Last Updated: 25/11/2024Version No: 1
This LM Apex LLC ("Company") Privacy Policy (“Privacy Policy”) strives to protect user privacy and information when using website https://locked.money/ (“System”) and services (“Services”), as they are defined in the Terms and Conditions (“Terms”). By accessing or using the System and Services, you agree to the Privacy Policy, which may get updated without prior notification.
The Company and you, as the user of the System/Services, are legally bound by the Terms that governs the contractual relationship between the Company as a service provider and the Client, as any natural person, as a Service user, or a user of System prior to/without logging-in/creating an account. This Privacy Policy might be applicable to any other contact you have with the Company, for example during recruitment process.
This Privacy Policy shall be applicable and interpreted in line with Terms. The definitions set out in the Terms shall be applicable to this Privacy Policy.
If you disagree to be bound by the Privacy Policy in any scope or way, you must not use or must immediately cease your use of the Services, System or any part of it, as well as its features and functionalities.
1.1. The Company values the trust that you place in the Company when using Services/System. For this reason, privacy and data security are extremely important to us. It is very important to us that you feel safe when you visit our System and use our Services.
1.2. As soon as you use Company's System/Services, you entrust Company with the processing of your personal data. The Company wants to offer you the best possible experience with the System to ensure that you can enjoy using Services now and in the future. That is why the Company wants to understand user behaviour on the System in order to continuously improve it. The processing of your personal data is therefore not only necessary for the provision of Services, but also to improve user-friendliness. Therefore, in this Privacy Policy you are informed which personal data Company collects from you, how the Company processes it and to whom the Company passes it on in detail. In addition, the Company informs you about the precautions it takes to protect your personal data, what rights you have in this context and who you can contact regarding data protection issues.
1.3. In the light of the above, the Company strives to protect your privacy and obliges to process your personal data in accordance with the following rules and principles:
1.3.1. Processing shall be performed lawfully, fairly, and in a transparent manner.
1.3.2. Personal data must be adequate and limited to what is necessary in relation to the purpose for which it is processed.
1.3.3. Personal data shall be accurate and, where necessary, kept up to date.
1.4. This Privacy Policy is prepared based on the international practices and principles of data protection.
1.5. For the purposes of this Privacy Policy, the terms:
1.5.1. "Controller" shall mean the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
1.5.2. "Processing" shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
1.5.3. "Processor" shall mean a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
1.6. For the purposes of this Privacy Policy, the Company is typically the data "controller" of any personal information provided to the Company. Very occasionally, the Company might act on specific retainers as a "processor" (by processing personal data only in accordance with the directions of other data controller).
2.1. Data transfers. The Company shall not transfer personal data to country or territory outside the Saint Vincent and the Grenadines unless that country ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
2.1.1. Where adequate level of protection is not ensured, an exemptions shall be made by a) creating adequate protection through appropriate safeguards (for example, by using Standart Contractual Clauses), or 2) by getting data subject's explicit consent and making sure the transfer does not conflict with the public security interests.
2.2. Data processing records. The Company shall keep data processing records upon its own decision, unless such record keeping is mandatory legal requirement.
2.3. Data breach notification. The Company strives to protect your personal data in the best way possible. However, sometimes data breaches occur and such event can happen for various reasons. In the case of a data breach that would prejudice the privacy, confidentiality and security of the personal data of a data subject, the Company, as a data controller, will immediately take action to prevent or minimize the harm, and will contact the law enforcement or other authorities as required by the applicable laws, regulations and the nature of breach.
2.4. Data retention. The Company shall not store personal data after the completion of the purpose for which such data was processed unless the identity of the data subject is no longer identifiable through the use of anonymization techniques.
