This Privacy Policy governs the website https://sqn.lucroranalytics.com (the “Site”) owned and 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 access the Site (collectively, “You”).
This Privacy Policy describes the manner in which We collect, store, process, use, transmit, transfer and disclose information that You disclose to Us or that We collect through Your access to or use of the Site and the services provided through the Site (the “Services”) (collectively, “Your Information”).
By accessing or using the Site and/or the Services, You acknowledge that You have read and understood this Privacy Policy and consent to the processing of Your Information 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 or Services.
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.
We may use Your Information for the following purposes:
Certain communications relating to account management, system maintenance or security are considered part of the Services and You may not be able to opt out of receiving them.
The information We collect depends on how You interact with the Site and Services.
Information contained in enquiries submitted by You regarding Our Services.
Information about how You use the Site including:
Information about devices used to access the Site including:
Information provided when registering for the Services including:
This information may also be obtained from Your employer or from publicly available professional profiles.
Information relating to communications between Us and You or Your employer.
Information submitted through the use of the Services (“service data”). This may include data uploaded or entered by users in connection with their use of the SQN Platform, including portfolio holdings, securities identifiers, investment positions, analytics inputs and related financial data.
Service data is processed solely for the purpose of providing and operating the Services requested by You or Your employer, including generating analytics, scores, reports and other outputs within the SQN Platform.
Lucror does not use portfolio or other client-uploaded financial data for the benefit of other users, and such data is not shared with or made accessible to other clients of the Services.
Access to such data is restricted to authorised personnel and systems strictly for the purpose of operating, supporting and maintaining the Services.
Information used for sending service notifications.
Information contained in communications sent to Us including emails or messages submitted through the Site.
Please do not provide personal data belonging to another person without their consent.
We may disclose Your Information to:
Such disclosures will be limited to what is reasonably necessary for the purposes described in this Privacy Policy.
Lucror recognises that certain information submitted to the Services, including portfolio holdings, securities positions, investment strategies and other financial data provided by users (“Client Data”), may constitute confidential commercial information of the relevant client.
Client Data is processed solely for the purpose of providing the Services to the relevant user or customer organisation and generating analytics, reports or other outputs within the SQN Platform.
Lucror does not use Client Data to create aggregated datasets or products for other clients, and Client Data is not made available to other users of the Services.
Access to Client Data is restricted to authorised personnel and systems on a strict need-to-know basis and protected through technical and organisational safeguards designed to prevent unauthorised access or disclosure.
Your Information 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 the 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 comparable to that provided under the Personal Data Protection Act 2012 (PDPA).
By using the Site and Services, You acknowledge that Your Information may be transferred internationally in accordance with this Privacy Policy.
Your Information will not be retained for longer than necessary for the purposes for which it was collected.
Information relating to the provision of the Services is generally retained in accordance with Lucror’s internal records management and regulatory compliance policies.
In most cases, records relating to user accounts, contractual relationships and service usage will be retained for a minimum period of five (5) years following termination of the relevant customer relationship, unless a longer retention period is required by law or regulatory obligations.
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.
Subject to applicable law, You may have the right to:
Requests may be submitted using the contact information provided below.
Cookies are small files stored on Your device that allow websites to recognise returning users.
We may use cookies for:
We may use Google Analytics or similar analytics services to analyse the use of the Site.
You may disable cookies through Your browser settings, although some features of the Site may not function properly if cookies are disabled.
In order to maintain the security and integrity of the Services, Lucror may collect and analyse system logs and related operational data (“Log Data”).
Log Data may include information such as IP addresses, login activity, system events, access timestamps, device identifiers, and actions performed within the platform.
This information is used solely for purposes including:
Log Data is processed and stored in accordance with Lucror’s internal security and data protection policies.
We may engage third-party service providers to support the operation and delivery of the Site and Services, including cloud hosting providers, analytics providers and technology vendors.
These service providers may process personal data on Our behalf solely for the purpose of performing services for 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.
Service providers are not permitted to use personal data for their own marketing or independent purposes.
Lucror maintains administrative, technical and organisational safeguards designed to protect personal data against unauthorised access, disclosure, alteration or destruction.
In the event that 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 relevant authorities of a personal data breach.
While We take reasonable measures to protect Your Information, no security system is completely secure.
Accordingly, We cannot guarantee that information transmitted through the internet or stored on Our systems will be absolutely secure.
Users are encouraged to protect their account credentials and log out of accounts when using shared devices.
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 with service providers, affiliates or other third parties only where necessary to operate the Site and Services, comply with legal obligations or enforce agreements.
Certain features of the Services may involve automated processing of data, including the generation of analytics, scores, models, rankings or other analytical outputs.
Such outputs are generated through automated calculations and analytical models based on data provided by users or obtained from third-party sources.
SQN outputs are analytical tools provided to institutional clients to support their own investment analysis and decision-making and do not constitute automated decisions about individual persons.
This Site is owned and operated by Lucror Analytics Pte. Ltd.
Registration number: 201005735Z
Registered office:
Marina One East Tower
7 Straits View, #05-01
Singapore 018936
You may contact us:
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
This Privacy Policy is governed by the laws of Singapore.
Any disputes relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore.