LordToken

Privacy policy

Privacy policy

Your privacy is important to us and we pay special attention to its protection. This personal data protection policy (hereinafter referred to as the “privacy policy”) describes the information that we collect about you, partly or fully, via our website or one of our social media pages, as well as in general as part of your relationship with us, and how we process this data.

This privacy policy also specifies the rights that you have over your personal data. 

You can send us to any questions, comments or concerns about this policy using the contact details provided below in the paragraph “What are your rights and how can you exercise them?”.

1. Definitions

In addition to the terms defined elsewhere in this policy, the following capitalised terms shall have the meaning set out below, whether used in the singular or plural in this policy:

1.1 “Controller”: means a person who either alone or jointly or in common with other persons processes any personal data, or has control over, or authorises the processing of any personal data, but not does not include a Processor.

1.2 “Data Subject”: means a natural person, whether living or deceased.

1.3 “Personal Data”: means any information in respect of commercial transactions which is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose; is recorded with the intention that it should wholly or partly be processed by means of such equipment; or is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a Data Subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject.

1.4 “Processing”: means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the Personal Data, including the

(a) organisation, adaptation or alteration of personal data;

(b) retrieval, consultation or use of personal data;

(c) disclosure of personal data by transmission, transfer, dissemination

or otherwise making available; or

(d) alignment, combination, correction, erasure or destruction of Personal Data.

1.5 “Processor”: means, in relation to Personal Data, a person who processes data on behalf of a Controller but does not include an employee of the Controller.

1.6 “Recipient”: means a natural person or legal entity, public authority, agency or any other body to whom Personal Data is disclosed, whether a third party or not.

2. Who are we and what is our role in the Processing of Personal Data?

2.1 Lord (BVI) Ltd. (hereinafter also referred to as “Lord BVI”, “the company”, “we” or “us” in this policy) is a BVI BUSINESS COMPANY (a company limited by shares incorporated in the British Virgin Islands) with its registered office at 171 Main Street, PO Box 92, Road Town, Tortola, British Virgin Islands, VG 1110, and listed in the Registrar of Corporate Affairs of the British Virgin Islands under the BVI Company Number: 2089258 with a contact e-mail address of contact@lordtoken.com

Its main business is the development and management of all systems, software, technical solutions, websites, platforms and applications, as well as the acquisition, subscription, possession, management and sale, in any form, of all shares and transferable securities in any company or legal entity.

For more information on our company, click here.

2.2 The company operates the publicly accessible website with the following URL address (hereinafter referred to as the “Website”): www.lordtoken.com. This purpose of the Website is to:

Provide users with information on the business and services offered by the company in addition to its news (events, publications, etc.);

Offer features and/or information for users to contact the company and present the services provided by the company, its current or future projects and the team working on said projects;

Provide users with a means to create an online account and access to the digital assets trading platform and the various related services as outlined in our general conditions

Provide users with the opportunity to take part in one-off fundraising operations.

The company also manages social media pages to present its business, publish content and interact with internet users (e.g. Facebook, Instagram, Twitter, YouTube, Pinterest and LinkedIn).

When browsing and interacting on the Website, on the social media pages administered by the company or, in general during your interactions or discussions with the company, we may collect and process your Personal Data, to manage operations that we carry out and on our own behalf, as Controller, whether you are a potential or current client, prospect, contact, Internet user, candidate, supplier, service provider or partner (also referred to as “you”, “the data subject(s)” or the “user(s)” in this policy).

3. How is your Personal Data collected?

3.1 Your Personal Data is collected directly from you or indirectly from third parties.

3.1.1. In particular, your Personal Data is collected or processed in whole or in part when you browse the Website, interact with the Website, and enter your information in the data collection forms contained therein, as well as, in general, in connection with requests that you may send to the Company by any means available, with your relationship and your interactions with the company, and when you share content from the Website using the social media share buttons that may be offered on our Website, or when you browse one of the company’s pages on social media.

In summary, your Personal Data is collected directly from you in the aforementioned cases.

3.1.2. In addition, your Personal Data may also be collected from you via third parties (i.e. indirect collection from third parties).

In particular, the Personal Data that we collect and process about you may be collected or enriched by us, including for the purposes of carrying out commercial, communication, solicitation, prospecting or marketing operations, through other sources of information (social media, “public” information, websites, file rentals, etc.).

In addition, your Personal Data can also be sent to us by other members of staff / contacts within your company or via third parties in certain circumstances.

3.2 Additionally, please note that:

  • If the Processing of your Personal Data is necessary to comply with our legal or regulatory obligations, we may have no choice but to process your Personal Data;
  • If the Processing of your Personal Data is necessary for the performance of a contract with you or to carry out pre‑contractual steps at your request, the disclosure of your Personal Data is required for the fulfilment and continuation of that purpose and it is possible that the company may, if your Personal Data is not disclosed, be prevented from performing its contractual obligations or the aforementioned pre‑contractual steps;
  • In other cases, the Processing of your Personal Data is subject to your consent. In such cases, you may choose to object to the Processing (where we are the data controller) (though please understand that the refusal to permit your Personal Data to be processed for these other purposes may, however, prevent us from carrying out the Processing in question).

Special cases: if Personal Data collection forms (for example, forms on the Website or on our social media pages, or any collection form in any format that we may provide to you to collect information about you) require the input of mandatory Personal Data for the implementation of the related Processing, you will be informed of the data required to fulfil the purposes to be achieved and you will be informed of the possible consequences of the failure to provide such information (it being specified that data not indicated as mandatory will be optional). 

