LUCENT
AI Property Operations Platform
Legal · Data Protection

Privacy Policy

How Lucent collects, uses and protects personal data across the platform — the WhatsApp intake agent, the Lucent CMS, and associated API services.

Effective 1 July 2026 Last updated 1 July 2026 Jurisdiction Singapore · PDPA
Contents
  1. 01Introduction
  2. 02Who This Policy Applies To
  3. 03Data We Collect
  4. 04How We Use Your Data
  5. 05Legal Basis for Processing
  6. 06Requestor vs. Resident Data
  7. 07Data Sharing and Third Parties
  8. 08Data Retention
  9. 09Data Security
  10. 10Your Rights
  11. 11AI & Automated Decision-Making
  12. 12Contact Us
  13. 13Changes to This Policy
01

Introduction

Lucent ("we", "us", or "our") is an AI Property Operations Platform designed to help property managers, residents, vendors and council members manage service requests and day-to-day property operations.

This Privacy Policy explains how we collect, use, store, share and protect personal data when you interact with Lucent through any of its channels — including the WhatsApp messaging interface, the Lucent CMS web application, and any associated API services.

By using Lucent, you agree to the practices described in this policy.

02

Who This Policy Applies To

This policy applies to all individuals whose data we process in connection with Lucent, including:

  • Residents — verified occupants registered to a property managed on the platform.
  • Requestors — individuals who contact the platform via WhatsApp to raise a service request. A Requestor is not automatically a Resident; these records are kept strictly separate.
  • Property Managers and Administrators — HQ Admins, Condo Managers, Building Managers and Operations Team members who use the Lucent CMS.
  • Council Members — external stakeholders with limited access for procurement approval.
  • Vendors and Workers — service providers and field technicians assigned to service requests.
03

Data We Collect

3.1Information You Provide Directly

When you raise a service request via WhatsApp, our AI Agent collects the following through a guided conversational flow:

Field Purpose
WhatsApp phone numberIdentify and contact you; link to property / unit
Name / contact detailsCreate a Requestor or Resident record
Property / unit / locationScope the service request to the correct estate
Issue title and descriptionUnderstand and classify the request
Photos or videosAssist AI in assessing category, priority and scope
Service category preferenceRoute the request to the correct vendor

Note  Voice notes are not processed. If you send a voice note, our agent will ask you to type your request or send a photo instead.

3.2Information Generated Automatically

When you interact with Lucent, the platform automatically records:

  • WhatsApp conversation transcripts — all messages sent and received during an active session.
  • Service Request records — including status changes, SLA timestamps, and assignment history.
  • AI Action Log entries — what the AI agent saw, what it recommended, the confidence score, and what action was taken or approved.
  • Operational Events — structured records of every system activity (SR created, vendor assigned, status changed, approval granted, etc.).

3.3Information We Receive From Third Parties

  • Meta (WhatsApp Business) — inbound message metadata and delivery status.
  • ScheduleR — vendor records, task status, deployment and scheduling data.
04

How We Use Your Data

We use the data described above for the following purposes:

Service Request Operations

To receive, classify, route, assign and resolve maintenance and service requests at your property. This includes using AI to suggest priority, category, SLA targets, vendor assignment, and estimated cost.

Communication and Notifications

To send you updates about your service request via WhatsApp — including status changes, vendor assignment, scheduling, and completion notifications. Messages sent outside a 24-hour session window use pre-approved Meta message templates only; no unsolicited free-text messages are sent.

Identity and Access

To authenticate CMS users (Managers, Admins, Council) via WhatsApp One-Time Password (OTP). Access is scoped strictly to properties assigned to each user.

Vendor Performance and Operational Intelligence

To record vendor response times, SLA achievement, feedback and outcome data. This information is used to build and improve the Vendor Intelligence engine over time. Vendor data is not personal data of individuals.

AI Audit and Accountability

Every AI recommendation, the human decision made in response, and the final outcome are recorded in the AI Action Log. This log supports auditability, continuous improvement and regulatory compliance.

Knowledge Base and Retrieval

Resolved service request records, vendor feedback and operational history may be embedded and indexed in our operational knowledge base (using vector search) to help the AI agent retrieve relevant context for future requests.

05

Legal Basis for Processing

Lucent operates primarily in Singapore. Our processing is conducted in accordance with the Personal Data Protection Act 2012 (PDPA) of Singapore.