2.5. Sensitive personal data protection. In general, the Company does not process any special categories of personal data from users. This includes data that reveal racial or ethnic origin, political opinions, religious or ideological convictions or trade union membership, as well as genetic and biometric data. In some cases, during verification (KYC procedure), in addition to the actual verification data (e.g. screenshots of ID documents and identification data from them, place of residence, video data, etc.), biometric data (e.g. personal data resulting from specific technical processing in connection with the physical, physiological or behavioral characteristics of a person and data for the clear identification of a person, e.g. facial images) are recorded. Such processing of biometric data takes place exclusively based on your express consent, which you can revoke at any time.
2.6. Proper agreements between controller and processor. The processor shall perform and implement the processing of personal data based on the instructions of the controller and in accordance with the contracts and agreements entered into between them, which shall specifically set out the scope, subject-matter, purpose and nature of the processing, the type of personal data, and categories of data subjects. The Company, either acting as a controller or the processor, shall make sure beforehand that such agreements are concluded and are proper for planned data processing.
3.1. The Company may collect personal information from you in the course of provision of Services, when you use the System, contact us or request information from us, or as a result of your relationship with any of our personnel. The categories of data collected also vary based on the type of user you are (Clause 3 of the Terms).
3.2. The personal information that we might process includes:
3.2.1. Contact data. when creating a new user account or communicating with the Company (for example, by contacting our support team), we may process basic details, such as your name, your contact information (such as your email address, physical address, contact numbers).
3.2.2. Verification data. if an account/other details are verified, also depending on the verification level, we may therefore process, for example: screenshots of national identity documents such as passport, driver's license, ID card and identification data from these documents, utility bill details for residence verification, data about the status of political exposed persons, video data from the video authentication procedure, biometric data for verification, reference letter, as well as information collected from publicly available resources to verify the same.
3.2.2.1. The Company always asks you to verify your identity when you are applying for Professional User status;
3.2.2.2. The Company may ask you to verify your identity when you are contacting Company and asking to provide any sensitive or personal data.
3.2.2.3. The list indicated in Clause 3.2.2. can be changed at the sole discretion of the Company.
3.2.2.4. The Company is using third party service provider Togggle for identity verification and KYC procedure. More information about tool is available here: https://www.togggle.io/, information about Toggle's privacy policy is available here: https://www.togggle.io/privacy-policy.
3.2.3. Order data. In the context of ordering Services, we might process information relating to the matter on which you are seeking our Services.
3.2.4. Financial data. In the context of ordering Services and accepting payments, as well as processing withdrawals and ensuring proper use of Services/System we might process crypto walled address and other related data, information about the payment service provider, payment details, transaction-ID, etc.
3.2.5. Log data. During activities on the System (website) and while using Services, we might process, for example: IP-address, your location, traffic data, transaction data (like deposit, payment, withdrawal address), computer or mobile device information, frequency, time, length of visit and other page interaction data, operating system, browser type, device type, unique device identification number, identification cookies, optionally form data, crash reports, performance data, third-party cookies, etc.
3.2.6. Marketing data. If you visit System or our social media sites, we might process statistical and marketing data, for example: number of visitors, frequency, clicks, time, places, target groups, data from cookies and similar technologies (pixels, ClearGIFs, etc.), consumer's behavior, interests and preferences, data on market research and target group surveys, etc.
3.2.7. Photo, video and audio data. When we attend or organize events or fairs or conduct interviews with people, or you visits to our offices or our meetings and events, we may take photos and other recordings of such events and process photo, video and audio data, as well as data on time, location, participant list, etc. However, we will always inform you separately about any such recordings by photographic or video images and/or audio recordings.
3.2.8. Hiring data. If you apply for a job on our System, social media (for example, via LinkedIn) or in other ways, we may process data that is necessary for the recruitment process, for example: contact details, curriculum vitae, qualifications, police clearance certificate, credit report, national identity documents such as passport, driver's license and the data from all of these documents, links to your portfolio or social media platforms, etc.
4.1. We process your personal data based on at least one of the legal bases mentioned below. If the Company requests the provision of other personal data not described above, this data as well as the purpose and legal basis for the collection and processing will be communicated to the Client at the point of collecting the personal data.
