[Last revised: March 9th, 2020]
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.
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.
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.
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.
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:
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.
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.
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:
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:
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.
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: *protected email*.
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.
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.
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:
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.
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.
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.
You have a right to:
Please know that if you have any questions or objections as to how we collect and process your personal information, please contact us at *protected email*.
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 *protected email*. 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.
Full name of legal entity: LCX AG
registration number: FL-0002.580.678-2
Email address: *protected email*
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.
LCX AG is a company registered in Liechtenstein No. FL-0002.580.678-2. LCX AG is regulated by the Financial Market Authority of Liechtenstein under the registration No. 288159 as a trusted technology service provider.
LCX AG Herrengasse 69490 VaduzLiechtenstein
LCX AG © 2021. All Rights Reserved