Lucen Finance (“Lucen”, “we”, “us”, “our”) respects the privacy of its users. This Privacy Policy explains how we collect, use, disclose, and safeguard your Information when you visit lucen.finance, use the Lucen mobile application (the “App”), and any other media, channel, or application related thereto (collectively, the “Site”). Please read it carefully. If you do not agree with these terms, please do not access the Site.
00 — Introduction
We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. Any changes are effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change.
You are encouraged to periodically review this Privacy Policy to stay informed. You will be deemed to have been made aware of, subject to, and to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the revised version is posted.
01 — Collection of your information
We may collect the following categories of Information when you use the Services.
1.1 Personal data
Personally identifiable Information such as your name, email address, and telephone number, and demographic Information such as your age or interests, that you voluntarily give to us when you contact us or use the Site or the App. You are under no obligation to provide us with personal Information of any kind; refusal may prevent you from using certain features of the Site or the App.
1.2 Derivative data
- Log files — registries of events, processes, and messages created when you view content or otherwise interact with the Services.
- Cookies — small data blocks placed on your device by your browser; we only include cookies necessary to access and interact with the Site, and we do not use cookies to collect data that is not essential to its operation.
- Other derivative data — wallet address, IP address, browser type, operating system, access times, and the pages you viewed directly before and after accessing the Site.
1.3 Mobile device data
Device Information such as your mobile device ID, model, and manufacturer, and information about the location of your device, when you access the Site from a mobile device.
1.4 Third-party data
Information from third parties, such as personal Information you allow third parties to share with us when you connect your account and grant the App permission to access it.
1.5 Mobile application data
If you use the App we may collect:
- Geo-location — with your permission, location-based information from your device to provide location-based services (change permissions in your device settings).
- Device access — with your permission, features such as your camera, storage, or contacts.
- Device data — device information, operating system, version, and IP address.
- Push notifications — with your permission, notifications regarding your account or the App; you can opt out in your device settings.
02 — Use of your information
We use Information about you to enable the use and proper functioning of the Services, including to: operate and manage the Services; administer the Site; detect usage patterns and compile anonymous statistics; process billing and collection of any fees; answer your comments, questions, and requests; send security alerts; detect, prevent, and address fraud, breach of terms, and threats; troubleshoot problems; comply with applicable laws and regulations; and protect the security and integrity of the Services, including preventing fraudulent transactions and protecting against criminal activity.
03 — Disclosure of your information
We may share Information we have collected in the following situations.
3.1 By law or to protect rights
Where we believe disclosure is necessary to respond to legal process, investigate or remedy potential policy violations, or protect the rights, property, and safety of others, as permitted or required by applicable law — including exchanging information with other entities for fraud protection.
3.2 Third-party service providers
With third parties that perform services for us or on our behalf, including fraud prevention, payment processing, data analysis, customer support, and hosting. Providers are restricted to using the Information only on our behalf and in accordance with our instructions.
3.3 Affiliates
With our affiliates and related entities, which we require to honour this Privacy Policy.
3.4 Business partners
With business partners to offer and improve certain products and services.
3.5 Sale or bankruptcy
If we reorganize, merge, are acquired, or transfer assets, your Information may be transferred to the successor entity, which may decline to honour commitments made here.
3.6 Consent and request
With your consent or at your request. We are not responsible for the actions of third parties with whom you choose to share personal data.
04 — Tracking technologies
4.1 Cookies and web beacons
We may use cookies, web beacons, and similar technologies on the Site and the App. Most browsers accept cookies by default; you can remove or reject them, but doing so could affect the availability and functionality of the Site or the App.
4.2 Analytics
We may partner with selected third-party vendors to analyse and understand use of the Site through first- and third-party cookies. We do not transfer personal Information to these vendors. You are encouraged to review their privacy policies and contact them directly.
05 — Third-party websites
The Site and the App may contain links to third-party websites and applications not affiliated with us. Once you leave the Site, any Information you provide to those third parties is not covered by this Privacy Policy, and we cannot guarantee its safety and privacy. Review the privacy practices of any third party before providing information. We are not responsible for the content or privacy and security practices of any third parties.
06 — Security
We use administrative, technical, and physical security measures to help protect your Information. While we have taken reasonable steps, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against interception or misuse. We therefore cannot guarantee complete security.
07 — Your rights and choices
Cookies. We use only strictly necessary cookies — those essential for you to browse the Site and use its features, including accessing secure areas.
Do-Not-Track. See section 08 below.
Statutory rights. Your rights as a data subject are set out in section 09 below.
08 — Controls for Do-Not-Track features
Most browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature. No uniform standard for recognising DNT signals has been finalised, and we do not currently respond to DNT signals. If a standard is adopted in future, we will inform you in a revised version of this Privacy Policy.
09 — International & Panama data-protection basis
Lucen Finance is established in the Republic of Panama. We process your personal data in accordance with Panama’s Law 81 of 2019 on the Protection of Personal Data (Ley 81 de 2019) and its implementing regulations.
Lawful basis
We process personal data where: you have given consent; processing is necessary to provide the Services you request; processing is necessary to comply with a legal obligation; or processing is necessary for our legitimate interests, provided your rights and freedoms do not override them.
Your rights (titular)
Under Ley 81 de 2019 you may access your personal data; request its rectification; request its cancellation (deletion); and oppose (object to) its processing — the “ARCO” rights — as well as request portability of your data. To exercise any right, contact us at privacy@lucen.finance, specifying the right you wish to exercise. We will respond within the period established by applicable law and may require information to verify your identity.
Supervisory authority
You may lodge a complaint with the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI), Panama’s data-protection supervisory authority.
Blockchain immutability
Notwithstanding the above, we cannot edit or delete information recorded on a public blockchain. This may include transaction data (purchases, sales, transfers) tied to your blockchain wallet address and any tokens held by it.
EEA & UK users
If you are located in the European Economic Area or the United Kingdom, you also have the rights afforded under the GDPR and UK GDPR — including access, rectification, erasure, restriction, objection, and portability, and the right to withdraw consent — and you may lodge a complaint with your local data-protection authority. Where we transfer personal data internationally, we rely on appropriate safeguards such as standard contractual clauses.
10 — Contact us
If you have questions or comments about this Privacy Policy or our data practices, contact us:
By email · privacy@lucen.finance
By mail · Lucen Finance, [PLACEHOLDER — registered address], Panama
[PLACEHOLDER — registry / folio number, if displayed]