Privacy Policy

Last updated: October 2, 2019

Lode Association (“LODE”), a licensed private limited company formed under the laws of Liechtenstein, its direct and indirect subsidiaries and affiliates and any entities under common control or ownership with LODE (collectively, “LODE”, “we”, “us” and “our”) take data protection and security seriously. This Privacy Policy describes how we collect and process your personal data when you access content we own or operate on the website located at www.lode.one (the “Website”) or any other websites, pages, features, content or applications we own or operate (collectively, the “LODE Site”).

Please read this Privacy Policy carefully and its entirety. If you have any questions about this Privacy Policy, please contact us at info@lode.one

ACCEPTANCE OF PRIVACY POLICY

By accessing and using our Services, you signify that you have reviewed the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to alter, amend or modify this Privacy Policy from time to time, in our sole discretion. We will provide you with notice of such changes by sending an e-mail, providing notice on the homepage of the Website and/or by posting the amended Privacy Policy via our Website and
updating the “Last Updated” date at the top of this Privacy Policy. The amended Privacy Policy will be deemed effective immediately upon posting on the Website. Your continued use of the LODE Site and/or our Services constitutes your agreement to be bound by any such changes to this Privacy
Policy.

If you do not agree with this Privacy Policy or any amendment to it, you should discontinue access and use of the LODE Site and our Services.

WHAT DATA DO WE COLLECT?

When you visit the LODE Site, you may provide us with two types of information: personal information that you voluntarily disclose or that is collected on an individual basis; and information collected automatically when you use the LODE Site or our Services including, without limitation,
information that we obtain from our partners (collectively, the“Information”).

We collect and process this Information for the purpose of providing Services and information about our Services to you and/or to comply with legal requirements. You may be asked to provide personal information anytime you are in contact with us. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you choose not to share certain information with us.

We ask for your name, address, phone number and email address as a minimum as this is our primary mechanism to identify you. We may also request identity documents to help with our fraud screening and identification.

Personal Information

Personal information is data that can be used to identify you directly or indirectly, or to contact you. This Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you. Personal information means any information that is unique to you, such as your:

  • Full legal name, date of birth, age, nationality, gender, signature, utility bills, phone number, email address and home address;
  • Passport or other photo identification cards such as a driver’s license or national identification card, other photographs like selfies;
  • User ID, security questions, authentication data, transaction information, financial information, cryptocurrency or wallet addresses; and
  • Other personal information you choose to provide.

We may also obtain information about you in order to comply with our legal obligations, such as anti-money laundering laws. We may obtain from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, channel partners, joint marketing partners, and social media platforms. For example, we obtain information about you from public databases and ID verification partners for purposes of verifying your identity when you sign up for our Services. Our ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanction lists maintained by public authorities, and other relevant data. In some cases, we may process additional data about you to ensure our Services are not being used fraudulently or for other illicit activities.

By providing us with your personal information, you also consent for us to collect, hold, use and disclose your personal information in accordance with this Privacy Policy. In addition to providing the foregoing information, if you choose to correspond further with us through e-mail or any other
means of communication, we may retain, use and disclose the content of your messages together with your user ID or e-mail address and our responses.

Information that is Collected Automatically

When you use the LODE Site or our Services, we automatically collect information from your devices. We collect the following information:

  • Server Log Information: We collect server log information when you use the LODE Site, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your Internet Protocol (IP) address and time spent at the LODE Site.
  • Device Information: We collect information about the computer or mobile device you use to access the LODE Site, including the hardware model, geo location/tracking details, browser fingerprint, operating system and version, the web browser and version you use, and other device identifiers.
  • Telemetry Information: If you use any of our open source software, we may collect bandwidth download and upload speeds, the amount of free and used storage space on your device and other statistics about your device.
  • Usage Information: If you use the LODE Site, we will collect metadata about the files you upload for storage and information about the transactions you make on the LODE Site or with our Services, such as the name of recipients, your name, amounts, click-stream data, instances in which you have used any private key to authenticate communications and/or the timestamp of transactions.
  • Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information when you interact with the LODE Site, including cookies, web beacons and other unique device identifiers. Cookies are small data files that are stored on your device when you visit a website, which enable us to collect information about your device, IP address, web browsers used to access the LODE Site, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behaviour of the user visiting the website or sending the email. They are often used in combination with cookies.

HOW WILL YOUR INFORMATION BE USED

The primary purpose for collecting your Information is to provide you with the best possible user experience and Services and to safeguard the security and stability of our systems. In general, we use Information to create, develop, operate, deliver, and improve our Services, content and marketing, to comply with our legal obligations, for anti-fraud purposes and for loss prevention. We may use your Information in the following ways:

  • To provide, maintain, deliver or improve the LODE Site or our Services;
  • For quality control and staff training to ensure we can provide you with the best user experience and accurate information;
  • To monitor and analyze trends, usage and activities in connection with the LODE Site, to determine the usefulness or popularity of certain content and to better understand the online activity of users of the LODE Site;
  • To enforce the terms and conditions and other agreements we may have with you or third parties;
  • To ensure network and information security including processing your Information in order 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;
  • To provide you with the information or products or services that you have requested;
  • To provide you with customer service including, without limitation, answering your inquiry or responding to a communication from you
  • To send you technical notices, support or administrative notifications;
  • To deliver targeted marketing, promotional offers and to communicate with you about news, products, services, events and other information we think will be of interest to you;
  • To process transactions and send notices about your transactions;
  • To verify your identity by comparing your personal information against third-party databases;
  • To enhance security, prevent fraud, monitor, investigate and verify identity or service access, combat spam, malware, security risks or unauthorized or illegal activities;
  • To resolve disputes; and
  • To comply and fulfil our legal and/or regulatory requirements.