The legal bases we rely on include:

  • Contractual necessity — processing required to manage properties and fulfil the service request workflow on behalf of property management companies.
  • Legitimate interests — operating the platform, improving AI recommendations, and ensuring vendor accountability.
  • Consent — where required by law, we obtain consent before processing data, particularly for residents and residents' personal data linked to tenancy records.
06

Requestor vs. Resident Data — Strict Separation

Lucent enforces a strict data separation rule (Business Rule BR-09):

  • A Requestor is any person who contacts the platform via WhatsApp. A Requestor record is created automatically when an unknown phone number submits a service request.
  • A Resident is a verified occupant whose identity has been confirmed through the Tenancy Approval flow.
  • Raising a service request as an unknown contact does not create or update a Resident record. These two databases remain separate at all times.
  • Promotion from Requestor to Resident requires explicit administrative action.
07

Data Sharing and Third Parties

We do not sell your personal data. We share data only in the following circumstances:

Recipient Data shared Purpose
Meta Platforms (WhatsApp Cloud API)Phone number, message contentDeliver WhatsApp messages to and from you
Anthropic (Claude AI)Conversation context, SR detailsAI reasoning engine for intake, classification and recommendations
Voyage AIText content for embeddingGenerate vector embeddings for the operational knowledge base
ScheduleRSR reference, vendor ID, scheduleCreate tasks, deployment signals and retrieve vendor availability
Assigned vendors / workersSR description, property, location, scheduled timeAllow the assigned party to attend and resolve the request
Property management companyAll SR data for their propertiesOperational management; data is scoped by property

All third-party processors are required to handle data in accordance with applicable data protection law.

08

Data Retention

Data type Retention period Notes
WhatsApp conversation transcripts 24 months (rolling) Retained as the "reasonable period" under PDPA; reviewed with legal.
Service Request records Per statutory records policy Aligned with property operations regulatory requirements.
AI Action Log 6 months Anonymised (PII stripped) after 6 months; records are not hard-deleted.
Knowledge Base items and vector embeddings Same as source record Deleted when the linked business record is deleted. Note: a vector copy may persist briefly until the next index refresh.
Operational Event log Per SR record lifecycle Append-only; used for audit and AI learning.
09

Data Security

We protect your data through:

  • Authentication: All CMS users authenticate via WhatsApp OTP. The Super Admin uses password authentication on a hardcoded device.
  • Role-based access control (RBAC): Each user accesses only the properties they are assigned to. Access is enforced at the database level using row-level security scoped by property_id.
  • Encryption: Data is encrypted in transit (TLS) and at rest.
  • Audit logging: Every AI action and human override is recorded and reviewable. The update source (Lucent vs ScheduleR) is stamped on every record.
  • Approval gates: AI actions above a confidence threshold may execute autonomously; lower-confidence actions require human approval before execution.
10

Your Rights

Under the Singapore PDPA (and applicable data protection law in other jurisdictions), you have the right to:

  • Access the personal data we hold about you.
  • Correct inaccurate or incomplete personal data.
  • Withdraw consent where processing is based on consent.
  • Request deletion (subject to our legal retention obligations).
  • Data portability where technically feasible.

To exercise any of these rights, contact us at the address in Section 12.

11

AI and Automated Decision-Making

Lucent uses AI (powered by Anthropic's Claude) to:

  • Classify service request categories and priorities.
  • Recommend vendor assignments based on contracts, performance data, and SLA constraints.
  • Generate status updates and notifications.
  • Identify patterns in operational data.
Human oversight is built in.

Actions with AI confidence below configurable thresholds require human approval before execution. Every AI recommendation is logged alongside the human decision that followed, ensuring full accountability. No irrevocable action (such as vendor termination or resident eviction) is taken autonomously.

12

Contact Us

For privacy-related enquiries, data access requests, or complaints, please contact:

Lucent — Data Protection Contact
Email privacy@thelucent.tech
Platform Lucent — AI Property Operations Platform

We aim to respond to all enquiries within 10 business days.

13

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in the platform, applicable law, or our practices. The "Last updated" date at the top of this page will reflect when changes were made. We will notify affected users of material changes via WhatsApp or the Lucent CMS where required.

Lucent is an AI Property Operations Platform. All rights reserved.

LUCENT · Privacy Policy thelucent.tech