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This “Privacy Policy” describes how and when Lucrotec, LLC (“Lucrotec”) collects, uses, shares, and protects personal information of Lucrotec’s clients, prospects, employees, partners, consultants, and website visitors.


For purposes of this Privacy Policy, the term:

“Personal information,” refers to information that identifies an individual or relates to an identifiable individual. The types of personal information collected and used by Lucrotec are identified below.

“Non-personal information” is information that does not permit direct association with an individual.

“Human resources data” refers to personal data about employees, past or present, collected in the context of the employment relationship. Examples of other types of personal data that could be covered include the following: customer, client, visitor, and clinical trial data.

  • Human resources data
  • Personal data other than human resources data

Lucrotec is committed to cooperating with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and complying with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Collection and Use of Information

Clients, Prospects and Partners

Lucrotec collects personal information from our clients, prospects and partners. Lucrotec may collect, use, transfer and disclose non-personal information for any purpose. The information may be collected by members of our marketing, legal, sales, operations, professional services, client support and administrative teams. The information collected includes, but is not limited to: contact information (i.e., name, address, telephone numbers, e-mail address, company, IP address, etc.) and user preference information.

In general, Lucrotec uses the personal information collected for purposes of responding to user requests for information about our company, products and services, to manage your participation surveys and promotions and to enable better communication through our blogs, online forums, social media pages and other interactive media found on our website and elsewhere on the internet.

Employee Client Information

To deliver Lucrotec’s products and services, we are provided and receive employee information from our clients and partners (e.g., when our partners white label our products and services).

This employee information may contain one or more of the following data elements which are considered personal information: employee identification, name, title, location, corporate e-mail address, department and/or cost center, phone numbers, and corporate address, etc.

We receive invoice, billing and usage information of the assets we manage for our clients. This information includes data regarding mobile devices, fixed lines or software subscriptions. We obtain this information either directly from service providers, our clients or partners. This data is only used for the delivery of Lucrotec’s products and services to our clients and partners and often includes the following:

  • Creating secure online databases to enable asset, cost management, cash management and greater data visibility
  • Aligning users to the corporate services they are granted access to related to our database, products and services
  • Ensuring vendor billing accuracy and compliance with their service provider contract terms and conditions
  • Identifying and implementing cost savings, cost management, cost avoidance, audit and potential profit opportunities
  • Ensuring that our database is kept updated and maintained
  • Benchmarking, monitoring and tracking supplier negotiations
  • Generating non-personal, aggregated financial and statistical information at a client, partner and industry level

Website(s) Visitors

It is the practice of Lucrotec to collect personal information related to visitors to our website(s) only when the visitor chooses to provide such data. Visitors have the opportunity to provide personal information such as name, company, address, phone number and email address. Providing this type of information on our website(s) to Lucrotec allows visitors to request and receive more details about our company, products, services, and register their company. We use registered user data to analyze trends, statistics (regarding the use of our website(s)), improve the user experience, among other things.

Website(s) and Cookies

Those visiting the Lucrotec website(s) can visit us without providing personal information. Computers connected to the internet, however, contain information such as IP address (i.e., Internet Protocol) and domain name which may identify the computer and network attempting to access our website(s). This information may be captured and stored for use related to tracking and reporting purposes.

“Cookies” are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies allow the website to remember critical information about a Lucrotec website visitor. Lucrotec uses cookies to improve the visitor’s on-line experience and provide customer and client support related to our website. For instance, we use cookies to monitor the total number of visitors to our site(s). We perform this analysis on an anonymous and aggregated basis. We may also use cookies as a way to remember returning visitors and to keep track of the items requested by the user from Lucrotec. The use of cookies also helps us customize your website experience on return visits to the Lucrotec site(s). We track the pages visited from our website and the content accessed. In those cases, we may associate personal information with a cookie on file.

Lucrotec websites use cookies provided by Google Analytics to track and report user interactions. This information is anonymous in nature and may include an IP address. This information is transmitted to Google and used to determine which pages are more appealing to our visitors.

We will never allow any third party to, use Google Analytics to track or to collect any personally identifiable information of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any personally identifiable information from any source, unless you explicitly submit that information via a fill-in form on our website.

Disclosure of Information

Except as otherwise provided herein, Lucrotec contracts with third-party vendors to perform certain functions on Lucrotec’s behalf that enhance our existing and future product and service offerings. These third-parties will have access to personal information only to the extent necessary to permit them to do their jobs. Such recipients must agree to abide by confidentiality obligations. Examples of third-parties that may receive personal information include analysts or consultants that have been contracted on behalf of your employer (the clients with which we are contracted) and will only be provided with advance written notice.

All third-parties receiving personal information must have a written confidentiality agreement in place between client and third-party and Lucrotec and third-party that meets or exceeds Privacy Shield standards. For example, Lucrotec may store such personal data in facilities operated by third-parties. Such third-parties must agree to use such personal data only for the purposes for which they have been engaged by Lucrotec and they must either: (1) comply with the Privacy Shield principles or another mechanism permitted by the applicable European data protection law(s) for transfers and processing of personal data; or (2) agree to provide adequate protections for the personal data that are no less protective than those set out in this policy.

