers, and legal counsel;
- regulators, law enforcement authorities, courts, or other authorities where required by law;
- prospective purchasers, investors, or counterparties in connection with a merger, acquisition, financing, or sale of business or assets.
Any such disclosure will be limited to what is reasonably necessary for the purposes described in this Privacy Policy.
6. Service Providers
We may engage third-party service providers to support the operation and delivery of the Site and services, including hosting providers, analytics providers, customer communication tools, and other technology vendors. These service providers may process personal data on our behalf solely for the purpose of providing services to us and are contractually required to protect the confidentiality and security of such data and to process it only in accordance with our instructions and applicable data protection laws. They are not permitted to use personal data for their own marketing or independent commercial purposes.
7. International Transfers of Personal Data
Your personal data may be transferred to and processed in countries outside your jurisdiction, including Singapore, the United States, and the European Union, in order to operate the Site and provide services.
Where personal data originating from the European Economic Area is transferred outside the EEA, Lucror implements appropriate safeguards such as Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms permitted under applicable data protection law.
Where personal data originating from Singapore is transferred outside Singapore, Lucror takes reasonable steps to ensure that the recipient provides a standard of protection to the personal data that is comparable to the protection under the PDPA, whether through contractual safeguards, internal policies, or other legally recognised transfer mechanisms.
By using the Site, you acknowledge that your personal data may be transferred internationally in accordance with this Privacy Policy.
8. Retention of Personal Data
We will not retain personal data for longer than necessary for the purposes for which it was collected. In most cases, records relating to website accounts, subscriptions, enquiries, customer relationships, and service usage are retained in accordance with Lucror's internal records management and compliance policies and generally for a minimum period of five (5) years, unless a longer period is required by legal, regulatory, accounting, or operational requirements.
We may retain data for longer where necessary to:
- comply with legal obligations;
- resolve disputes;
- enforce agreements;
- maintain records relevant to regulatory or audit requirements; or
- detect or prevent fraud, abuse, or security incidents.
9. Security Incidents
Lucror maintains administrative, technical, and organisational safeguards designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. If Lucror becomes aware of a security incident involving personal data under its control, Lucror will investigate the incident and take appropriate remedial measures. Where required by applicable law, Lucror will notify affected individuals and/or relevant authorities of a personal data breach.
10. Security Practices
While we take reasonable measures to protect personal data, no security system is completely secure. Accordingly, we cannot guarantee that personal data transmitted over the internet or stored on our systems will be absolutely secure. Users are encouraged to protect their credentials and to log out of password-protected areas when using shared devices.
11. Log Data and Security Monitoring
To maintain the security and integrity of the Site and services, Lucror may collect and analyse system logs and related operational data ("Log Data"). Log Data may include:
- IP addresses
- login activity
- access timestamps
- session records
- browser and device information
- system events
- actions performed within password-protected areas of the Site
This information is used solely for purposes such as maintaining platform security, detecting unauthorised access or suspicious activity, troubleshooting technical issues, ensuring service reliability, and supporting internal audits and security investigations.
12. Your Consent
Personal data is processed in accordance with this Privacy Policy. By using the Site, you consent to such processing and confirm that any information you provide is accurate.
13. No Sale of Personal Data
Lucror does not sell, rent, or otherwise disclose personal data to third parties for their own marketing or commercial purposes. Personal data may be shared only where necessary to operate the Site and services, comply with legal or regulatory obligations, enforce agreements, or as otherwise described in this Privacy Policy.
14. Automated Processing
Certain features of the Site or services may involve automated processing, including user authentication, content access controls, preference settings, analytics, and other website functionality. To the extent Lucror provides research tools, filters, alerts, or other functionality through the Site, such outputs are provided for informational purposes only and do not constitute automated decisions about individual persons.
15. Cookies
Cookies are small files stored on your device that allow websites to recognise returning users. We may use cookies and similar technologies for the following purposes:
- authentication
- login status
- security
- personalisation
- analytics
- storing user preferences
- cookie consent preferences
- improving the functionality and performance of the Site
Cookies may be either persistent or session cookies. Where required by applicable law, including for users in the European Economic Area, non-essential cookies such as analytics cookies will be used only after you have provided your consent through the cookie consent mechanism made available on the Site.
16. Cookies Used by Service Providers
We may use Google Analytics or similar analytics services to analyse the use of our website. These services gather information about website usage through cookies and similar technologies. You can find more information in the relevant provider privacy policies and settings pages.
17. Managing Cookies
Most browsers allow you to refuse or delete cookies. You can manage cookie preferences through your browser settings. Where a cookie consent mechanism is made available on the Site, you may manage your preferences for non-essential cookies through that mechanism. Blocking cookies may affect the functionality of the Site.
18. Amendments to This Privacy Policy
We may update this Privacy Policy from time to time. Where material changes are made, we may notify users through the Site or by email. Your continued use of the Site following the posting of changes constitutes acceptance of the revised Privacy Policy. Where you are a Registered User subject to a Subscription Agreement, any material changes to the processing of your personal data that conflict with that agreement will not apply unless agreed in writing.
19. Third-Party Websites
The Site may contain links to websites operated by affiliates or third parties. Those websites have their own privacy policies and terms, and Lucror is not responsible for their content, privacy practices, or security. You should review the privacy policies of those websites before submitting personal data to them.
20. Our Details
This Site is owned and operated by Lucror Analytics Pte. Ltd. Lucror is registered in Singapore under registration number 201005735Z. Registered office: Marina One East Tower, 7 Straits View #05-01, Singapore 018936
You may contact us:
- by post to the address above;
- through the website contact form;
- by telephone using the number listed on the Site; or
- by email at general@lucroranalytics.com
21. Data Protection Contact
For questions regarding this Privacy Policy or the handling of personal data, please contact:
Data Protection Officer
Lucror Analytics Pte. Ltd.
Email: general@lucroranalytics.com
22. Governing Law
This Privacy Policy is governed by the laws of Singapore. The courts of Singapore shall have exclusive jurisdiction over disputes arising in connection with this Privacy Policy. Notwithstanding the foregoing, Lucror may bring proceedings in any jurisdiction where necessary to protect its legal rights or enforce its agreements.