1. 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.

2. Categories of Personal Data We Collect

The personal data we collect depends on how you interact with the Site and our services.

2.1 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.

2.2 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

Account data is used for account administration, access control, service delivery, security, and communication.

2.3 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.

2.4 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.

2.5 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.

2.6 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.

2.7 Notification Data

We may process information that you provide for the purpose of receiving notifications, newsletters, or updates ("notification data").

2.8 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.

2.9 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.

3. 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.

4. 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.

5. 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.

6. 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.

7. 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.

8. Your Rights

Depending on your jurisdiction, you may have certain rights in respect of your personal data. These may include the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data in certain circumstances;
• object to or restrict certain processing of your personal data;
• request portability of your personal data in certain circumstances;
• withdraw consent where processing is based on consent;
• lodge a complaint with your applicable data protection authority.

To exercise these rights, please contact us using the details in section 20. We will respond to requests in accordance with applicable law. We may need to verify your identity before processing certain requests. We may decline requests that are legally permitted to be refused.

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.

1. Information About Us

The Sites are operated by Lucror Analytics Pte. Ltd. ("Lucror", "we", "us", or "our").

Lucror is incorporated in Singapore under registration number 201005735Z and has its registered office at:
Marina One East Tower
7 Straits View #05-01
Singapore 018936

2. Access to the Sites

Access to the publicly available portions of the Sites is provided free of charge. Certain areas of the Sites provide access to a subscription-based research service (the "Subscription Service") through which Lucror makes available research reports, analysis, publications, and related materials. Access to the Subscription Service is limited to:

1. users whose organisation has entered into a Subscription Agreement with Lucror ("Registered Users"), and
2. individuals authorised to participate in a free trial of the Subscription Service ("Free Trial Participants").

If you are not a Registered User or authorised Free Trial Participant, you are not entitled to access the Subscription Service. Lucror may modify, suspend, or discontinue any part of the Sites or Subscription Service at any time.

3. Eligibility and Authority

By accessing or using the Sites, you represent and warrant that:

• you are legally capable of entering into binding agreements;
• where you access the Sites on behalf of an organisation, you have the authority to bind that organisation to these Terms of Use;
• your use of the Sites will comply with all applicable laws and regulations.

Your organisation is responsible for the actions of its authorised users accessing the Sites.

4. Account Management and Security

If you are provided with login credentials as part of the Subscription Service, you must treat them as confidential and must not disclose them to any third party. You agree that:

• all information provided during account registration is accurate and complete;
• you will keep account information up to date;
• you will notify Lucror promptly if you become aware of any unauthorised use of your account;
• you will not transfer, sublicense, or otherwise permit unauthorised access to your account.

You remain responsible for all activity conducted through your account. Lucror reserves the right to disable access credentials if it reasonably believes these Terms of Use or the Subscription Agreement have been breached.

5. Confidentiality of Platform Information

Login credentials and any non-public information relating to the Sites or Subscription Service are confidential. You agree not to disclose such information to any third party except where necessary for authorised use within your organisation.

6. Permitted Uses

You may access and use the Sites and Content solely for lawful internal research and informational purposes. Except as expressly permitted in these Terms of Use or the applicable Subscription Agreement, you may not:

• reproduce or redistribute any Content;
• modify or create derivative works from the Content;
• distribute Content to third parties;
• commercially exploit the Sites or Content;
• use the Sites or Content in a manner that competes with Lucror or exploits the Content for the benefit of unauthorised third parties.

7. Intellectual Property Rights

"Lucror Analytics" and related logos are trademarks of Lucror. The Sites and all Content—including research reports, analysis, data, graphics, and platform design—are protected by copyright and other intellectual property laws. Unless otherwise stated, all intellectual property rights are owned by Lucror or its licensors. No part of the Sites or Content may be reproduced or distributed without Lucror's prior written consent.

8. Reliance on Information

The Content published on the Sites is provided for informational purposes only. It does not constitute investment, legal, tax, or accounting advice. Users should conduct independent analysis and obtain professional advice where appropriate. All Content is provided "as is", and Lucror does not guarantee its accuracy, completeness, or timeliness. Further regulatory and research disclaimers applicable to the Content are set out in the Disclaimer published on the Sites, which forms part of these Terms.

9. Availability and Suspension of the Sites

Lucror does not guarantee that the Sites will always be available. Access may be suspended or restricted for reasons including:

• scheduled or emergency maintenance
• system upgrades
• security incidents
• legal or regulatory requirements
• operational or technical reasons

Lucror will use reasonable efforts to restore service where practicable.

10. Security and Acceptable Use

You must not misuse the Sites. You must not:

• introduce malicious code or malware
• attempt to gain unauthorised access to systems
• interfere with platform operations
• conduct denial-of-service attacks
• use automated scraping tools, bots, spiders, or crawlers without Lucror's prior written consent

11. Third-Party Links

The Sites may contain links to third-party websites. Lucror does not control these websites and accepts no responsibility for their content.

12. Privacy

Personal data is processed in accordance with the Privacy Policy available on the Sites. By using the Sites, you consent to such processing and confirm that any information you provide is accurate.

13. Exclusion of Liability

To the fullest extent permitted by law, Lucror excludes liability for any loss arising from use of the Sites or Content, including:

• loss of profits
• trading losses
• loss of business
• loss of data
• loss of goodwill
• indirect or consequential losses.

Nothing in these Terms excludes liability that cannot lawfully be excluded.

14. Indemnification

You agree to indemnify and hold Lucror harmless from any claims, losses, liabilities, damages, and expenses arising out of:

• your breach of these Terms;
• your misuse of the Sites;
• your violation of applicable laws.

This indemnity does not apply to the extent such losses arise from Lucror's own negligence, fraud, or wilful misconduct.

15. No Partnership or Agency

Nothing in these Terms creates a partnership, joint venture, employment, fiduciary, or agency relationship between you and Lucror.

16. Jurisdiction and Applicable Law

These Terms are governed by the laws of Singapore. The courts of Singapore have exclusive jurisdiction over disputes arising from these Terms. Notwithstanding the foregoing, Lucror may seek injunctive or equitable relief in any jurisdiction to protect its intellectual property or confidential information.

17. Variations

Lucror may revise these Terms from time to time by updating this page. Your continued use of the Sites after such updates constitutes acceptance of the revised Terms. Where you are a Registered User subject to a Subscription Agreement, any revisions that conflict with that agreement will not apply unless agreed in writing.

18. Waiver

No waiver of any provision of these Terms shall be effective unless in writing and signed by the party granting the waiver. Failure to enforce any provision does not constitute a waiver.

19. Termination

You may stop using the Sites at any time. Lucror may suspend or terminate access if:

• you breach these Terms;
• required by law or regulation;
• necessary for security reasons;
• necessary to protect the integrity of the Sites.

Where practicable, Lucror may provide notice and an opportunity to remedy a breach. Provisions relating to intellectual property, liability, indemnification, confidentiality, and governing law survive termination.

20. Contact

For questions regarding the Sites, contact:
general@lucroranalytics.com