We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties.

You may choose not to have your personal information shared with third parties where we rely on consent as the lawful basis for processing your personal information. You may also choose not to allow us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization.

If you choose to limit the use of your personal information, we may not be able to continue to offer you our services.

HOW WILL YOUR INFORMATION BE SHARED

We take care to allow your personal information to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it.

We will never sell or rent your personal information. We will only share your Information in the following circumstances:We may share your information with other third parties with your consent or direction to do so that we have partnered with or perform work for us;

With third party identity verification services in order to prevent fraud. This allows us to confirm your identity by comparing the information you provide us;

With any law enforcement officials, courts or third parties where required to do so by applicable law or any court or other authority to which we are subject in any jurisdiction; or we believe in good faith that the disclosure of personal information is necessary to prevent harm or financial loss, to report suspected illegal activity or to investigate violations;

if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

In connection with offers, products or Services provided on the LODE Site;

With our current or future parent companies, affiliates, subsidiaries and with other; and

Companies under common control or ownership with us or our offices internationally.

OUR LEGAL BASIS FOR PROCESSING DATA

We collect and use the data that we have, in line with and:

  • As necessary to fulfil our Terms and Conditions;
  • Consistent with your consent, which you may revoke at any time by sending us an email, if we process for any other purpose than as set forth under this Privacy Policy.

HYPERLINKS AND THIRD-PARTY SITES

The LODE Site may contain links to other third-party websites that may collect personal information about you, including through cookies or other technologies. If you link to another website, you will leave the LODE Site and this Privacy Policy will not apply to your use of and activity on those other websites. You should consult these other websites’ privacy policies as we have no control over them and are not responsible for any information that is submitted to or collected by these third parties.

MARKETING

We require your consent to send you marketing communications (for example: email marketing, exclusive offers, etc). We would like to send you information about products and services of ours.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to other members of our company.

If you no longer wish to be contacted for marketing purposes, please email info@lode.one

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is. This is why we take every precaution necessary to maintain security of your personal information.

We store your personal information so that it helps us prevent fraud and for ease of use.

We use computer safeguards such as firewalls and data encryption in order to keep all your personal information, including payment details secure.

Please recognize that you play a vital role in protecting your own Information. When registering on the LODE Site or accessing or using our Services, you should choose a password of sufficient length and complexity, not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure or warrant the security or confidentiality of Information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS,
since we have no way of protecting that Information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at info@lode.one

RETENTION PERIOD OF YOUR DATA

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including identifying you for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. This is a case-by-case determination that depends on
things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.

TRANSFERS TO A THIRD COUNTRY AND SAFEGUARDS

While LODE is based in Liechtenstein, our service providers may store, transfer, and otherwise process your personal information in countries outside of the country of your residence. We require that the third party agree to at least the same level of privacy safeguards as required under
applicable data protection laws.

WHAT ARE YOUR DATA PROTECTION RIGHTS?

You have certain individual rights regarding the personal information that we collect and process about you through the LODE Site.

Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies (please refer to the help menu on your browser); however, switching off cookies may restrict
your use of the LODE Site.

You may also opt out of receiving promotional communications from us at any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information
about your account (if you have one).

We would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:

  • The right to access – You have the right to request us for copies of your personal data in a structured, commonly used and machine-readable format. This information will be provided without charging a fee. However, we may charge a “reasonable fee” for the administrative costs of complying with the request if it is manifestly unfounded or excessive or further copies of your data are requested.
  • The right to rectification – You have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
  • The right to erasure – You have the right to request us to erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request us to restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to us processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • The right to lodge a complaint – You have the right to lodge a complaint with the relevant supervisory authority (see Complaints section for further details).

Please note, however, that your rights are subject to exceptions or derogations. Specifically, we may need to further process and retain your Information to perform a contract with you, to protect our legitimate interests (such as the establishment, exercise or defence of legal claims) or to comply with legal requirements. To the extent permitted by law, namely to protect the rights and freedoms of others or to protect our own legitimate interests, we may therefore refuse to satisfy your request or
we may satisfy your request only restrictedly.

WILL THERE BE AUTOMATED DECISION-MAKING INCLUDING PROFILING?

We do not make decisions based solely on the automated processing of personal data. We will inform you separately in accordance with the statutory regulations of any intention to use this method in particular circumstances.

Certain business areas involve the automated processing of personal data at least to a certain extent, where the objective is to evaluate certain personal aspects in line with statutory and regulatory requirements (e.g. money laundering prevention), carry out needs analysis in relation to
products and services or for the purpose of managing risks.

CHILDREN’S PERSONAL INFORMATION

We do not knowingly collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, we will require the user to close his or her account and will not allow the user to continue to use our Services. We
will also take steps to delete the Information as soon as possible. Please notify us if you or anyone you know is under the age of 18 and are using our Services so we can take action to prevent access to our Services.

CONTACT US

With regards to this Privacy Policy, or if you have a complaint or request related to your rights and personal information, please contact us at:

Address:
LODE Association,
Bergstraße 10,
9490 Vaduz,
Principality of Liechtenstein

Email: info@lode.com

COMPLAINTS

You have the right to lodge a complaint with the relevant Liechtenstein supervisory authority. You may also lodge a complaint with another supervisory authority in an EU or EEA member state, e.g. your place of habitual residence, place of work or the place in which the alleged breach took place.

The contact details for the data protection authority in Liechtenstein are as follows:

Address:
Liechtenstein Data Protection Office,
Städtle 38,
P. O. Box 684,
9490 Vaduz,
Principality of Liechtenstein

Telephone: +423 236 60 90

E-Mail: info.dss@llv.li