4.1.1. Performance of the contractual obligations. A controller (the Company) / processor may process personal data without the consent of the data subject (you) to which the data relates where processing is necessary for the performance of a contract (the Terms, Membership Agreement) to which the data subject is party or in order to take steps at the request of the data subject for entering into, amending or terminating a contract.
4.1.2. Consent. We may ask you to provide consent if your consent is relied upon as a lawful basis for the processing of your personal data. For example, we may ask you to express consent prior to using System or when you are using the System without logging-in, as well as before collecting / processing any other personal data not described in this Privacy Policy.
4.1.2.1. If you have given us your consent to the processing of your personal data, the processing will only occur for the defined purposes and to the extent agreed in the declaration of consent.
4.1.2.2. A given consent can be revoked at any time without giving reasons with effect for the future if you no longer agree to the processing.
4.1.2.3. With your consent, we process data for the following purposes, for example: direct marketing and advertising, website analysis and tracking for advertising purposes, certain uses of audio, video and photo data for marketing and other representing purposes through various channels, automated authentication process (KYC), recruitment process.
4.1.3. Compliance with legal obligations. Processing of personal data may also be necessary to abide by various legal obligations. Such legal obligations include, for example, the following data processing operations: contract management, accounting, and invoicing, monitoring to prevent fraud, misuse, money laundering and terrorist financing, providing information to criminal authorities in context of fiscal criminal proceedings or prosecution to official orders, assessing the working capacity of the employee or the provision of health/social care, etc.
4.1.4. Protection of legitimate interests. Where necessary, data processing can occur beyond the performance of the contract to ensure the legitimate interests of the Company or a third party. Such a legitimate interest includes the following data processing operations:
4.1.4.1. prevention of fraud, misuse (e.g. for illegal purposes), money laundering and terrorist financing,
4.1.4.2. risk management and risk minimization, e.g. through inquiries to credit agencies, debtor directories,
4.1.4.3. data transfer within the Company for internal administrative purposes,
4.1.4.4. account management and processing of general user requests and inquiries,
4.1.4.5. processing of inquiries from authorities, lawyers, collection agencies in the context of legal prosecution and enforcement of legal claims in the context of legal proceedings,
4.1.4.6. market research, business management and further development of services and products,
4.1.4.7. processing of statistical data, performance data and market research data via the System or social media platforms,
4.1.4.8. processing of customer preferences (e.g. language, region) via cookies on our website,
4.1.4.9. direct marketing and advertising (e.g. implementation of marketing and advertisement strategies).
4.1.5. The Company may also process personal data without the consent of the data subject to which the data relates where the data has been made public by the data subject.
6.1. You shall be entitled to the following rights:
6.1.1. Right to withdraw your consent and right to opt-out. In all cases you are entitled to object to and suspend to the processing of your personal data where the processing is performed for direct marketing purposes; and the processing is performed for statistical survey purposes. You have the right to revoke your consent any time by email to hello@locked.money or by other means available (e.g. 'unsubscribe' option in email received from the Company). Please note that if you withdraw your consent, we may no longer be able to offer you all or any Services. Withdrawing your consent does not affect the legality of the processing of your personal data based on your consent up to the point of withdrawal.
6.1.2. Right prior to the start of processing activities, to get information on the purpose of the processing, sectors or entities with whom your personal data will be shared, the appropriate safeguards used by the Company in the context of cross-border processing.
6.1.3. Right to obtain additional information upon request, including:
6.1.3.1. confirmation whether we are processing personal data related to you.
6.1.3.2. the types of personal data of the data subject being processed;
6.1.3.3. the decisions taken on the basis of automated processing;
6.1.3.4. the rules and criteria of the periods for which the personal data will be stored and kept; and
6.1.3.5. the measures to be taken upon the occurrence of a data breach.
6.1.4. Right to rectification. You are entitled to obtain the rectification of inaccurate personal data concerning you, and to have incomplete personal data completed.
