This privacy policy (the "Policy") explains how Lucent Holdings Limited, Lucent Trading Limited, Lucent Trading Private Limited, Omega Services Systems Inc. and/or additional Lucent Group entities to whose services/website you have registered (collectively "Lucent", "we" or "us" and the member of the Lucent group to whose services you registered, the "Lucent Entity") collects, uses and discloses personal information through its websites, mobile applications, and other online products and services that link to this Policy (collectively, the "Services") or when you otherwise interact with us.
We encourage you to read the Policy carefully as it forms part of the relevant Lucent Entity’s terms and conditions, terms of business and/or terms of use, as the case may be.
For the purposes of applicable international data protection laws, the respective Lucent Entity with whom you have registered is the "controller" of personal information collected through www.lucent.io (http://www.lucent.io), other Lucent Group’s websites, widgets, mobile applications and other platforms (together the "Site"), and is the company to contact if you have questions about the use of your personal information (see the "Contact Us" section below). This policy also applies to personal data about each authorized representative of a client and about other persons or entities collected in the course of providing our services (such as directors of corporate clients).
We collect information you provide directly to us. For example, we collect information when you create an Lucent account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, make a purchase, apply for a job, communicate with us via third party social media sites, request customer support, or otherwise communicate with us.
When You Sign Up or Register for an Lucent Account or ServicesIf you sign up for an Lucent account or Services, we will collect basic information about you including your name, email address and telephone number. You may provide this information to us directly, or by signing in to your account/service with a third party, including without limitation, Facebook or Google (see "Information We Collect from Other Sources" below). We will use the information that we collect about you to:
Create and maintain your account;
Allow you to log in to Lucent; and
Contact you about your account and/or the services that Lucent offers.
Once you have created an Lucent account, we will ask you to provide additional optional information about yourself to complete your "Profile". The information we ask for includes your gender, date of birth, place of birth, addresses, nationality, passport number (or other government-issued identification number), citizenship and residency status, tax identification number, and information about your experience trading, education, source of income, investment aims and appetite, occupation, employer and employment position, annual income, investment portfolio, total cash and liquid assets and other details or questions as may be required in the Profile creation and process and may be amended by us from time to time.
We will also ask you to provide a copy of an identification document, such as a passport, residency, visa or national identity card, a utility bill and such other documents as may be required by us in order to comply with our regulatory obligations and to verify your identity. Further details about the identification process can be found in the relevant Lucent’s terms and conditions, terms of business and/or terms of use, as the case may be. We will use the information you provide in your Profile to:
You can update your Profile at any time by visiting the "Account" page in the Settings menu. We recommend that you update your Profile regularly, to ensure that the Lucent Services offered to you are appropriate for your current circumstances. You further agree to update such information upon Lucent’s request, if Lucent considers the information provided as untrue, incorrect, incomplete and/or inconsistent with other information provided by you at any time. You acknowledge that we may rely upon such information and that you are responsible for any damages or losses which may result from any inaccuracies, including without limitation, the inappropriateness of our Services to your profile. You do not have to provide the information to complete your Profile, however if you choose not to, we may be unable to offer Lucent’s full functionalities to you.
When you Contact UsIf you contact us by telephone, email, post or use another function offered by Lucent, such as the chat feature. We will collect any information about the communication and any additional information that you choose to give us. We will use this information to review, investigate and respond to any comment or question that you may raise. Please note that we record and retain all telephone calls and other communication with us and may use it in our dealings with you including any dispute resolution or legal proceedings.
When an Lucent User Invites You to Use LucentUsers of Lucent can invite their contacts to sign up for an account with us. We only collect the email addresses of individuals that users choose to invite to join Lucent, Lucent only uses the email addresses for sending an invitation to the individual at the request of the existing Lucent user.
We collect information about your use of the Services, such as financial information and geo-location.
Automatically Collected InformationWhen you access or use our Services, we automatically collect information about you, including:
Log Information: We collect log information about your use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, any other network identifiers, and the page you visited before navigating to our Services.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Activities on the Site: We collect records of activities on the Site, including, any content you post, your account details, the time, value and currency of any deposit, withdrawal, or transaction made and the payment method
Location Information: In accordance with your device permissions, we may collect information about the precise location of your device.
Information Collected by Cookies and Other Tracking Technologies: We use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. You can find out more about Lucent’s use of Cookies in our Cookies Policy.
Information We Collect from Other SourcesWe may obtain information from other sources and combine that with information we collect through our Services. We may also collect personal information about you from third party entities when we seek to verify your identity as part of our regulatory requirements. This may include, for example, identity verification agencies, credit referencing agencies and similar bodies. For example, we may collect information about you from third parties, when you use or connect to Lucent by or through a third-party platform, such as Facebook or another site, you allow us to access and/or collect certain information from your Third Party Platform profile/account as permitted by the terms of the agreement and your privacy settings with the third party platform. We will share such information with the third party platform for their use.
We will share some of the information we collect from you on installation of the mobile app with vendors and other service providers who are engaged by, or working with us in connection with the operation of the services we provide to you. This information may also be shared with these parties for analytics purposes, which may require the reproduction and display of your information in an aggregated and anonymized manner that will not in any way identify you.
