Privacy Notice
Last updated 12 October 2026
Luscent runs on a simple privacy posture: we collect little, we track nobody, and the sensitive data our platform processes for client firms never touches this website. This notice explains what we do collect when you visit luscent.io or apply to the pilot programme, why, and the rights you have.
Who we are
The website luscent.io is operated by Luscent S.à r.l. (in formation), a company being incorporated under the laws of the Grand Duchy of Luxembourg (“Luscent”, “we”). Registered office: 9, rue du Laboratoire, L-1911 Luxembourg. Once registration with the Luxembourg Trade and Companies Register (RCS) completes, this notice will state the registered company details.
For anything in this notice: privacy@luscent.io.
What this notice covers, and what it does not
This notice covers the luscent.io website: visitors, pilot-programme applicants, and people who correspond with us.
It does not cover the Luscent platform. When a wealth management firm uses Luscent, the firm remains the controller of its client data and Luscent processes that data on the firm's documented instructions under a Data Processing Agreement, on EU infrastructure. That processing is governed by the firm's agreement with us and the firm's own privacy notices, not this page. An overview is in our Trust Center.
What we collect
Pilot programme applications. If you apply on the pilot page, we collect what the form asks for: institution name and type, assets under management (band), number of relationship managers, primary jurisdiction, website, your full name, position title, and work email.
Meeting bookings. If you book a call on the pilot page, we receive what the booking form asks for: your name, your email and anything you choose to add. Booking runs on Cal.com, which loads only when you pick a meeting length.
Correspondence. If you email us or connect through LinkedIn, we process the contact details and content you choose to send.
Site analytics, without cookies. We use our hosting platform's privacy-first analytics (Framer), which gives us aggregate counts: page views, approximate region, device class. It sets no cookies and does not track you across sites. We cannot identify site visitors and do not try to. The detail is in our Cookie Policy.
We do not buy visitor data, run advertising pixels, or enrich profiles of people who visit this site.
Why we process it (legal bases)
| Processing | Purpose | Legal basis (GDPR Art. 6) |
|---|---|---|
| Pilot application data | PurposeAssess the application, run the selection process, contact you about it | Legal basis (GDPR Art. 6)6(1)(b): steps prior to entering a contract, at your request |
| Correspondence | PurposeAnswer you; maintain the business relationship | Legal basis (GDPR Art. 6)6(1)(f): legitimate interest in running our business communications |
| Aggregate analytics | PurposeUnderstand what content is read; improve the site | Legal basis (GDPR Art. 6)6(1)(f): legitimate interest, using the least intrusive tooling available |
| Site delivery and security logs (hosting level) | PurposeServe the site, prevent abuse | Legal basis (GDPR Art. 6)6(1)(f): legitimate interest in a secure, functioning website |
| Record-keeping where law requires it | PurposeCompliance with legal obligations | Legal basis (GDPR Art. 6)6(1)(c) |
We do not use website data for automated decision-making that produces legal or similarly significant effects, and we do not profile site visitors.
Who receives data
We use a small number of service providers (“processors”) to run this website and our business:
| Provider | Role | Location of processing |
|---|---|---|
| Framer B.V. (Netherlands) | RoleWebsite hosting, form handling, cookieless analytics | Location of processingEU-based provider; some sub-processing may occur outside the EEA under Standard Contractual Clauses |
| Microsoft (EU Data Boundary) | RoleEmail and business systems where applications and correspondence are handled | Location of processingEU Data Boundary |
| Cal.com, Inc. (United States) | RoleMeeting scheduling on the pilot page, loaded only when a visitor picks a meeting length | Location of processingUnited States; see section 08 |
We do not sell personal data. We do not share it with advertising networks. We disclose it only to the providers above, to professional advisers where necessary, or where law requires disclosure.
How long we keep it
- Pilot applications: for the duration of the selection process and 12 months after our last contact, unless we enter an agreement with your firm, in which case the contract's terms govern.
- Correspondence: as long as needed for the relationship and any applicable business-record retention periods.
- Aggregate analytics: contains no personal data in our hands.
Your rights
Under the GDPR you can ask us for access, rectification, erasure, restriction, portability, and you can object to processing based on legitimate interest. Write to privacy@luscent.io; we respond within 30 days.
You also have the right to complain to a supervisory authority: in Luxembourg, the Commission nationale pour la protection des données (CNPD, cnpd.lu), or the authority of your habitual residence.
If you are in Brazil, we honour the equivalent rights under the LGPD through the same contact.
Where data lives
This website is served by an EU-based hosting provider. Our own platform and business systems run on EU infrastructure (Scaleway, France; Hetzner, Germany; Microsoft EU Data Boundary). Where a provider, or one of its sub-processors, processes data outside the EEA, as Cal.com does for meeting bookings, transfers rest on Standard Contractual Clauses or an adequacy decision.
Children
This site addresses professionals in financial services and is not directed at anyone under 18.
Changes
We update this notice when our processing changes and stamp each version with its date. Material changes to how we handle application data will be communicated to affected applicants directly.