Privacy Policy

Privacy Policy

This Privacy Policy, together with our Terms of Service, explains how LINX Collect, use, process, disclose, share, transfer, and protect personal information obtained through LINX and its partners. As used in these Policy, “we”, “us”, “our” or “the Company” refers to LINX. This policy constitutes a part of the Terms of Service to which you have previously agreed by registering for our Service and accessing our websites. When we ask for certain personal information from users, it is because we are required by applicable laws or government orders to collect such information or it is relevant for our specified purposes.

This Privacy Policy applies to all services offered by the Company. The Company will notify you through the website announcement (or individual notice) when revising the policy of processing personal information.

Article 1 Information We Collect

 

1.　While providing our services we may collect the “Personal Information” which is defined as any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains. Namely, we may collect:

  1. Identity information: name, facial picture, social security number, ID number, documents proving your identity and any other information they may contain;
  2. Residential information: IP address, residence address, documents proving your residency and any other information they may contain;
  3.  Contact information: email address, mailing address, phone number;
  4. Security information: alias, passwords;
  5. Financial and billing information: number of bank accounts and names of banking institutions, identifiers in payment systems or other means of payment, information on your balance accounts, your trade history, incoming and outgoing wallet addresses;
  6. Cookies: to know more about cookies, please check our Cookie Policy on Article 11 below;
  7.  Your personal devices you use with us may provide some information that may potentially identify you, such as the type (including identifiers) of the device, mobile phone number, your internet service, operating system, geolocation information, browser you use, browser language, etc.;
  8. We may collect some of your behavior information, such as your visiting us, clicking on ads or other similar information. Such information may be received with additional related data (or metadata), such as the time, date, and location related to such information;
  9. Sometimes you decide to share with us some other personal information and we may collect it as well.

2. We do not collect any information that may identify you without your permission.

Article 2 Purpose of Collecting and Using Personal Information

The Company shall collect and use customers’ personal information for the following purposes:

1. Legal Obligations. We use and process certain information to comply with our legal obligations:

  1. To maintain legal and regulatory compliance: we are required by law to collect and use your personal data in connection with certain of our core service. For example, we must identify and verify users to comply with anti-money laundering and countering the financing of terrorism laws in various jurisdictions. For this purpose, we use third parties to verify your identity by comparing the personal data you provided against third-party databases and public records. If you do not provide this personal data, you will not be allowed to use our services.
  2. To ensure network and information security: we process your personal data to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable security laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our services. Without processing your personal data, we may not be able to ensure the security of our services.

2. Contractual Obligations. We use and process certain information to be able to perform our obligations under our contract with you:

  1. To provide the services: we process your personal data to provide the services to you, including to open an account and to process your transactions. We cannot provide you with services without such information.
  2. To provide communications: we send administrative or account-related information to you to keep you updated about our services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our services.
  3. To provide customer services: we process your personal data to resolve user questions or disputes, to collect fees, or to troubleshoot problems. Without processing your personal data for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the services.
  4. To ensure quality control: we process your personal data for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process personal data for quality control purposes, you may experience issues on the services such as inaccurate transaction records or other interruptions.

3. Legitimate interests. We use and process certain information based on our legitimate business interests in connection with our provision of the services to you:

  1. To enforce our terms of service and other agreements: LINX handles sensitive information, such as your identification and financial data, so it is very important for us and our customers that we actively monitor, investigate, prevent and mitigate any potentially prohibited or illegal activities or violations of our Terms of Service, and enforce our agreements with third parties, and violations of our Terms of Service or other agreements related to the services. We may use any of your personal data collected on our services for these purposes.
  2. For research and development purposes: we process your personal data to better understand the way you use and interact with the services. In addition, we use such information to customize, measure, and improve the services and the content and layout of the websites and applications, and to develop new services. Without such processing, we cannot ensure our continued enjoyment of our services.
  3.  To enhance your website experience: we process your personal data to provide a personalized experience and to implement the preferences you request. Without such processing, we may not be able to ensure your continued enjoyment of part of all of our services. 
  4. To facilitate corporate acquisitions, mergers, or transactions: we may process any information regarding your account and use of our services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You have the option of closing your account if you do not wish to have your personal data processed for such purposes. 
  5. To engage in marketing activities: based on your communication preferences, we may send you marketing communication to inform you about our events or our partner events, to deliver targeted marketing, and to provide you with promotional offers based on your communication preferences. We use information about your usage of our services and your contact information to provide marketing communications. We may also share personal data with third parties to help us with our marketing and promotional projects or sending marketing communications.

