Privacy
1. Controller and data protection officer
Controller within the meaning of Art. 4(7) GDPR, and the organization responsible under the Singapore Personal Data Protection Act 2012 (PDPA), is:
Lucet Holding PTE. LTD.
32 Pekin Street, #5-01
048762 Singapore, Singapore
Email: info@lucet.ai
Website: www.lucet.ai
Under Section 11(3) PDPA, every Singapore organization must designate at least one data protection officer. The business contact information of the data protection officer must be made publicly available; the officer's name need not be published. You can reach our data protection officer at: dpo@lucet.ai
2. EU representative (Art. 27 GDPR)
As the controller is established outside the EU but offers services to individuals in the EU (Art. 3(2) GDPR), it has appointed the following representative in the European Union under Art. 27 GDPR, who serves as an additional point of contact for data subjects and supervisory authorities alongside the controller:
Lucet GmbH, represented by its managing director Cem Kilinc
Unter den Linden 16
10117 Berlin, Germany
Email: cem.kilinc@lucet.ai
3. General information on data processing
We process personal data only where this is necessary to provide this website, respond to enquiries, maintain security and communicate with interested parties. The legal bases are Art. 6(1)(b) GDPR where processing is necessary for pre-contractual communication, Art. 6(1)(f) GDPR for our legitimate interests in operating a secure and functional website, and Art. 6(1)(a) GDPR where consent is requested.
4. Access data and hosting
When you visit this website, technical access data may be processed automatically. This can include IP address, date and time of access, requested file, referrer URL, browser type, operating system and access status. Processing is necessary to deliver the website, ensure technical stability and detect misuse. Legal basis is Art. 6(1)(f) GDPR.
Hosting provider: Google Cloud (Google Cloud EMEA Limited, Ireland). Data is processed on servers in the EU region europe-west3 (Frankfurt, Germany). Processing by Google Cloud is governed by a data processing agreement pursuant to Art. 28 GDPR (Google's Cloud Data Processing Addendum), which incorporates the EU Standard Contractual Clauses where required.
5. Contact form and email contact
If you use the contact form, the website creates a pre-filled email to info@lucet.ai. The data entered in the form, such as name, email address and message, is processed for the purpose of responding to your enquiry. Legal basis is Art. 6(1)(b) GDPR for pre-contractual enquiries or Art. 6(1)(f) GDPR for general business communication.
Since the current implementation uses a mailto link, the message is sent through your own email client. Your email provider may process the data independently. We store enquiry data only as long as necessary to handle the request and comply with legal retention duties.
6. Cookies and device access
This website does not set tracking or marketing cookies and does not use analytics tools (no Google Analytics, no pixels). As long as only strictly necessary storage is used, no cookie consent banner is required.
The website stores two technically necessary values in your browser. The first is a session storage entry (key "lucet_intro_seen") so that the opening animation is not replayed during the same session; it is removed when the browser tab is closed. The second is a local storage entry (key "lucet_motion"), written only if you use the control that pauses or resumes animations, so that your choice is remembered on your next visit; it stays until you clear your browser storage. Neither entry contains personal data and neither is used for tracking. Legal basis: Section 25(2) TDDDG (storage strictly necessary to provide a function you requested) and Art. 6(1)(f) GDPR.
Please note that the operator of this website is established outside the EU, in Singapore. Any information stored on or read from your device is limited to the strictly necessary entry described above; should non-essential cookies, analytics or third-party embeds ever be added, we will introduce a consent mechanism that meets the requirements of Section 25(1) TDDDG and the GDPR beforehand.
This website does not track visitors over time or across third-party websites, so it does not respond differently to Do Not Track (DNT) signals sent by browsers.
7. Fonts and media
The website uses the "LUCET Sans" web font (based on the open-source typeface Aspekta), which is hosted locally on this website (self-hosted under the SIL Open Font License 1.1). No font data is requested from Google or any other third party, so no IP address is transmitted to external font servers and no consent is required for font delivery.
