FORWARD


Welcome to LXDX, a digital asset trading platform owned and operated by LXDX Ltd, a Malta company. At LXDX, we understand that security and confidentiality of the personal information (“Personal Information”) that you share with us is paramount. LXDX Ltd and its affiliates (“LXDX”) are committed to protecting the privacy of Personal Information, including Personal Information of customers, employees, agents, job applicants or others inside or outside of LXDX.


By visiting, accessing, or using LXDX, you consent to the policies and practices of our privacy policy (the “Privacy Policy”) so please read them carefully and consider their implications. If any policy of practice of this Privacy Policy is unacceptable to you or non-compliant with your local regulations, please do not visit, access or use LXDX.


All uses of “we”, “our”, or “us” in the Privacy Policy refer to LXDX Ltd., registered with the Registrar of Companies of Malta under the Companies Act of the Republic of Malta under the number C 87672, with its registered address at Orange Point Building, Second Floor, Dun Karm Street, Birkirkara By-Pass, Birkirkara, BKR 9037, Malta.


The Privacy Policy, along with our Terms of Use, govern LXDX’s collection, processing and use of your Personal Information. Applicable “Data Protection Law” means data protection law applicable to LXDX, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts. “Personal Information” has the appropriate meaning as set forth in Data Protection Law.


PURPOSE

The purpose of this Privacy Policy is simple: it defines what Personal Information we collect, why we collect it, and how we treat it.


DEFINITIONS


Cookies

Tiny data files called cookies, flash cookies, pixel tags, or other tracking tools placed on client device or computer upon visit to LXDX.


Identifiable Natural Person

An “Identifiable Natural Person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.


Personal Information

“Personal Information” means any information relating to an Identifiable Natural Person.


GENERAL


By visiting, accessing or using LXDX, you affirm that you are at least 18 years old and have the legal capacity to consent to this Privacy Policy. You agree to be bound by the policies and practices in entirety of this Privacy Policy.


We have developed specific policies and procedures designed to protect the privacy of your Personal Information.


This Privacy Policy explains what Personal Information (as defined below) we collect, why we collect it, and how we treat it.


LXDX reserves the right to make changes to this Privacy Policy, however the latest version of this Privacy Policy will always available here on this page. Visiting, accessing, or using LXDX following any change to this Privacy Policy is considered to be an acceptance of any such changes.


COLLECTED PERSONAL INFORMATION 


We collect Personal Information you provide directly to us or which we generate when you visit, access or use LXDX. Included in this collection is:

  1. Identifying Information (collected, verified and authenticated)
    1. Full legal name
    2. Home address
    3. Email address
    4. Phone number
    5. National ID number
    6. Date of Birth
    7. Proof of Identity
      1. Images of government-issued ID, national ID, passport, or driving license
      2. Images of utility bills, phone bills, or similar information
  2. Financial Information including trading records, bank statements, and bank account numbers
  3. Account Information including usernames, passwords, and account preferences
  4. Usage Information including the way in which the LXDX platform is used and which features of LXDX are used
  5. Correspondence Information including support tickets, emails, phone records or similar information
  6. Device Information including certain browsing, computer, and device information when you access the LXDX website or use LXDX services. Information includes:
    1. Computer or mobile device information
    2. IP addresses
    3. Operating System
    4. Networking Information
    5. Browser Type and Settings
  1. Location Information including probably geographical location
  2. Third Party Personal Information including Personal Information from third party partners and public sources including:
    1. Reputation Information
    2. Financial Information
    3. Business activities of corporate users


Additionally, we need to collect certain information for compliance with legal requirements relating to our know your customer, anti-fraud, anti-money laundering, prevention of terror financing obligations.


Your Personal Information may be processed if necessary on reasonable request of relevant law enforcement or regulatory authority, body, or agency or in the defense of legal claims.

Personal Information will not be deleted if relevant to an investigation or legal claim. Such Personal Information will be stored until said issues are resolved.


LXDS performs no behavioral tracking or analysis of user behavior across our website or external websites and, to the fullest extent possible, LXDX strives to prohibit third-party data collection through LXDX save as expressly set out in this Privacy Policy.


Personal Information created upon account creation will be retained for the mandatory retention period set forth by applicable law and as necessary for us to maintain complete records of all our operations as required from relevant financial sector regulations.


COOKIES


LXDX makes use of the standard practice of placing Cookies on user devices or computers for the purpose of recognizing customers and collecting information concerning the customer’s use of LXDX. The purpose of this information collection is to better customize services and content for you, to collect information about your device or computer to ensure compliance with relevant compliance practices, and to improve account security by detecting irregular or suspicious account activities.


Upon logging into LXDX, you will be offered the opportunity to accept or reject Cookies. If you reject cookies, many features of LXDX will be unavailable. If you do not consent to the placing of Cookies on your device or computer, please do not vitis, access, or use LXDX.


USE OF PERSONAL INFORMATION


Personal Information is collected in an effort to provide users with the best experience possible, protect the user and the community from both improper use and fraud, and to help us maintain and improve LXDX.


Much of the information we collect is required by law due to our compliance obligations or in the public interest such as making sure we verify our customers' identities.