We use the information we collect to provide, maintain, and improve our services, such as to administer and verify your account, to provide the services you request and customize your experience with us. We also use the information we collect to:
We will not share the personal information we hold about you except in the following circumstances:
If you have elected to use one of our applications provided via social networks (such as Facebook, Twitter, etc.), our application will access your social network account general information which includes your name and username in the social network, profile picture, gender, networks, user ID, list of friends, and any other information you have shared depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Lucent and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or www.youronlinechoices.eu/
We process and store your personal information using data centers located in Singapore and Philippines (where the laws have been recognized as providing the same level of data protection as the European Union or the United States of America). We and our service providers also may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. If you would like further information about the safeguards in place for transfers of personal information to our group companies or other third parties, under the applicable data protection laws that apply to us, please contact us (see "Contact Us" below).
You may update, correct, or delete your information at any time by logging into your account or emailing us at [email protected]. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
CookiesMost web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Promotional CommunicationsYou may opt out of receiving promotional emails or text messages from Lucent by following the instructions in those emails or text messages or by visiting the "Notifications" tab in the "Settings" menu on our platform. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Mobile Push Notifications/AlertsWith your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
We use the personal information you provide to us, or that we gather when you use our services, to tailor Lucent to your Profile and to assign you a risk score. Lucent will carry out this analysis automatically, and in most cases without human intervention. You can update the information in your Profile at any time by visiting the "Account" page in the Settings menu. We recommend that you update your Profile regularly, to ensure that the Lucent Services offered to you are appropriate for your circumstances. If you have any questions about the automated analysis of your personal information, please contact us (see "Contact Us" below).
When we process your personal data we will only do so in the following situations.
Entering into and Performing the Contract with You: If you have an Lucent account or have registered on the Site or for the Services, our legal basis for processing your personal information is that it is necessary for the performance of the relevant Lucent Entity’s terms and conditions, terms of business and/or terms of use, and to provide a service to you. With respect to an Lucent account, this includes facilitating access to our platform, processing payments and executing trades.
For other Justifiable Grounds, including Legal Obligation and Legitimate Interests: We process your personal information where necessary for Lucent to comply with legal and regulatory obligations we are under, and also where it is necessary for legitimate interests we have in conducting our business. These include without limitation:
Learning about your interests and preferences to contact you with information that is relevant to you and helping us target marketing communication and advertisements so that they are more relevant to you. Using your pseudonymised details to show you advertising on social media platforms, such as Facebook or via other third-party advertising that may appear on other websites you use. The information shared with these platforms is pseudonymised to protect your personal data.
Analyzing and continually improving the Site and our services and helping us pilot test versions of the Site internally to develop new features and ensure the efficient running of Lucent’s services.
Detecting and reducing fraud and credit risk.
You have certain rights and protections under the law regarding the processing of your personal data. We recognize you the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing and in some circumstances to obtain a copy of the personal information in machine readable format. If you would like to exercise any of these rights, you can log into your account or contact us. Any such request should be submitted in writing to [email protected].
Individuals also have the right to complain about the use of their personal information to the supervisory authority for Lucent which is Asia Blockchain And Cryptocurrency Association ("ABACA") which you may contact at *.
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.
Lucent is a real-time social trading platform, which integrates rich community and social characteristics into the trading platform. As part of the Lucent traders’ network, traders who choose to be part of the community share their strategies and performance with the community. The amount traded is never disclosed and all traders are required to agree to be part of the network and share their strategies and performance.
Downloading, installing and accessing the Lucent Services constitutes your agreement and acknowledgment that the following information and content shall be considered non-confidential and nonproprietary information (other than your personal data as described below), collectively, the "Content" and shall be publicly shown on the Site: your username and full name, your picture/avatar (if provided), your state of residency, gender, networks, list of users who follow you, users who copy you etc., list of users you follow or copy, and any network status/posts/blogs and any other content options that enable our users to interact amongst themselves, including without limitation content and information you post on the Lucent community, comments, feedback, postings, "likes", blogs and/or all information that You provide to us via our website, our mobile apps, and/or by email, chat, fax or telephone and/or any other means.
You can change your privacy settings at any time, and can make your trading activity private by visiting the "Privacy" page in the Settings menu.
We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you are invited to use Lucent by another user, we will store your personal information for a period of six months in order to send an invitation to you by email.<br><br>If you have an account with Lucent, we will store your personal information for as long as you maintain that account, and after you cease holding an account, for as long as we are required to by laws and regulations that are applicable to us.
We protect your personal information by using data security technology and using tools such as firewalls and data encryption. We also require that you use a personal username and password every time you access your account online. As set out in the relevant Lucent Entity’s terms and conditions, terms of business and/or terms of use, you must not share your password with anyone else. We restrict access to personal information at our offices so that only officers and/or employees with a legitimate business purpose can access it.
Lucent is not available for users under the age of 18 (or the age of legal consent for the jurisdiction the user is located in) (a "Minor"). We do not knowingly collect personal information from or about Minors. If you are a Minor, you should not download or use any of our services nor provide any personal information to us.
If we become aware that a Minor has shared any information with us, we will delete such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].
The Policy will be reviewed from time to time to take account of changes to our operations or practices and, further, to make sure it remains appropriate to any changes in law, technology and the business environment. Any personal information held will be governed by our most current Policy.
The Site may include links to other websites on the internet. We are not responsible for the content of these sites or for any other privacy practices on these internet sites. You should read the terms of use and the privacy statements of any such websites. Our terms of use and our Privacy Policy apply only to information collected by us in accordance with this Policy.
Should you have any questions regarding the Policy, please contact us at [email protected]. Please include your name, and mailing or email address.