Privacy and Cookie Policy

(Updated – December 2023)

Background:

Lucep Pte Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site or when requesting a call-back and You will be required to accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.


  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings:

    “Account” means an account required to access and/or use certain areas and features of Our Site;
    “Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
    “Our Site” means both lucep.com and virtuaq.com;
    “We/Us/Our” means Lucep Pte Ltd, a limited company registered in Singapore [registration number: 201401386E], whose registered address is 2 Venture Drive, #14-02 Vision Exchange, Singapore 608526

  2. Information About Us

    Our Site, lucep.com, is owned and operated by Lucep Pte Ltd, a limited company registered in Singapore [registration number: 201401386E], whose registered address is 2 Venture Drive, #14-02 Vision Exchange, Singapore 608526

  3. Scope – What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site. We have no control over how your data is collected, stored, or used by other websites and advise you to check the privacy policies of any such websites before providing any data to them.


  4. What Data Do We Collect?

    Some data will be collected automatically by Our Site (for further details, please see section 12 on Our use of Cookies), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account or requesting a call-back. Depending upon your use of Our Site, We may collect some or all of the following data:

    1. Name

    2. Phone number

    3. Email address

    4. Financial information such as credit/debit card numbers

    5. IP address

    6. Clicks

    7. Scrolls

    8. Referral URL

    9. UTM tags

    10. URL browsing history on our site

    11. Web browser type and version

    12. Operating system information

  5. How Do We Use Your Data?

    1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

    2. We use your data to provide the best possible products and services to you. This includes:

      1. Providing and managing your Account;

      2. Responding to a request for a call back;

      3. Providing and managing your access to Our Site;

      4. Personalising and tailoring your experience on Our Site;

      5. Supplying Our products and services to you;

      6. Personalising and tailoring Our products and services for you;

      7. Responding to communications from you;

      8. Supplying you with email newsletters, alerts, welcome emails, reminders, notifications etc. (you may unsubscribe or opt-out at any time by adjusting your preferences on the email or by writing to support@lucep.com)

      9. Providing you with email updates on our policies, terms and conditions, legal notices etc (you may unsubscribe or opt-out at any time by adjusting your preferences on the email or by writing to support@lucep.com)

      10. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;

    3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.

    4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and other relevant legislation

    5. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:

      1. you have given consent to the processing of your personal data for one or more specific purposes;

      2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

      3. processing is necessary for compliance with a legal obligation to which we are subject;

      4. processing is necessary to protect the vital interests of you or of another natural person;

      5. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

      6. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

  6. How and Where Do We Store Your Data?

    1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.

    2. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.

    3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected through Our Site.

    4. Steps We take to secure and protect your data include:

      • Obtaining SSL certification for our websites

      • Employing industry standard encryption algorithms and technologies employed for transferring, storing, and receiving individuals sensitive personal information

    5. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

  7. Data Sharing and Transfer:

    1. Approved Contractors and Analytics Providers: We share aggregated, non-personally identifiable information with approved contractors and analytics providers, specifically for updating our designs. This includes Google Analytics and SentinelOne for capturing application log data. Personal data is never included in these logs.

    2. Use of Aggregated Data: We do not transfer user data but send aggregated statistical information to enhance our website and application design. This includes data like page visits, clicks, screen sizes, etc.

    3. Confidentiality of Personal Data: All personally identifiable information is kept strictly confidential and is not shared with any third parties.

    4. Non-Disclosure Agreements: All our contractors are bound by strict non-disclosure agreements for data confidentiality and security.

    5. User Consent and Data Removal: Users can opt out of data collection via our privacy center and request data removal via our support page.

    6. Data Security: Data encryption in transit and at rest is ensured, and personal information is never transmitted to third parties.

    7. User Experience: Opting out of data sharing has no impact on the user experience.

    8. Policy Updates: Users will be notified of any policy changes on our website.

    9. Google User Data: We confirm that no Google user data obtained via our Google Plugins is shared with third parties.

    10. Anonymization of Data: Data is anonymized and aggregated to prevent individual identification.

  8. Do We Share Your Data?

    1. With Third Parties for Service Provision: We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods and search engine facilities. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

    2. Approved Contractors and Analytics Providers: Specifically, we share aggregated, non-personally identifiable information with approved contractors and analytics providers for the purpose of optimizing our website and application design. This includes, but is not limited to, Google Analytics and SentinelOne. These providers help us capture and analyze application log data, but no personally identifiable information is included in these logs.

    3. Non-Disclosure Agreements: All our contractors and third-party service providers are bound by strict non-disclosure agreements to ensure the confidentiality and security of any data they access.

    4. Aggregated Statistical Information: The only data that is in scope for sharing with third parties is non-personal, such as mouse clicks, page visits, and aggregated user behavior on our website. This data is never "sold"; rather, it is used solely for the purpose of optimizing our website and application design.

    5. Data Security and Confidentiality: We ensure that all data shared is subject to robust security measures. Personal data, especially any that could be used to identify an individual user, is never shared with third parties.

    6. Legal Requirements: In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority.

    7. Changes to Business Ownership: In the event of a change in ownership of our business or a merger with another business, data provided by users may be transferred along with the business. You will be notified in advance of any such transfer.

    8. Google User Data: We do not share Google user data obtained via our Google Plugins with any third parties. This data is considered confidential and is solely accessible to the account owner.