6.1.5. Right to erasure. You are entitled to request the Company to delete your personal information if:
6.1.5.1. the personal data is no longer necessary in relation to the purposes for which it was collected or processed; and/or
6.1.5.2. You withdraw your consent or expressed objection to processing and there are no legitimate grounds for the Company to continue the processing.
6.1.5.3. The personal data have been illegally processed.
6.1.5.4. The deletion of personal data is necessary to fulfil a legal obligation under law to which the Company is a subject.
6.1.6. Right to receive a copy and have your personal data transmitted to another controller, if technically feasible.
6.1.7. Right to object to decisions based on automated processing. The Company usually does not use any personal data for automated decision-making including profiling. In case we would make such decision in any scope, you shall be entitled to object.
6.1.8. Additionally, you have the right to object to the processing of your personal data at any time if the processing is based on your legitimate interests.
6.1.9. Right to restriction of processing. You shall have the right to request that we restrict processing if one of the following conditions is met:
6.1.9.1. You dispute the accuracy of the personal data (the restriction applies for a period of time that enables the Company to verify the accuracy of the personal data).
6.1.9.2. The processing of your personal data was unlawful, and you refuse to delete your personal data and instead request that its use is to be restricted.
6.1.9.3. The Company no longer needs your personal data for processing purposes, but you need them to assert, exercise or defend legal claims.
6.1.9.4. You have objected to the processing of your personal data, and it has not yet been determined whether the Company's legitimate grounds outweigh your own.
6.1.10. Right to lodge a complaint. We always encourage you to contact us in case you have any questions or concerns regarding your personal data.
6.1.11. Right to contact. To exercise any of the above rights, you can send an email to hello@locked.money or a letter to Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines.
6.2. The Company uses decentralized storage solutions which offers a secure and private way to store data across a network of nodes instead of relying on a central server. This enhances your data security, but at the same time might have an impact on your rights indicated above. For example, due to the nature of decentralized solutions we might not be able to redact or delete data you have provided.
6.3. By accepting this Privacy Policy, you acknowledge understanding and agree that the Company is using decentralized solutions for your data storage and processing. This might influence your rights and limit ways to make later adjustments to the data/scope of data you have shared with Company or its affiliates.
6.4. By accepting this Privacy Policy, you acknowledge understanding and agree that the Company might not be able to fulfil all your requests (even though they are based on your rights) if it is not possible from technical side.
7.1. The Company shall only transmit your personal data to the extent described below or as part of an instruction at the time the data was collected from you. In addition, personal data that we collect about you will not be sold by us or otherwise passed on to third parties.
7.2. Within the Company, those departments or employees will receive your personal data who need it to fulfil contractual and legal obligations and legitimate interests. We transfer personal data for the purpose of our day-to-day business operations such as account management and other processes you have requested, as well as for the efficient performance of internal administrative activities in a joint manner and for the maintenance and improvement of our products and services.
7.3. To a limited extent, we also transfer personal data to processors who provide services for us such as IT services, legal services, accounting, invoicing, marketing services and sending marketing material. Processors may only use or pass on this data insofar as this is necessary to provide services for us or to comply with legal regulations. We contractually oblige these processors to guarantee the confidentiality and security of your personal data that they process on our behalf.
7.4. We may also transfer your personal data (i) if we are required to do so by law or during legal proceedings, (ii) if we believe that disclosure is necessary to avoid damage or financial loss, or (iii) in connection with an investigation into suspected or actual fraudulent or illegal activities.
7.5. If the Company acts together with other parties as joint controller (e.g. processing of data for jointly defined purposes within a group of associated entities), we may provide those parties with personal data if applicable and based on at least one of the legal bases mentioned above under Clause 4. In case of a joint controllership, we transfer your personal data only based on a sufficient agreement with our partners.
7.6. The Company may transmit your personal data to another person at the request of the person concerned with your consent for the transfer or for the purpose of fulfilling the contract or in order to take steps at the request of the data subject prior to entering into a contract.
