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LCX is committed to protect and respect your privacy. At the same time, LCX is a strong supporter of blockchain regulation where accountability and transparency are equally important. Ultimately, building the key infrastructure for a new financial world. 

Privacy Policy

[Last revised: March 9th, 2020]

1. GENERAL PROVISIONS

This Privacy Policy governs your use of products, services, content, features, technologies or functions offered by LCX and all related sites, applications, and services (collectively “LCX Services”) including, without limitation, when you provide any information to us in relation to your use of LCX Services.

You accept and consent to this Privacy Policy when you sign up for, access, or use the our Services. By accepting and consenting to this Privacy Policy, you expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

In order to operate the our Services, to meet out regulatory obligations and to reduce the risk of online fraud, LCX AG (“LCX”, “we”, “our”, “us” or “the Company”), LCX, as a data controller, must ask you to provide us with information about yourself, including your personal details, and information about any  financial instruments or payment options that may be connected to your use of LCX Services, as well as any other types of information specified in this Policy. 

By consenting to and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. LCX takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. For the purposes of this Privacy Policy, the term “information” means any confidential and/or personally identifiable information or other information related to your use of our services. 

We will not sell or rent your information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer LCX Services to our users; enhance the quality of our Services from time to time; and protect the interests of our users, we will in limited circumstances share some of your information with third parties under strict restrictions, as described in greater detail in the following sections of this Policy. It is important for you to review this Privacy Policy as it applies to all LCX Services.

This Privacy Policy is intended to govern the use of LCX Services by our users (including, without limitation those who may use our Services in the course of their trade or business) unless otherwise agreed through contract.

Personal information or data refers to any information that can be associated with a specific person and can be used to identify that person, directly or indirectly, in particular by reference to required information that the user provides to LCX to gain access to and use our Services (hereinafter “Personal data” or “personal information”).

LCX is aware of the importance of how Personal data is handled and will observe all applicable data protection laws, in particular the General Data Protection Regulation (EU) 2016/679 (hereinafter: GDPR).

Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.

Changes to this Privacy Policy: All future changes to this Privacy Policy are incorporated by reference into the Terms and Conditions (our contract) with you and will take effect as specified in the Policy Updates, when they may occur. “Policy Update” means a prior notice of changes to any of your agreements with LCX, which we may make available to you in writing, including in electronic form. If you disagree with the terms of this Privacy Policy, please do not register for or use the LCX Services.

 

Notification of Changes: This Privacy Policy may be revised over time, for example, as new features are added to LCX Services, or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised Privacy Policy. We may post the notice on our website and/or send the notice by email. As of the effective date of the revised Privacy Policy, you will be considered as having consented to all changes to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your user account  with us at any time.

Third Party Websites: Some pages on the LCX website may include links to third-party websites. These sites are governed by their own privacy statements, and LCX is not responsible for their operations, including, but not limited to, their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.



2. COOKIE POLICY

When you access our website, or use our Services, we (including companies we work with, as the case may be) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We use Cookies to recognize you as a customer, customize our Services, content and advertising, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety across our sites and LCX Services.

Most web browsers are set to accept cookies by default. You are free to decline most of the cookies if the browser or browser add-on permits. Choosing to remove or disable cookies may interfere with the use and functionality of the Services. Additionally, LCX may use certain persistent cookies that are not affected by browser settings but will use such cookies solely for identity verification and fraud prevention purposes.

 

3. INFORMATION LCX COLLECTS

 

Information we collect from users:To register for and use the LCX Services, you must provide your full name, address, phone number, the details of your identification document, and email address. In order to top-up your wallet balance with us or make certain payments or transactions through the our Services, you must provide (where applicable) your payment instrument or account information details, API details and other information required. We may also ask you to choose different security questions to answer for the purposes of account verification or password reset.

We may also require you to provide us with other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through our Services or as is otherwise required in order for us to comply with our anti-money laundering  and risk management obligations.

Using your device: When you use LCX Services using any device), we may additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data.

Photographs: If you use certain functionalities provided by us,  we may ask you to upload a picture of you in order to provide you with these specific services. Your face must be recognizable.