Article 3 Period for Storage of Personal Information

  1. We will retain your information until you unregister your membership and apply for withdrawal of your consent to personal information. However, if there is a record of fraudulent use or misuse by a member pursuant to the terms of the Company, the Company shall retain and destroy it for five years from the time of collection, regardless of the withdrawal of the user’s request for withdrawal or withdrawal of the consent of the user.

  2. Addresses, personal photos, copies of ID cards collected for rating uplift, documents of residence identification, and copies of ID cards collected for change of member information, and certificates of service contract of the carrier are immediately destroyed upon completion of the work.

Article 4 Automated Decision Making

We may make automated decisions on certain matters, such as to fulfill our obligations imposed by law (such as to verify your identity), to detect fraudulent or prohibited activities, or to determine whether you are eligible for certain services. If you disagree with the decision you are entitled to contest this by contacting us.

Article 5 Disclosures to Third Parties

We take care to allow your personal data to be accessed only by those who need to perform their tasks and duties, and to share your personal data only where we have consent from you or have a proper legal basis for doing so without your consent. We generally disclose your personal data in the following circumstances:

1. We may share your personal data with third party identity verification and transaction monitoring services to assist in the prevention of fraud and other illegal activities and to fulfill our obligations under anti-money laundering and countering the financing of terrorism laws and regulations. This allows LINX to confirm your identity by comparing the personal data provide us to public records and other third-party databases.

2. We may share your personal data with service providers under contract who provide professional services to us (such as legal and accounting advisors) or help with parts of our business operations (such as marketing, payment and technology services). Our contracts provide for binding enforceable requirements on our service providers in compliance with applicable laws.

3. We may share your persona data with financial institutions and payment services providers with which we partner to process payments you have authorized.

4. We may share your personal data with companies or other entities that we plan to merge with or be acquired by. If any such a combination occurs, then we will require that the new combined entity follow this Privacy Policy with respect to your personal data.

5. We may share your information with companies or other entities that purchase LINX’s assets pursuant to a court-approved sale under applicable bankruptcy laws or where we are required to share your information pursuant to applicable insolvency laws.

6. We may share your information with law enforcement, government officials or regulators, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, to comply with applicable laws and regulations, to report suspected illegal activity, or to investigate violations of our Terms of Service or any other applicable policies.

7. We may request your consent to share your information with third parties in certain other circumstances. Such requests may be presented to you in our Terms of Service, an email from us to you, or otherwise through the services.

8. We may disclose your data to third parties without your consent but only to the extent allowed by applicable laws. Also we may disclose your data to third parties without your consent in the case of amalgamation, division of company, business succession, including the provision

Article 6 International Transfers of Personal Data

 

1. As a global company, we may store and process your personal data in our facilities in various locations, including Liechtenstein. This Privacy Police applies regardless of the location in which we store and process your personal data.

2. We transfer personal data to service providers that process data in Liechtenstein for the specific purposes of performing identity verification and other screening, to enable us to prevent fraud and to comply with our know-your-customer obligations under anti-money laundering and countering the financing of terrorism laws and regulations.

3. We have provided for an adequate level of protection for your personal data including applicable technical and organizational security measures to protect your personal data. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.

 

Article 7 Entitlements to Your Personal Data

Depending on the application of different Data Privacy Laws, you may be entitled to certain rights concerning your personal data. We may refuse your request where authorized or required by applicable Data Privacy Laws. Where you are not entitled to these rights, we may at our sole discretion choose to extend them to you or choose not to fulfil your request. You can request to exercise these rights by contacting us. These rights include:

  1. Access: you are entitled to request a copy of your personal data held by us, and, depending on applicable Data Privacy Laws, a confirmation as to whether or not personal data concerning you is being processed. Where permitted or required by applicable data Privacy Laws, we may ask for further particulars relating to your request, refuse to provide some or all of the personal data and, in certain circumstances, charge a fee to cover our costs.

  2. Correction: you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected. We may refuse your request where permitted or required by applicable Data Privacy Laws.

  3. Erasure: you may be entitled to ask us to delete or remove personal data in certain circumstances. There are also certain situations where we may refuse a request for erasure, such as in cases where the personal data is required for compliance with law or in connection with pending legal claims. We may be entitled not to fulfil this request if applicable Data Privacy Laws do not provide you with such rights.