  9. Single Sign On (SSO) authentication services

    Lucep’s integration with, and access to, your third-party services may be accomplished through an authentication service such as Google Accounts Single Sign On (SSO).

    Restricted scopes that Lucep Automated Lead Qualification Drive Connector will request, for and upon successful authentication through Google Accounts SSO

    • OAuth to access Google Drive resources;

    • Retrieval of user’s list of folders and spreadsheets to allow user to browse their Google Drive and choose the spreadsheet to bind;

    • Each row in the spreadsheets will be treated as lead data;

    • Read permissions are required for spreadsheets, in order to read the rows, and know when the data is ready, and collect the data to be exported as a lead;

    • Write permissions to mark a row as processed after lead data is exported;

    • Register notifications to know if and when the configured spreadsheets have new rows of data which must be processed as newly created leads;

    • Write permissions to push lead outcome back into configured spreadsheets; and

    • Permission to read the user profile to know if the access token requires update.

    This information collected by Lucep will be consistent with your privacy settings in your account with the relevant Authentication Service

    This link provides exhaustive information on Google’s privacy policy. The relevant section on “When Google shares your information” states that “We’ll share personal information outside of Google when we have your consent.”

    This link explains how you can manage Lucep’s access to your Google account. You can:

    1. Review what a third-party can access;

    2. Remove third-party account access;

    3. Report an app or service; and

    4. Learn about data sharing with third-parties.

  10. What Happens If Our Business Changes Hands?

    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

    2. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.

  11. How Can You Control Your Data?

    When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data, including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by contacting us at support@lucep.com

  12. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

    1. You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

    2. You may restrict your internet browser’s use of Cookies. For more information, see section 12

    3. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

  13. How Can You Access Your Data?

    You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at support@lucep.com, or using the contact details below in section 15.

  14. What Cookies Do We Use and What For?

    1. Our Site may place and access certain first party Cookies or equivalent technology on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies or equivalent technology and have taken steps to ensure that your privacy is protected and respected at all times.

    2. By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies or equivalent technology on Our Site for analytics purposes. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

    3. When Cookies are placed on your computer or device subject to section 12.5 AND/OR section 12.8, you will be shown a pop up requesting your

    4. to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

    5. Certain features of Our Site depend on Cookies to function. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.11, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

    6. The following first party Cookies or equivalent technology may be placed on your computer or device:

      Name of Cookie Purpose
      X-Mapping-dcbblbfg Traffic load balancing
      mailmunch_second_pageview Used to manage subscription service to mailing lists of blogs (mailmunch)
      Local Storage items: Understand user behaviour in order to optimize website performance
      lucep-sg-profile
      lucep-menu
      gorilla-geo
      desktop-popup-perms

      and the following third party Cookies may be placed on your computer or device:

      Name of Cookie Provider Purpose
      1P_JAR Google To gather website statistics
      HSID
      SIDSSID
      APISID
      SAPISID
      SIDCC      		 Google Google uses these security cookies to authenticate users, protect user data from unauthorized access prevent fraudulent use of login credentials, and protect user data from unauthorized parties
      NID Google Google uses these cookies to allow Google to remember information that changes the way the site behaves or looks, such as your preferred language or the region you are in.
      LOGIN_INFO
      VISITOR_INFO1_LIVE
      PREF
      YSC      		 Google ( YouTube.com) We have embedded videos from our Youtube channel. This action may set cookies on your device when you click on the video player.
      YouTube will not store personally identifiable cookie information for playbacks of embedded videos using the privacy-enhanced mode. More information is available in the support pages of youtube.com
      _adpxluid
      ckiimage
      favicon.ico
      VBSVjJVO
      Fr9lxpOi      		 Adpxl.co To provide the the visitor with a better experience


    7. Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

    8. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.

    9. The analytics service(s) used by Our Site use(s) the following Cookies:

      Name of Cookie First / Third Party Provider Purpose
      _ga
      _gat
      _gid      		 First party Universal Analytics (Google) These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.

    10. In addition to the information found in 12.5 and 12.8, Our Site also uses a Facebook pixel to measure the effectiveness of our advertising by understanding the actions people take on your website

    11. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

    12. You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

    13. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

  15. Summary of Your Rights under GDPR

    For individuals residing in the EU, under the GDPR, you have:

    1. the right to request access to, deletion of or correction of, your personal data held by Us;

    2. the right to complain to a supervisory authority;

    3. be informed of what data processing is taking place;

    4. the right to restrict processing;

    5. the right to data portability;

    6. object to processing of your personal data;

    7. rights with respect to automated decision-making and profiling (see section 14 below).

    To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

  16. Automated Decision-Making and Profiling

    1. In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

    2. The right described in section 14.1 does not apply in the following circumstances:

      1. The decision is necessary for the entry into, or performance of, a contract between the You and Us;

      2. The decision is authorised by law; or

      3. You have given you explicit consent.

    Where We use your personal data for profiling purposes, the following shall apply:

    1. Clear information explaining the profiling will be provided, including its significance and the likely consequences;

    2. Appropriate mathematical or statistical procedures will be used;

    3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

    4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

  17. Contacting Us

    If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@lucep.com. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

  18. Changes to Our Privacy Policy

    We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site, and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.