Transaction Information: When you use the our Services to send funds to someone else or request money from someone else, as the case may be, we may ask you to provide information related to that transaction. This information includes the amount and type of the transaction, transactional details and the details pertaining to the identity of the third party. Also, if you send funds to another LCX customer, you may be asked to provide personal details to that customer to complete the transaction. Those details may also be passed on to us from that customer. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to access or use our Services, in order to help detect possible instances of unauthorized transactions.

Information About You From Third Parties: In order to execute certain transactions of our customers, protect all our customers against potential fraud,  comply with our legal obligations and enforce our Terms and Conditions, we verify and validate information provided to us by users with a number of 3rd parties, such as financial partners, fraud agencies, data vendors, as well as using information available through internet and publicly accessible social network data. In the course of such verification, we may receive personally identifiable information about our users from such services and sources. 

If you send or receive high overall  payment volumes or display inconsistent transactional patterns through LCX Services, or if you have a limited transactional history with us, in some circumstances we will conduct a background check on you by obtaining information about you and your activities, and potentially (if legally permitted) also about your business partners,  from a credit reference or fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. LCX, at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close a user account based on information obtained during this credit review process.

 

We may also collect public information about your activities and your behavior on social media platforms (such as the email address and the number of “likes” and “followers”), to the extent relevant to confirm an assessment of your transactions and/or  the nature of your activities that are relevant to our services offered to you.

 We may also collect information about you from other sources, including from other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).

 

Examples of information we automatically collect about you may include:

  • the Internet protocol (IP) address used, information about your device and its location, as well as the details about your internet provider or mobile phone operator;
  • your login, e-mail address, password and the outcome of the strong authentication methods you use;
  • your interaction with our services, for example, the content you viewed, uploaded or downloaded, your transactional history;
  • your (URL) clickstream to, through and from our website (including date and time); cookie number, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
  • phone numbers used to call our customer service number.

 

Additional Verification: If we cannot verify the information that you provide, or if you request a withdrawal to an account, payment instrument or digital wallet  not previously used by you, we may ask you to upload or send us additional confirmation or to answer additional questions online to help verify your information.

 

Website Traffic Information: Because of the way Internet communication standards work, when you arrive at or leave the LCX website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website.

 

Communications: When you communicate with us for customer service or other purposes (e.g., by emails, calls, tweets, etc.), we retain such information and our responses to you in the records of your account.

 

Questionnaires, Surveys, Sweepstakes and Profile Data: From time to time, we offer optional questionnaires, surveys, online competitions and sweepstakes to our users for such purposes as collecting demographic information or assessing users’ interests and needs. If we collect personally identifiable information from our users in these questionnaires, surveys, and sweepstakes, the users will be given notice of how the information will be used prior to their participation in the survey, questionnaire or sweepstake.

 

Account Information: For the purposes of this Privacy Policy, account information (“Account Information”) includes without limitation: name, address, email address, phone number, username, photograph, IP address, device ID, geolocation information, account numbers, account types, details of funding instruments associated with the account, details of payment transactions, details of commercial transactions, customer statements and reports, account preferences, details of identity collected as part of our “know your customer” checks on you, and customer correspondence.

 

Some of this information, for example, indicating your racial origin or biometrical details, is considered especially sensitive, from the point of view of data protection, and we will use and process this information in strict accordance with the law.

4. HOW LCX MAY USE CUSTOMER INFORMATION

Below is a summary of how LCX may use customer information collected from our users or about our users.

Internal Uses: We collect, store and process your information on servers located in the European Economic Area and Switzerland. Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:

  • Process and execute your transactions and provide the LCX Services;
  • Verify your identity, including during account creation and password reset processes;
  • Resolve disputes, collect fees, and troubleshoot problems;
  • Manage risks, or to detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities;
  • Detect, prevent or remediate violations of policies or applicable user agreements;
  • Provide you with customer support services;
  • Improve the LCX Services by customizing your user experience;
  • Measure the performance of LCX Services and improve the content and layout of our website and user interfaces;
  • Manage and protect our information technology infrastructure;
  • Provide targeted marketing and advertising (if you opted in to receive them), provide service updates, and deliver promotional offers based on the communication preferences you have defined for your LCX account; and
  • Perform online security, compliance, risk, creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties, as the case may be.

 

Questionnaires, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use such information to improve our Services, send your marketing or advertising profile preferences, or as otherwise explained in detail in the survey or campaign itself.

