This privacy policy applies to users of the CS Lucas website and authorised users of the CS Lucas Mobile application. It explains how CS Lucas collects, uses, stores, shares and protects personal data in connection with the website, mobile application and related services.

CS Lucas Mobile is provided to authorised users of organisations that use CS Lucas products and services. Where CS Lucas processes information on behalf of a customer organisation, that organisation ordinarily determines the purposes of the processing and acts as the data controller, while CS Lucas acts as its processor or service provider. CS Lucas may act as a data controller for information processed for its own account administration, security, support, legal-compliance and service-management purposes.

This policy should be read together with any privacy information provided by the user’s organisation and the applicable customer agreement. It does not apply to independent third-party websites or services that may be linked from the website or application.

Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Data	collectively all information submitted, collected, accessed, generated or otherwise processed by CS Lucas in connection with the Website, Application or Services. This includes personal data where applicable under the Data Protection Laws;
Cookies	a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below ( Cookies);
Data Protection Laws	any applicable law relating to the processing of personal Data;
GDPR	the General Data Protection Regulation (EU) 2016/679;
CS Lucas we or us	CS Lucas Associates Pte Ltd (incorporated in Singapore), CS Lucas Limited (incorporated in the United Kingdom), CSLucas Service Corporation (incorporated in the Philippines)
UK and EU Cookie Law	the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
User or you	means a person who accesses or uses the Website, Application or Services;
Website	means www.cslucas.com and its subdomains, unless expressly excluded;
Application or App	means the CS Lucas Mobile application;
Services	means the Website, the Application and the associated CS Lucas services covered by this policy.

 

In this privacy policy, unless the context requires a different interpretation:

a.  the singular includes the plural and vice versa;

b.    references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c.   a reference to a person includes firms, companies, government entities, trusts and partnerships;

d.    “including” is understood to mean “including without limitation”;

e.   reference to any statutory provision includes any modification or amendment of it;

f.   the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies to CS Lucas and Users in connection with the Website, Application and Services. It does not extend to independent third-party websites or services linked from the Website or Application.

CS Lucas’s role under applicable Data Protection Laws depends on the processing activity. Where CS Lucas processes information on behalf of a customer organisation, the customer ordinarily acts as controller and CS Lucas acts as processor or service provider. CS Lucas acts as controller for information processed for its own account administration, security, support, legal-compliance and service-management purposes.

Data collected

We may collect the following Data, which includes personal Data, from you:

a.   name;

b.   job title;

c.   profession;

d.   contact information such as email addresses and telephone numbers;

e.   demographic information such as postcode, preferences and interests;

f.    financial information such as credit / debit card numbers;

g.   IP address (automatically collected);

h.   web browser type and version (automatically collected);

i.    operating system (automatically collected);

j.    a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

in each case, in accordance with this privacy policy.

Mobile Application Data

When an authorised user registers or uses the Application, CS Lucas may process:

a.   account identifiers, including user ID, name and profile information;

b. device-registration information, including a device-generated identifier, device name, operating-system type and registration status;

c. authentication and security information, including authentication tokens, login events and related security and audit records;

d. treasury, transaction, trade and workflow information that the user is authorised to access;

e. comments, approvals, verifications and other actions submitted through the Application;

f. Insight questions, conversation names, generated responses and visualisations; and

g. technical information required to operate, secure, diagnose and support the Application, such as IP address, timestamps, error information and service activity.

Passwords and one-time passwords are transmitted for authentication and are not intended to be retained by the Application after authentication. Where biometric login is enabled, biometric templates remain under the control of the device operating system. CS Lucas does not receive or store the user’s facial or fingerprint biometric template.

The Application may retain limited account, device-registration, session, trade and Insight information locally on the device to provide security, session continuity and cached application functionality. Users should protect access to their devices and remove the Application or clear its registration when the device is no longer authorised.

The Application does not collect payment-card details and does not use third-party advertising cookies or perform cross-app tracking.

Insight and AI Processing

The Insight feature processes questions submitted by authorised users, relevant treasury information that the user is permitted to access, and generated responses and visualisations.

CS Lucas uses contracted cloud and artificial-intelligence service providers, including Amazon Web Services and Amazon Bedrock, to support this functionality. These providers process information only to deliver the service and are subject to appropriate confidentiality, security and data-protection obligations. Insight inputs and outputs are not used to train public or shared artificial-intelligence models.

Insight conversations are stored to provide conversation history and related functionality. They are retained for the period agreed between CS Lucas and the applicable customer organisation, subject to legal, regulatory, security, audit and backup requirements.

Limited technical and audit information may be recorded to operate, secure, monitor and support the service. CS Lucas does not sell this information or use it for third-party advertising or cross-app tracking.

How we collect Data

We collect Data in the following ways:

a.   data is given to us by you, when you register a device, authenticate, submit an Insight question, add a comment, approve or verify a transaction, or otherwise interact with the Application;

b.   data is received from other sources; and

c.   data is collected automatically.