We do not ever sell your Personal Information to third parties for the purposes of marketing, ever.


We may use your Personal Information to:

  1. Verify your identity in accordance with relevant know-your customer, anti money laundering and other financial sector regulations including as required by:
    1. LXDX’s KYC and AML Policy
    2. Law enforcement needs as described in our Terms of Use
    3. Compliance with relevant legislation and regulations applicable to LXDX
  1. Enable your use of our services, including customer support for LXDX
  2. Improve and optimize our services for other customers or you specifically
  3. Generate reporting data about our services
  4. Monitor the usage of our services for both performance and security audits

If it becomes necessary to make modifications regarding the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.


ACCURACY OF PERSONAL INFORMATION


We take reasonable and practicable steps to ensure that Personal Information held by us is accurate with regard to the purposes for which it is to be used.


RETENTION OF PERSONAL INFORMATION


We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy.


The primary criteria applicable for determining the period of retention are:

  1. Age of account
  2. Legal or contractual requirements that require data being kept for a certain duration
  3. Ongoing legal or financial claim that relates to the data

In accordance with our record keeping obligations, we will retain Account, Order, Trading, and other Personal Data for at least seven years (up to 10 years as required by applicable law) after an Account is closed.


AUTOMATED DECISION MAKING


We may make automated decisions on certain matters, particularly related to risk profiling as to whether we are able to provide products or services to you. If you disagree with the decision, you are entitled to contest this by contacting us at adm@lxdx.co.


MARKETING


We may send direct marketing materials promoting products, services, or activities to you using information collected from you. We shall only do this when you have given us your consent or otherwise where we are permitted to do so under Data Protection Law in pursuit of our legitimate interests (that is, promoting our services).


You may opt out of receiving promotional and marketing messages.


Even if opting out of receiving promotional and marketing messages, LXDX may still contact you regarding our business relationship with you, such as account status and activity updates, response to inquiries or complaints and similar communications.


DISCLOSING AND TRANSFERRING PERSONAL DATA


We may disclose your Personal Information to legal and regulatory authorities, other third parties, and transfer your Personal Information outside the EEA, as described below.


We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities when:

  1. Compelled by court order, or other legal procedure.
  2. Required to report suspected illegal activity.
  3. Required to investigate violations of this Privacy Policy or our Terms of Use.

Personal Information is primarily stored in data centers in Frankfurt, Malta, and Singapore; however, fragments of Personal Information may temporary exist in data centers around the world where service providers are located. As such, your Personal Information may be transferred outside of the European Union.


It is possible that some of the countries to which your Personal Information is transferred do not benefit from an adequacy decision issued by the EU Commision regarding necessary protections to be afforded to personal data. Such transfers are undertaken in accordance with our regulatory obligations and appropriate safeguards under Data Protection Law will be implemented.


We may additionally share your Personal Information with third parties when:

  1. Required in accordance of our legal, regulatory or compliance practices.
  2. Required in defense of a legal claim relating to your information.
  3. Required in discussion of a sale or transfer of all or part of the business.
  4. The third party acts as a contractor or service provider. Common use cases include searches of anti-fraud databases, authentication of photos and IDs, and various other suitability screenings.

YOUR RIGHTS


You have rights relating to the access, correction, deletion, restriction, transfer, and automated decisions concerning your Personal Information.


Access: You are entitled to request if we have possess your information and, if we do, you have the right to request access to your Personal Information. Due to the large volumes of data, in accordance with Data Protection Law, you may specify the specific information or processes activities to which your request relates.

Correction: You are entitled to correct any of your data that is inaccurate.

Deletion: You are entitled to request removal of your personal information in certain circumstances. We may be unable to comply if such information is necessary for compliance with law or regulatory requirements.

Restriction: You are entitled to request the suspension of the processing of data about you.

Transfer: You are entitled to request the transfer of your Personal Information to another party.

Automated Decisions: You are entitled to contest any automated decision made about you where such decision has a legal or similar significant impact.


INFORMATION SECURITY


Security is never foolproof; users accessing our systems over the internet are exposed to insecurities outside of LXDX’s control. Security is of utmost concern at LXDX and we take the following measures to ensure the confidentiality of your Personal Information, and to protect your Personal Information from unauthorized access, misuse, theft, loss, alteration or destruction.


Measure include encryption of the LXDX website communications with SSL, password protected databases, required two-factor authentication for all user and administrative sessions, periodic reviews of our security policies as they pertain to collection, storage and processing of your Personal Information, and heavily restricted access to your Personal Information to our employees and contracts who are all subject to strict confidentiality obligations and receive mandatory training to satisfy these obligations.


Our security measures our reviewed regularly in light of emerging technical and regulatory developments.


We will never ask via email or text for any financial information, such as your credit card number, passcode, account number or pin number.


Please always verify that any website on which you are asked for financial information in relation to our services is truly operated by LXDX. Do not ever provide your information to a suspicious request and report such request to on one of our service representatives.


Your passcode is your responsibility. Keep it safe and do not share it with anyone. Notify us as soon as possible if you suspect unauthorized use or any other breach of security involving your information.