  4. Restriction: you are entitled to ask us to restrict or stop the collection, use, processing and/or disclosure of your personal data. However, we may continue to do so to the extent permitted or required by applicable Data Privacy Laws.

  5. Data Portability: you are entitled to ask us to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity if both

    1. Our lawful basis for processing the personal data was based on either your consent or where it was necessary for our performance of our obligations under our contract with you

    2. The processing was carried out by automated means.

We may be entitled not to fulfil this request if applicable Data Privacy Laws do not provide you with such rights.

  1. Objection: If we are processing your personal data on the basis of our legitimate interests or public interests, you are entitled to object to such processing. You also have the right to object to the processing your personal data for the purpose of direct marketing. We may continue to process your data if there are compelling legitimate grounds for doing so or to establish, exercise or defend any legal claims. We may be entitled not to fulfil this request if applicable Data Privacy Laws do not provide you with such rights.

  2. Automated Decisions: we use automated decision making in certain circumstances describe in Article 4 above. You may entitle not to be subject to a decision based solely on any automated decision, including profiling, where this has a legal or similar significant effect and ask for it to be reconsidered. We may continue to use automated decision making where authorized or required by applicable Data Privacy Laws. We may be entitled not to fulfil this request if applicable Data Privacy Laws do not provide you with such rights.

  3. Right to Submit a Complaint: if you believe that we have infringed your rights, we encourage you to contact us first so that we can try to resolve the issue or dispute informally. You can also submit a complaint about our processing of your personal data to the relevant data protection authority. You can submit a complaint in the country where you live or work or in the place where the alleged breach of the applicable Data Privacy Laws has taken place.

Article 8 Data Security

We use a variety of security measures to ensure the confidentiality of your personal data and to protect your personal data from loss, theft, unauthorized access, misuse, alteration or destruction.

However, we cannot guarantee that loss, theft, unauthorized access, misuse, alteration or destruction of your personal data will not occur. Please take adequate measures to protection your personal data. When registering to use our services, it is important to choose a password of sufficient length and complexity and to keep this password a secret. Please notify us immediately if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure the security or confidentiality of personal data that you transmit to use or receive from us via the internet or wireless connection, including email, phone, or SMS. If you have reason to believe that your data is no longer secure please contact us.

Article 9 Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click a third party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services.

Article 10 Children’s Personal Information

We do not knowingly request to collect Personal Data from any person under the age of 18. If a user submitting personal data is suspected of being younger than 18 years of age, we will require the user to close his or her account. We will also take steps to delete the personal data as soon as possible. Please notify us if you know of any individuals under the age of 18 using our services so we can act to prevent access to our services.

Article 11 Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to allow websites to work properly or more efficiently, as well as to provide information to the owners of the website.

There are two general categories of cookies. “First-party cookies” cookies are set directly by us. “Third-party cookies” are set by a third party, and that third party can recognize your computer both when it visits the websites and when it visits certain other websites and/or mobile apps.

Cookies can remain on your computer or mobile device for different periods of time. Some cookies are “session cookies”, which exist only while your browser is open and expire once you close your browser. Other cookies are “persistent cookies”, which survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the internet again.

We use cookies (and local storage objects, but we refer to these collectively as “cookies” in this policy), web beacons/tags, and other related approaches to collect information about your use of our website. In particular, we use the following:

  1. Strictly necessary cookies: these cookies are necessary because they enable you to move around our websites and use certain features on our service. without these cookies, some services cannot be provided. We also use these cookies to balance traffic over multiple servers, so we can keep it responsive and capable of dealing with high traffic from all users.

  2. Performance Cookies: these cookies collect information on how people use our website. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is only used to improve how our services work.

  3. Functionality Cookies: these cookies remember choices users make such as the country users visit from, languages, search parameters, etc. These can be used to provide users with an experience more appropriate to users’ selections.

  4. Advertising and Tracking Cookies: our websites may allow third party companies, including advertising companies, to place cookies on our websites. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you last saw it. This information may be used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads. These cookies are anonymous they store information about the content you are browsing, but not about who you are.

If you want to delete any cookies, please check your browser or device settings for instructions on how to delete them. Your browser or device may also offer tracking controls for things other than cookies.

Please note that by deleting our cookies or disabling future cookies, in particular the “strictly necessary” cookies describes above, you may not be able to access certain areas or features of our site.

Article 12 Revision

We reserve the right to amend this Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you. It I s your responsibility to check periodically for any updates or changes to our Privacy Policy.

 

Agenda

This Privacy Policy shall be effective November 30, 2023.