Privacy Policy

GENERAL
This Privacy Policy, together with the Terms of Use (“Terms”), governs Leondrino Exchange’s and its licensee’s collection, processing and use of your Personal Information. As used in this Privacy Policy, “LEX,” “we,” “us,” or “ours” refer to Leondrino Exchange Inc. and its licensee for Germany, the Leondra GmbH (LEONDRA), including, without limitation, its owners, directors,
investors, employees, affiliates or other related parties. Depending upon the context, “LEX” may also refer to the services, products, website, content or other materials (collectively, “LEX Services”) provided by Leondrino Exchange Inc.

“Personal Information” refers to information that identifies an individual, such as name, address, telephone number, e-mail address, trading information, and banking details.” Personal Information” does not include anonymized and/or aggregated data that does not identify a specific user. LEX is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

  • The types of Personal Information we collect and how it may be used;
  • Our use of cookies and similar technology;
  • How and why we may disclose your Personal Information to third parties;
  • The transfer of your Personal Information within and outside of the United States (US) and the European Economic Area (“EEA”);
  • Your right to access, correct, update, and delete your Personal Information;
  • The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Information; and
  • LEX’s retention of your Personal Information.

COLLECTION AND USE OF PERSONAL INFORMATION
1. PERSONAL INFORMATION WE COLLECT
We collect the Personal Information you provide directly to us when you open a Leondrino Account, perform any transactions on the Leondrino Exchange Platform (located at the domains www.leondrino.exchange, test-www.leondrino.com, www.leondrino.eu, www.leondrino.de and including the subdomains wallet.leondrino.com, trade.leondrino.com, exchange.leondrino.com), or use other LEX Services. This may include:

  • Contact information, such as name, home address, telephone number and email address.
  • Account information, such as username and password.
  • Financial information, such as bank account numbers, bank statement, and trading information.
  • Identity verification information, such as images of your government issued ID, passport, national ID card, or driving
    license. Note: US residents may be asked to provide their social security numbers.
  • Residence verification information, such as Utility bill details or similar information.

We also automatically collect certain computer, device, and browsing information when you access the LEX website or use LEX Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

  • Computer or mobile device information, including IP address, operating system, browser type.
  • Website usage information.

2. USE OF COOKIES AND SIMILAR TECHNOLOGY
The LEX site uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends, and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our Site are most visited and difficulties our visitors may experience in accessing our Site. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receiptof, and response to, our emails and to provide you with a more personalized experience when using our Site.

We use third-party service provider(s), to assist us in better understanding the use of our Site. Our service provider(s)will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our site, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides us with aggregate reports. The information and analysis providedby our service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our service provider(s) is/are contractually restricted from using the information they receive from our Site other than to assist us.

3. HOW WE USE YOUR PERSONAL INFORMATION
We may use your Personal Information to:

  • Open your account and process your Leondrino transactions. We will process your Personal Information only for the purpose(s)
    for which it has been provided to us.
  • Verify your identity in accordance with applicable laws and regulations as well as address other law enforcement needs
    as more fully described in the General Terms and Conditions.   We also may share your information with other financial
    institutions as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal
    Revenue Service, pursuant to the Foreign Account Tax Compliance Act (“FATCA”), to the extent that this statute may be
    determined to apply to LEX
  • Personalize your LEX Services experience.
  • Analyze LEX website usage, and improve our website and website offerings.
  • Help us respond to your customer service requests and support needs.
  • Contact you about LEX Services. The email address you provide may be used to communicate information and updates related
    to your use of the LEX Services. We may also occasionally communicate company news, updates, promotions, and related information
    relating to similar products and services provided by LEX.
  • Administer a contest, promotion, survey or other site features as will be more explained on the website.

If you wish to stop receiving marketing communications from us, please contact us at
support@leondrino.com to opt-out.

DISCLOSING AND TRANSFERRING PERSONAL INFORMATION
We may disclose your Personal Information to third parties and legal and regulatory authorities, and transfer your PersonalInformation outside the US and the EEA, as described below.

1. DISCLOSURES TO THIRD PARTIES
In processing your transactions, we may share some of your Personal Information with third party service providers who help with our business operations. Your information will not be sold, exchanged, or shared with any third parties without your consent, except to provide LEX Services or as required by law. By using our Services, accepting the General Terms and Conditions and entering into the User Agreement, you consent to the disclosure of your Personal Information as described in this PrivacyPolicy.

Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. LEX’s third party service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms no less protective those described in this Privacy Policy, or those we are subject to under applicable data protection laws.

2. DISCLOSURES TO LEGAL AUTHORITIES
We may share your Personal Information with law enforcement, data protection authorities, government officials, and otherauthorities when:

  • Compelled by subpoena, court order, or other legal procedure.
  • We believe that the disclosure is necessary to prevent physical harm or financial loss.
  • Disclosure is necessary to report suspected illegal activity.
  • Disclosure is necessary to investigate violations of this Privacy Policy or our General Terms and Conditions and User Agreement.

3. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We may store and process your Personal Information in data centers around the world, wherever LEX facilities or service providers are located. As such, we may transfer your Personal Information outside of the US and the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.