 

Our Contact with Customers: We communicate with our users on a regular basis via email and chats to provide requested services. We may also communicate with our users by phone or using VOIP technologies to:

  • Resolve customer complaints or claims made by users;
  • Respond to requests for customer service;
  • Inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
  • Confirm information concerning a user’s identity, business or account activity;
  •  Carry out collection activities;
  • Conduct customer surveys; and
  • Investigate suspicious transactions.

We use your email to confirm your opening of a LCX account, to send you notices and confirmations related to your activities, to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be informational in nature, and not promotional.

We may also use your email address to send you other types of communications that you can control, including “news”, “customer surveys”. You can choose whether to receive some, all, or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account and then selecting settings, and updating your communicational preferences.

In connection with independent audits of our financial statements and operations imposed by applicable law, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.

 

5. MARKETING

LCX may use your Personal data to form a view on what we believe might enhance your user experience or present you with information that may be of interest to you. 

If you don’t wish to receive marketing communications from us, or to participate in our ad-customization programs, simply update your preferences.

If you would like to change your personal communication preferences or opt-out from receiving any marketing communications from us, you can do so  by adjusting your preferences in the communication preferences profile section or by contacting us at: .

 

6. DISCLOSURE OF YOUR PERSONAL DATA

 

We work with third parties to enable you, them and potentially their customers to accept or facilitate payments from or to you using the LCX Services. In doing so, a third party may share information about you with us such as your full name, email address or wallet address, when a payment is sent to you or when you are attempting to pay that third party. We use this information to confirm that you are a LCX customer and that LCX can be enabled to make a payment or make a transfer, or where a transfer is sent to you to send you a notification that you have received a payment. Please note that third parties you receive funds or transact with may have their own privacy policies, and LCX is not responsible for their operations, including, but not limited to, their information practices.

If you are a registered LCX user and you are sending funds or transacting with another registered LCX user, as a part of the transaction, some personal information of both parties will be shared as a part of transaction notification.

By accepting this Privacy Policy, you expressly agree and consent that each time you transact or attempt to to transact using LCX Services with a third party, LCX may transfer the relevant data to such third party, who may be located outside the European Economic Area (EEA), in order to process, execute or otherwise deal with and provide information about the transaction. You also expressly agree and consent to LCX providing transactional information and other information necessary to another LCX customer whom you have explicitly selected or chosen using the LCX service.  

How We Share Information with Other Third Parties. LCX works with third-party service providers which provide important functions to us that allow us to be an easier, faster, and safer way to facilitate transactions, display information and otherwise offer our services to you. We need to disclose certain user data to them from time to time, so that the services can be performed.

LCX will not transfer, disclose, sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy. This includes transfers of data to non-EEA countries, which LCX will always endeavor to carry out in compliance with the requirements of the applicable data protection law. In this regard, transfers to non-EEA countries may notably be carried out on the basis of adequate contractual arrangements, a copy of which may be obtained by you by simple request sent to LCX.

In order to provide the LCX services, some information we collect  may be required to be transferred to other entities, in their capacity as financial partners, payment providers, custodians, payment processors, technical service providers or account holders (or similar capacities). You acknowledge that according to their local legislation, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities in their relevant country.

 

Specifically, you consent to and direct LCX to do any and all of the following with your information:

  • Disclose necessary information to: the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies, departments, regulatory authorities, self-regulatory authorities or organizations and other third parties, that (i) we are legally compelled and permitted to comply with, including but without limitation the US Foreign Account Tax Compliance Act (“FATCA Law”) and with the OECD common reporting standard (“CRS Law”) as implemented in the Liechtenstein regulatory framework; (ii) we have reason to believe it is appropriate for us to cooperate with governmental agencies or payment or processing partners in investigations of fraud or other illegal activity or potential illegal activity, to the fullest extent permitted by law, or (iii) to conduct investigations of violations of our Terms and Conditions (including without limitation, your funding source or transactional history).  If you are covered by the FATCA or CRS Law, we are required to give you notice of the information about you that we may transfer to various authorities. If we believe your account may be subject to these regulations, we may notify you separately.
  • We and other organizations, including financial institutions that cooperate with  LCX, may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing).
  • Disclose necessary information in response to the requirements of other financial institutions, credit card associations or a civil or criminal legal process.
  • Disclose necessary information to the payment processors, financial partners, technical service providers, auditors, customer services providers, credit reference and fraud agencies, financial products providers, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties, in order to provide our services to you our pursue our other legitimate interests. 
  • Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
  • Disclose aggregated (i.e.: anonymized) statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in a certain city. However, this aggregated information is not tied to personal information.
  • Share necessary Account Information with unaffiliated third parties (listed below) for the following purposes:

o   Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk, as permitted by applicable law.