Data that is given to us by you

CS Lucas will collect your Data in a number of ways, for example:

a.   when you contact us through the Website, by telephone, post, e-mail or through any other means;

b.   when you register with us and set up an account to receive our products/services;

c.   when you complete surveys that we use for research purposes (although you are not obliged to respond to them);

d.   when you enter a competition or promotion through a social media channel;

e.   when you make payments to us, through this Website or otherwise;

f.    when you elect to receive marketing communications from us;

g.   when you use our services;

h.   in each case, in accordance with this privacy policy.

Data that is collected automatically

When you access the Website, Application or Services, certain Data may be collected automatically, as described below.

a.   we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b.   we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

c. when the Application is used, we may automatically receive device-registration information, IP address, operating-system type, access times, authentication events, service activity and limited diagnostic or audit information required to operate and secure the Services.

d. the Application does not use website cookies. Website cookies described in this policy apply to use of the Website through a web browser.

Our use of Data

Any or all of the above Data may be processed where necessary to provide, operate, secure and support the Website, Application and Services. Specifically, Data may be used by us for the following reasons:

a.   improvement of our products / services;

b.   transmission by email of marketing materials that may be of interest to you;

c.   contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;

d. authenticating users and registering, approving and managing authorised devices;

e. displaying treasury, transaction and workflow information that the user is authorised to access;

f. recording and processing comments, approvals, verifications and other authorised actions;

g. providing Insight conversations, generated responses and visualisations;

h. maintaining security, fraud-prevention, operational, support and audit records; and

i. complying with contractual, legal and regulatory obligations.

in each case, in accordance with this privacy policy.

We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

a.   soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.

b.   for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.

c.   if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

The following direct-marketing, advertising and cookie provisions relate to the Website and CS Lucas’s general business communications. They do not mean that the Application contains third-party advertisements or performs cross-app tracking. We may use your Data to show you CS Lucas adverts and other content on other websites. If you do not want us to use your data to show you CS Lucas adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed “Cookies” below).

Who we share Data with

We may share your Data with the following groups of people for the following reasons:

a.   any of our group companies or affiliates – to support the proper administration and operation of the Website, Application, Services and CS Lucas’s business;

b.   our employees, agents and/or professional advisors – to obtain advice from professional advisers;

c.   third party service providers who provide services to us which require the processing of personal data – to help third party service providers in receipt of any shared data to perform functions on our behalf to help operate, secure, maintain and support the Website, Application and Services;

d. third parties that process personal data on behalf of CS Lucas are contractually required to provide the same or an equivalent level of protection as described in this policy and required by applicable law;

e.   relevant authorities – to facilitate the detection of crime or the collection of taxes or duties;

in each case, in accordance with this privacy policy.

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

a.   access to your account is controlled by a password and a username that is unique to you.

b.   we store your Data on secure servers.

c.   payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology).

Certain entities of CS Lucas are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: webmaster@cslucas.com.

Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your rights

You have the following rights in relation to your Data:

a.   Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b.   Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

c.   Right to erase – the right to request that we delete or remove your Data from our systems.

d.   Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

e.   Right to data portability – the right to request that we move, copy or transfer your Data.

f.    Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: webmaster@cslucas.com

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers outside the European Economic Area

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA.  We also share information with our group companies, some of which are located outside the EEA.

We will transfer personal data internationally only where permitted by applicable Data Protection Laws. Depending on the countries and organisations involved, safeguards may include an applicable adequacy decision, the European Commission’s standard contractual clauses, the UK International Data Transfer Agreement or UK Addendum, binding corporate rules, or another legally recognised transfer mechanism. Where required, CS Lucas will also carry out an appropriate assessment of the protections applicable to the transfer.

To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to other websites

The Website or Application may provide links to independent third-party websites or services. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to a user’s independent use of those third-party websites or services. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

CS Lucas 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 CS Lucas. 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 supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it.

In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer.    CS Lucas uses Cookies to improve your experience of using the Website and to improve our range of products and services.   CS Lucas has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling CS Lucas to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

Type of Cookie	Purpose
Analytical/performance cookies	They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies	These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies	These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find a list of Cookies that we use in the Cookies Schedule.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

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

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

CS Lucas may update this privacy policy where necessary to reflect changes to the Website, Application, Services, business practices or applicable law. The updated policy will be published on this page with a revised “Last updated” date. Where required by applicable law or where a change is material, CS Lucas will provide additional notice or obtain consent.

 You may contact CS Lucas by email at webmaster@cslucas.com.

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Analytical/performance

We use the following analytical/performance cookies:

Description of Cookie	Purpose
Advertising Cookies Tracking Cookies Google Analytics	We use this cookie to help us analyse how users use the website.

Last updated: 9 September 2026