8.1. Unless otherwise indicated in the notice / consent form, the Company shall keep your personal information only for as long as necessary to:
8.1.1. To provide you with the Services you have ordered and to ensure proper use of System;
8.1.2. To comply with laws, including mandatory data collection periods.
8.1.3. To support a claim or defence in court or to act in other judicial proceeding.
8.2. In all cases the account data shall be saved for at least 6 months from the date the accountant was terminated.
8.3. Please note that decentralized data storage solutions might have impact on the data retention periods and the Company might not have possibilities to delete or destroy data provided in relation to the Terms, this Privacy Policy or any other contact between you and the Company
9.1. If you are a resident of European Union ('EU'), please note that:
9.1.1. We are striving to ensure your rights under The European Union's General Data Protection Regulation ('GDPR'). You can find more information on GDPR and your rights here: https://gdpr.eu/.
9.1.2. You are entitled to rights under GDRP, as Article 3.2. of GDPR states that the GDPR applies to organizations that are not in the EU if two conditions are met: the organization offers goods or services to people in the EU, or the organization monitors their online behaviour. If you are using System/Services, such situation falls into the scope of mentioned Article 3.2. of GDPR.
9.2. The obligations of the Company may be limited due to the exceptions indicated in the GDPR (like number of employees in the Company).
9.3. You can contact Company's data protection team in case you have any questions or concerns related to this Privacy Police or GDPR.
9.3.1. Please contact us via email, by sending your inquiry to our data protection team at hello@locked.money.
9.3.2. Please contact us via mail, by sending us your letter to Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines.
11.1. The System (this website) is owned and operated by LM Apex LLC. We are registered in Saint Vincent and the Grenadines under license No 3524 LLC 2024, and our register office is at Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines.
11.2. You can contact us via email, by sending your inquiry to hello@locked.money, or by sending us a letter to Euro House, Richmond Hill Road, Kingstown, St. Vincent and the Grenadines.
11.3. For matters related to data protection, we urge you to use hello@locked.money.
11.4. The Company shall reply to your inquiries within 30 days (with the possibility of two 30-day extensions).
11.5. The Company reserves the right to update this Privacy Policy at any time without prior notice.
11.6. Continued use of the System and Services after such change indicates your acceptance of the revised Privacy Policy. The most recent version of the Privacy Policy will always be available on our website (System).
5. Social media and other communications
5.1. The Company maintains social media presences on various platforms (see below) in order to communicate with its active customers, potential customers and interested social media users about Company's services, products and other news. When accessing such social media platforms, the general terms and conditions and the privacy policies of these operators also apply.
5.2. The Company may only process personal data from social media users if they communicate/engage directly with the Company via such platforms (e.g. visitors number, posted articles, likes, direct messages, customer inquiries, comments, etc.). In these cases, the Company is also responsible for processing the personal data collected thereby. In addition to data processing by us, other providers, in particular operators of social networks and platforms, also process personal user data. We have no influence on this data processing and are not responsible for it - the data processing takes place exclusively in the area of responsibility of the other providers.
5.3. For a detailed explanation of the respective processing and the possibilities of objection (opt-out) by providers of social media networks, we refer to the respective privacy policies. The Company uses the following social media accounts in order to engage with you and other third parties:
5.3.1. Telegram: https://t.me/locked_money. More information about data collection by Telegram and your preferences is available here: https://telegram.org/privacy/eu.
5.3.2. X: https://x.com/locked_money. More information about data collection by X and your preferences is available here: https://x.com/en/privacy.
5.3.3. Discord: https://discord.gg/locked-money. More information about data collected by Discord and your preferences is available here: https://discord.com/privacy.
5.3.4. Linkedin: https://www.linkedin.com/company/lockedmoney. More information about data collected by LinkedIn and your preferences is available here: https://www.linkedin.com/legal/privacy-policy.
5.4. The above indicated list is non-finite, and the Company is entitled to change/add social media accounts.
5.5. You should always make sure that the social media account is Company's before submitting or revealing any personal information of yours while engaging in any social media communication (for example, exchanging messages or leaving a comment).