In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, Lucrotec is potentially liable. Lucrotec’s liability under this agreement will be governed by the contract in place between the client and Lucrotec.

Lucrotec and its third-party vendors and suppliers may disclose or otherwise use personal information where we or they reasonably believe such disclosure is needed to: (a) satisfy any applicable law, regulation, legal process, or government request, (b) enforce the applicable contract between you and Lucrotec, including investigations of potential violations thereof, (c) detect, prevent or otherwise address illegal or suspected illegal activities, security or technical issues, or (d) protect against harm to the rights, property or safety of Lucrotec, its employees and clients or the public as required or permitted by law.

Lucrotec may disclose personal information in the course of any reorganization, restructuring, merger, acquisition or sale, or other transfer of assets. Lucrotec reserves the right to transfer information, including personal information, provided that the receiving party agrees to respect that personal information in a manner that is consistent with this Privacy Policy.

Notice of Privacy Rights to California Residents. Companies that collect Personal Information from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having his or her information shared with third parties. We have elected the second option, and you may request that your Personal Information not be shared with third parties by sending your request, including your full name, email address, and postal address Lucrotec at the corporate address under Contact Us.  California residents are also entitled to know that they may file grievances and complaints with the California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to

PIPEDA . The Personal Information Protection and Electronic Documents Act (PIPEDA) applies to private-sector organizations across Canada that collects, users, or discloses personal information in the course of a commercial activity. PIPEDA does not apply in instances where business contact information such as an employee’s name, title, business address, telephone number or email addresses that is collected, used or disclosed solely for the purpose of communicating with that person in relation to their employment or profession. PIPEDA does not apply for Lucrotec; Lucrotec only uses and stores limited business contact information for communicating with clients and partners.


Access and Amendments

Maintaining an accurate database for our clients and utilizing the data provided by clients, is a fundamental part of Lucrotec’s routine offerings. We have established products and services that are customized to each client’s needs and preferences. Implementation of these products and services includes Lucrotec taking reasonable steps to assist users to correct, amend or delete personal information that is demonstrated to be inaccurate or incomplete. We want to make it easy for individuals to communicate to Lucrotec especially regarding any updates or requests for changes to their information. Our staff is trained and familiar with their role in efficiently taking in these requests in a customer friendly manner.

Lucrotec will agree to data changes on an individual and client specific basis. Most changes are provided in routine automatic data feeds by our clients. In instances where changes are managed by Lucrotec the user will need to provide sufficient identifying information to begin the change request process. For example, Lucrotec may request additional identifying information as a security precaution.

Individuals who want to know what data is being held about them and understand how it is being used, by any organization, can submit a Subject Access Request (SAR) in writing, which can be done using the “Contact Us” section of this privacy policy, below.


Lucrotec employs reasonable and generally accepted measures to protect personal information from loss, misuse, unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Lucrotec conducts periodic internal and external audits to ensure that personal information is maintained in a manner consistent with this Privacy Policy.

Any employee, vendor, or supplier found to have violated this Privacy Policy will be disciplined, up to and including termination of employment or termination of service contract. Lucrotec will further correct any deficiencies identified by internal and external audits to ensure continued compliance with this Privacy Policy. No security system, however, can be guaranteed to be 100% secure. If you have any questions about the security of personal information, you can contact us via the “Contact Us” section of this Privacy Policy.

Lucrotec complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and/or Switzerland to the United States in reliance on Privacy Shield.  Lucrotec has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit

Under the Privacy Shield program individuals must first contact the company with their concerns. Lucrotec is committed to resolving issues promptly. If an individual is not satisfied they have a choice of 3 mechanisms: (1) independent Dispute Resolution at no cost to the consumer; (2) work with the local DPAs (to be used for customer data and must be used for HR data); or (3) arbitration as last resort. EU citizens can also sue in a private cause of action (e.g., false claims).

Lucrotec is fully committed to resolving privacy complaints, and when appropriate, utilizing an independent dispute resolution mechanism, the International Centre for Dispute Resolution the international division of the American Arbitration Association. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Lucrotec, please visit the AAA Privacy Shield website at for more information and to file a complaint. Under Privacy Shield, participants must respond promptly to inquiries and requests by the Department of Commerce for information relating to the Privacy Shield Framework. Lucrotec is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Contact Us

Lucrotec strongly encourages any complaints with regard to this Policy or Lucrotec’s implementation of this policy be raised with Lucrotec first using the contact information set forth below.

For suspected violations please include a description of the violation, date or timeframe in which the suspected violation occurred and your contact information. Lucrotec takes any report of privacy violation very seriously and will investigate each report to the fullest extent possible.

Subject Access Requests may also be submitted to the details below. Lucrotec, Inc.

100 Executive Avenue, Suite 301
Rockaway, NJ 07960 USA
ATTN: Chief Compliance Officer


Last Updated: September 23, 2019