EXTERNAL WEBSITES

Occasionally, the LEX website may provide references or links to other websites (“External Websites”). We do not control these External Websites third party sites or any of the content contained therein. You agree that we are in no way responsible or liable for External Websites referenced or linked from the LEX website, including, but not limited to, website content,policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by,related to, or arising from those sites.

External Websites have separate and independent privacy policies. We encourage you to review the policies, rules, terms, and regulations of each site that you visit. We seek to protect the integrity of our site and welcome any feedback about External Website information provided on the LEX website.


ACCESS RIGHTS TO PERSONAL INFORMATION

Our goal is to keep your data accurate and up-to-date.  You may update your data by logging onto to your account and clicking on the “My Data” link.  When finished making any updates or corrections to your personal data, you should click “Save” to record the changes you have made.  If you have any problems, please contact us at
support@leondrino.com.


SECURITY OF PERSONAL INFORMATION

We use a variety of security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

  • Password protected directories and databases.
  • Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet
    securely.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized LEX personnel are permitted access to your Personal Information, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.


RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as necessary to fulfill purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain Account and other Personal Information for at least seven years after an Account is closed.


CHILDREN’S PRIVACY

Unfortunately, if you are under 14, you cannot use any of the LEX Services.  So we do not knowingly solicit or collect information from anyone under 14.  If we become aware that a child under the age of 14 has provided us with personal information, we will delete it immediately.


GENERAL DATA PRIVACY REGULATION

The General Data Privacy Regulation (GDPR) requires additional information to be provided within the privacy policy. The scope of the information provided here covers the use of the LEX Website and the procedure and practices of the LEX Services as described in the Terms of Use.

1. OBLIGATORY INFORMATION REQUIREMENTS
LEONDRA supports the data privacy principles of the European GDPR. According to Art. 13 and Art. 14 GDPR you have the following
rights once your personal data is processed by LEONDRA:

  • Right of access (see Art. 15 GDPR)
  • Right to rectification (see Art. 16 GDPR)
  • Right to erasure (see Art. 17 GDPR)
  • Right to restriction of processing (see Art. 18 GDPR)
  • Right on notification (see Art. 19 GDPR)
  • Right to data portability (see Art. 20 GDPR)
  • Right to object (see Art. 21 GDPR)
  • Right to withdrawal (see Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR). The legitimacy of past data processing procedures
    remains unaffected.

With respect to personal data, LEONDRA abdicates from automated individual decision-making, including profiling, according to Art. 22 (1) and (4) GDPR. Therefore, influencing automated individual decision-making, including profiling, is not possible or rather not required.

2. RESPONSIBLE SUPERVISORY AUTHORITY
If you regard that the data privacy of your data is infringed, you have the right to lodge a complaint with a supervisory authority (see Art. 77 GDPR):
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219,
D-10969 Berlin
Tel.: +49 30 13889-0
Fax: +49 30 2155050
E-Mail: mailbox@datenschutz-berlin.de
Internet: https://www.datenschutz-berlin.de/index.html

3. RESPONSIBLE PERSON / CONTROLLER
Chief Execution Officer, Leondra GmbH
Sandra Leonie Ritter
Humboldtstrasse 3, D-12305 Berlin
Tel.: +49 30 577 026 – 880
E-Mail: slr@leondra.de
Internet: http://www.leondra.de

4. LEGITIMACY OF DATA PROCESSING PROCEDURES
The relevant data processing procedures are described in detail in the Terms Of Use, which are available to all visitors of the web pages and which have to be explicitly accepted by the user during the registration procedure. With the completion of the registration procedure, LEONDRA receives the agreement to use the provided personal information according to Art. 6 (1) lit. a, b GDPR. Furthermore, personal data is processed in the scope of legitimate interests of LEONDRA in accordance to  Art. 6 (1) lit. f GDPR to fulfill the LEX Service offering.

5. ABILITY TO EXERCISE RIGHTS
A user can cancel the registration process at any time; in particular by not accepting the Terms of Use. To a large extent, the registered user can self-administrate his account data. In particular, the user can disable notifications in the account settings. For selected data, element support procedures enable the rectification of user data. A registered user can request the deletion of the user account as detailed in the Terms of Use and within legal constraints as supported by Art. 17 (3) lit.

6. TRANSFER OF PERSONAL DATA
LEONDRA – in the scope of the LEX Website and LEX Services – does not transfer personal data to third parties abroad.

7. TECHNICAL AND ORGANIZATIONAL MEASURES
According to Art. 32 GDPR, LEONDRA takes technical and organizational measures to protect the privacy of your data. Technical measures include securing the data at transfer using secure protocols and storing data on encrypted media. For details see the above Privacy Policy statements and the Terms of Use. Organizational measures are used to protect your data within the procedures conducted by the staff maintaining and supporting the LEX Website and LEX Services, as well as infrastructure suppliers hosting the services.

8. DATA RETENTION
Personal data is retained by LEONDRA for the lifetime of an account of a registered user. Please consult the Terms of Use for details on account management for the LEX Services.


UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice, at the sole discretion of LEX. When we make changes to this Privacy Policy, we will notify all users on our website, and make the amended Privacy Policy available on our website.


CONTACT US

Please contact us with questions, comments, or concerns (including to make a complaint) regarding our Privacy Policy and/or practices at support@leondrino.com.