o   Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).

o   Legal & Compliance: to help us and our partners comply with anti-money laundering and counter-terrorist financing verification requirements, as permitted by applicable law.

o   Service Providers: to enable service providers under contract with us to support our business operations, namely fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.

o   Mergers or Acquisitions: As with any other business, it is possible that in the future LCX could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by LCX, including customer information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

 

7. STORAGE SECURITY & INTERNATIONAL TRANSFERS

 

LCX is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities, and who have committed themselves to confidentiality undertakings.

The security of your LCX account information also relies on your protection of your password or access credentials. You may not share your LCX password with anyone. LCX representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorized and suspicious and forwarded to us. If you do share your LCX password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away.

LCX is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information if your data is transferred outside of the EEA. In this regard, transfers to non-EEA countries may notably be carried out on the basis of adequate contractual arrangements, a copy of which may be obtained by you by simple request sent to LCX.

The Personal data that we collect from you will be transferred to and stored at a destination inside the European Economic Area (EEA) or Switzerland. As we provide an international service, your Personal data may be processed outside of the EEA in order for us to fulfil our contract with you to provide the LCX Services.

All information you provide to us is stored on our secure servers, encrypted at rest. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted in transit. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Certain LCX Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

8. DATA RETENTION

LCX is obligated under the Liechtenstein’s Law of 11th December 2008 on Professional Due diligence for the Prevention of Money Laundering, Organised Crime and Financing of Terrorism, no. 952.1 to retain personal data about you and your LCX transactions for a period of minimum ten years from the conclusion of the transaction or from their preparation. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 10 years after the termination of our business relationship, unless there are other legal obligations that require us to retain your information longer.

9. YOUR LEGAL RIGHTS

You have a right to:

  • Access the personal data we hold about you, or to get a copy of it,
  • Make us correct inaccurate data about you,
  • Ask us to delete your data, though for legal reasons we might not always be able to do it, due to various AML, data retention and financial reporting requirements applicable to us,
  • Object to us using your data for marketing communications,
  • Withdraw any specific consent or permission you’ve previously given us (for example, in relation to a specific promotion).

 

 

Please know that if you have any questions or objections as to how we collect and process your personal information, please contact us at .

 

  • You can add or update your personal information by login into your account profile and following the instructions. When you update information, we usually keep a copy of the previous version for our records.
  • If you don’t want to receive marketing emails or other communications from us, please adjust your account profile settings.
  • If you want to browse our websites anonymously, you may do so by logging out of your account and disabling cookies on your browser. Your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies.  

 

Our regulatory team is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information, make changes or have any questions about this privacy statement, LCXinformation practices, or data protection, you can write to us at

By writing to the above address, and subject to certain conditions set out by applicable data protection laws, you may also exercise your rights to:

      object to the processing of your information;

      ask for erasure of your information;

      ask for portability of your information;

      object to the use of your information for marketing purposes.

Request of transfer of your personal data to you. You can review and download your account information and transactional history via access to your LCX account online, however, should you require that we provide you with a copy of your account information in a more  structured, comprehensive and machine-readable format, please reach out to . We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data or account information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

If your request is clearly unfounded, repetitive or excessive we may refuse to comply with your request in these circumstances.

 

10. HOW TO CONTACT US OR RAISE A COMPLAINT

 

If you have questions about this privacy policy, including any information requests or potential complaints, you  may use the contact details set out below:

Full name of legal entity: LCX AG

registration number: FL-0002.580.678-2

Email address:  

Postal address: Herrengasse 6, 9490 Vaduz, Liechtenstein

If you are not satisfied by the way in which we address your concerns or how we handle your personal information, you have the right to lodge a complaint with the Liechtenstein’s Data protection Office at any time.

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