LFE Privacy Statement – July 2018
I. Scope of this Privacy Statement
This Privacy Statement describes the types of personal information LFE Market Ltd , Inc. (“LFE,” “us,” “we” or “our”) collects through www.LFE.com and any affiliated LFE sites (collectively, the “Site”) and through your use of the services available on the Site (the “Services”), and how we collect, use, and share that information. When we collect, use and share such information we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that information for the purposes of those laws.
II. What Personal Information do we Collect
A. Information You Give Us
You will also be asked to submit personal information or request information from us in order to use the Services offered through this Site. Once you provide us with personal information about you, you are no longer anonymous to us. This information may include:
• Registration Information: When you sign up to receive the Services, you may be required to provide information such as your name, address, phone number, email address, social security number, as well as residency information and sensitive financial documents, including without limitation bank statements, brokerage statements, asset statements, tax returns, and third party confirmation letters.
• Payment Information: In order to obtain the Services through the Site, you may be required to provide payment information in the form of bank account information, credit and/or debit card information, or a digital wallet compatible with Ethereum and/or Bitcoin and/or Ripple so that we may process the transaction, including without limitation the name of the wallet holder and wallet address.
• User Testimonials: You may choose to provide us with user testimonials. This information may be made public to users of the Site and other third parties.
• Additional Information: Additional information that you provide to us may include your investment information, feedback, messages, emails, and answers to surveys or questionnaires that you may submit, as well as any contact information you provide in order to receive updates from us.
B. Location Information.
We may collect your physical location information if you use the Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser. You may choose not to provide location-based information to us by disabling location sharing in your browser settings, but we may not be able to offer you location-based services and/or determine your eligibility to participate in offers.
C. Automated Information Collection
Automated information collection includes “passively collected” information that is, but not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:
• Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
• Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our Site and Services.
• URLs. When you visit or access the Site, we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.
• Aggregate Information. We may compile certain personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of people who have visited the Site and other user demographics. Such aggregate information does not identify you individually.
III. How do We Use Personal Information?
Under data protection law, we can only use the personal information you provide if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:
• processing is necessary for the performance of the Services we provide to you;
• processing is necessary for the purposes of the legitimate business interests pursued by us (in particular undertaking statistical analysis to help us manage our business and prevent unauthorised access and modification to our systems); and
• processing is necessary for compliance with a legal obligation to which we are subject (including undertaking screening for financial and other sanctions or embargoes and conduct checks to identify you and verify your identity).
Personal information collected through the Site may be used by us, our affiliates and third parties (but, in each case, only where it is lawful to do so) for purposes of:
• Completing required regulatory verifications for use of the Services through the Site;
• Managing your account and providing the Services through this Site;
• Responding to your questions and feedback;
• Contacting you, whether by email, postal mail, or telephone with information about this Site or our Services;
• For such purposes as you may authorize at the time you submit the information;
• Auditing, research, and analysis to maintain, protect, and improve this Site and our Services;
• Ensuring the technical functions of our network;
• Improving and customizing the content and layout of the Site;
• Developing new products and services; or
• Compiling personal information and other information collected through the Site on an aggregate basis.
IV. How do we Share Personal Information?
We may, where it is lawful for us to do so, sell, rent, trade, or otherwise share personal information collected through the Site in the circumstances described below.
• In Connection with the Services. Provision of the Services to you may require that we share certain personal information with third parties involved in the provision of Services. Such third parties may include those that provide identity verification, website hosting, marketing, analytics and fulfillment services.
• Subsidiaries and Affiliates. We may share personal information with our subsidiaries, affiliates and third parties for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
• Consent. We may share personal information in accordance with any consent you provide.
• Required by Law. We may disclose personal information or any information collected through this Site if we are required to do so by law (g., for purposes of completing required verifications for provision of the Services to you) or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
• Certain Transactions. We may disclose or transfer personal information or any information collected through this Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.
Personal information may be transferred and/or accessed in countries outside the European Economic Area (EEA), including the United States. We will only transfer your personal information outside the EEA where either the transfer is to a country which the European Commission has decided ensures an adequate level of protection for your personal information, or we have put in place adequate safeguards as required by applicable data protection law. If you would like further information please contact us using our details set out at the end of this Privacy Statement.
V. Your Choices and Rights
A. Information You Provide
You can always choose whether or not to provide information on the Site. However, if you choose not to disclose certain information, you may not be able to receive the Services or access certain portions of the Site.
B. Communications From Us
If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at firstname.lastname@example.org
C. Do Not Track
Our Site does not honor “do not track” signals or other mechanisms. However, as described in more detail in Section II.C of this Privacy Statement, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.
D. Your Rights
You have the following rights, which you can exercise free of charge:
Access The right to be provided with a copy of your personal information (the right of access).
Rectification The right to require us to correct any mistakes in your personal information.
Erasure The right to require us to delete your personal information—in certain situations.
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object The right to object:
—at any time to your personal information being processed for direct marketing (including profiling); or
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
Withdraw consent The right to withdraw your consent to us processing your personal information at any time if our processing is based on your consent.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
VI. Information Storage and Security
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. These security measures include the following:
• All stored personal information is encrypted using IEncryption library, using 256-bit AES algorithms.
• Uploaded user documents used for investor status verification are encrypted for storage using 256-bit AES algorithms.
• Multi-tier server architecture is used to safeguard user data. The Web layer is located in a DMZ and a Web Application Firewall is used to isolate server infrastructure from internet-based attacks.
• We employ Secure Socket Layer (SSL) technology to secure and encrypt communications between the Site and web browsers.
However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
Children are not eligible to use the Site, and we ask that minors (children under the age of majority in the country in which they reside) not submit any personal information to us.
VIII. External Links
IX. Data Retention and Complaints
A. How Long Your Personal Information Will Be Kept
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
When it is no longer necessary to retain your personal information, we will delete it.
B. How to Complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
X. Updates to this Privacy Statement
We may change or update the Site or any of our policies and procedures without prior notice. We will notify you by email to advise you of any significant changes to this Privacy Statement.
XI. Questions Regarding this Privacy Statement
If you have any questions or comments regarding this Privacy Statement, please send us an email at email@example.com.