The background video and all other media assets are likewise served locally from this website and do not involve third-party requests.
8. Recipients of personal data
Personal data may be processed by technical service providers, hosting providers, email providers and other processors used to operate the website and respond to enquiries. Where required, these providers are bound by data processing agreements.
9. International transfers
The controller is established in Singapore, a third country outside the European Economic Area that is not covered by an EU adequacy decision. Where you provide personal data directly to us (for example by sending an enquiry), that data is collected directly by the Singapore controller. Under the EDPB Guidelines 05/2021, such direct collection is not a "transfer" within the meaning of Chapter V GDPR, because there is no exporting entity in the EU; the GDPR nonetheless applies in full to this processing by virtue of Art. 3(2) GDPR, including the safeguards, legal bases and rights described in this policy.
Where personal data is passed on by a party subject to the GDPR to recipients in third countries (for example to processors or within the corporate group), such disclosures are based on appropriate safeguards under Art. 46 GDPR, in particular the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), supplemented where relevant by a transfer impact assessment. You may request a copy of the relevant safeguards using the contact details above. Beyond this, personal data is not intentionally transferred to further third countries through this website.
10. Storage period
We store personal data only for as long as necessary for the relevant purpose or as required by statutory retention periods. Server log files are generally deleted after 30 days, unless longer storage is required for security or legal reasons.
11. Your rights and information for users in the EEA and Germany
You have the right to request access to your personal data, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interests. Where processing is based on consent, you may withdraw that consent at any time with future effect. To exercise these rights, contact us at info@lucet.ai or through the data protection officer at the contact address in Section 1.
You also have the right to lodge a complaint with a competent data protection supervisory authority if you believe that the processing of your personal data violates applicable data protection law. If you are in the EEA, you may in particular lodge a complaint with the supervisory authority in your EU member state of residence or place of work; for users in Germany, this is the data protection authority of the German federal state in which you live or work. Complaints and other requests may also be addressed to the EU representative named in Section 2.
12. Information for California residents
We do not sell personal information and do not share personal information for cross-context behavioral advertising within the meaning of the California Consumer Privacy Act as amended by the CPRA. This website uses no advertising or tracking technologies.
We do not currently meet the CCPA/CPRA applicability thresholds (annual gross revenue above the statutory threshold, buying, selling or sharing the personal information of 100,000 or more California consumers or households, or deriving 50 percent or more of annual revenue from selling or sharing personal information), so the CCPA/CPRA does not apply to us as a legal obligation. As a matter of good practice, we will nevertheless honor requests from California residents to know, correct or delete personal information; contact us at info@lucet.ai. We do not discriminate against anyone for exercising these rights.
13. Information for users in Japan (APPI)
For users in Japan, we handle personal information in accordance with the Act on the Protection of Personal Information (APPI). The business operator handling your personal information is Lucet Holding PTE. LTD., 32 Pekin Street, #5-01, 048762 Singapore, Singapore (contact details in Section 1).
Purposes of use: we use personal information of users in Japan to respond to enquiries submitted by email or through the contact function, to communicate with you about our services in the course of business, and to operate, secure and improve this website. We do not use personal information for advertising profiling and do not provide it to third parties for their own purposes.
Cross-border handling: personal information you provide is received and stored by the operator in Singapore and processed on hosting infrastructure in the EU region europe-west3 (Frankfurt, Germany). Singapore is not among the jurisdictions designated as providing an equivalent level of protection under the APPI (currently only the EEA and the United Kingdom are); we therefore inform you of the destination country and safeguard your personal information through the contractual and technical measures described in this policy, and where the APPI requires it we will obtain your consent before your personal information is provided to a third party in a foreign country.
You may request disclosure, correction, addition, deletion or cessation of use of retained personal data. For these requests and for complaints, contact info@lucet.ai or the data protection officer at the contact address in Section 1.
14. Updates to this privacy policy
We may update this privacy policy if the website, legal requirements or processing activities change. Status: October 7, 2026.