3.3 With the exception of specific legal obligations, or unless otherwise specified in this policy, we do not collect so called “sensitive” Personal Data, meaning Personal Data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic or biometric data for the purpose of uniquely identifying a natural person, or health data or data relating to a natural person’s sex life or sexual orientation.

3.4 Personal data of minors or protected adults: we only offer our services to adults with legal capacity. Therefore, in general, the use of the Website and the company’s dedicated social media pages are reserved for adults over 18 years of age with legal capacity. The company may under no circumstances be held liable for the use of the Website or its social media pages by minors or incapacitated persons, or for the consequences that may result therefrom, particularly in relation to the Processing of their Personal Data.

4. What data is collected, for what Processing purposes, on what basis and for how long?

4.1 In our capacity as Controller, we may process your Personal Data for the following purposes:

a. Management, processing and monitoring of information requests and interactions with the users, initiated via or through the Website or the company’s social media pages, or by any other means, and more generally of the relationship between the company and its contacts in the broadest sense: 

  • Purpose of the Processing: We process your Personal Data to ensure the processing, management and follow-up of any contact or information request made by you, by any means and in particular via the Website (including exchanges through the chatbox) or through interactions on our social media pages (including the potential management, processing, monitoring and moderation of your messages or comments), and to ensure the processing, management and follow-up of such requests and the answers provided thereto, and in general for the purposes of managing our relationship with our contacts in the broad sense.
  • Processed data: Identity (title, full name), username or handle / alias, contact details (including mailing address, telephone number or email address), position and company as applicable, contact, information or documentation request and correspondence exchanged, photograph (if you are logged into your online account and have previously uploaded a photograph of you – see below in c. of this paragraph 4).
  • Legal basis: The Processing of your Personal Data in this context is necessary to respond to your requests, provide you with the functionalities and features offered on the Website and more generally to ensure the management of its relationships and follow-ups with its contacts.
  • Data retention period: The data is stored during the period needed to reply to your request or for the management of your relationship with the company and for such period thereafter as is necessary for the purpose of managing our relationship with our contacts in the broadest sense of the term, including for purposes under the terms and conditions stipulated below in g. of this paragraph 4.

b. Management of our relationship with “participants” (namely any person taking part in one-off fundraising operations):

  • Purpose of the Processing: To manage the relationship with participants, we collect the Personal Data of such participants and/or our points of contact at these participants’ premises to manage and monitor participations in the broadest sense of the term, including the management and monitoring of participant relations, transactions / payments (including the management of unpaid amounts and litigation), and the associated accounting.
  • Processed data: Identity (title, full name, date of birth, nationality, city and country of birth, passport photograph and ID photograph, and other data contained in these documents), matrimonial regime, family status, country of residence for tax purposes, contact details (email address, mailing address, telephone number, proof of address, etc.), origin of funds (nature of funds, source of funds, amounts and data contained in supporting documents such as bank statements, notarised deeds, records of bank transactions, etc.), relevant company (certificate of incorporation, articles of association, proof of beneficial ownership) and title / occupation, participant profile (information about the fundraising project, savings capacity, personal situation (number of children, ownership status, monthly loan instalments, financial/real-estate assets of the home), former investments, etc.), the reactions in the event of capital losses, financial knowledge, etc.), terms and characteristics of the subscription (amount, paying up, etc.), data pertaining to payments and methods of payments, bank details, data related to the monitoring of the relationship, data pertaining to the traceability and timestamping (refer to logs, certificates, etc.) of the conclusion of the contract by electronic means.
  • Legal basis: With regard to the Personal Data of participants, such Processing is in principle necessary for the performance of pre-contractual steps carried out at the request of the participant or the performance of an agreement entered into with said participant. Moreover, the secondary purposes of the Processing related to the management and monitoring of participations in the broadest sense of the term (including the management and monitoring of participant relations) are necessary in ensuring proper management thereof. With regard to the Personal Data of points of contact at the participants’ premises (when participants are legal entities), the Processing is based on the need to manage and monitor our relationship with the participants in the broadest sense of the term. Finally, such Processing operations may result from legal obligations (such as the obligations to know our participants - refer to the “KYC” or “Know Your Customer/Client” questionnaire for the purposes of combating money laundering and terrorism financing , to support law enforcement, or prevent tax evasion, or the “participant profile” questionnaire to ensure suitability of the participation to be carried out with the participant’s profile).
  • Data retention period: The data is stored for the duration of our relationship, and for such period thereafter as is necessary for the purpose of managing our relationship with our contacts in the broadest sense of the term, including for purposes under the terms and conditions stipulated below in g. of this paragraph 4.

c. Management of our relationship with our clients (pre-contractual, contractual and post-contractual relationship)

  • Purpose of the Processing: To manage our pre-contractual, contractual and post-contractual relationship with our clients, we collect the Personal Data of our clients and/or our points of contact at our clients’ premises to provide, manage and monitor your online account, to manage and monitor the services provided, the entering into and performance of contracts, payments and transactions, invoicing / associated accounting, client relations in the broadest sense of the term, in particular the management and monitoring of client accounts, complaints, disputes and outstanding payments, or for carrying out and drawing up studies, analyses, reports and statistics, including for commercial use.
  • Processed Data: Identity (title, full name, identifier, date of birth), contact details (email address, mailing address, telephone number, etc.), login and password (encrypted) for your online account as well as the data associated with the connections to said account (including information collected / used as part of dual authentication) and with the operation of the account, photograph (if you choose to upload a photograph of you), nationality, proof of identity, address, origin of funds, etc., relevant company and position, information about transactions / services provided / contracts and data related to said transactions / services provided/contracts, data related to payments and methods of payment, bank details, information about the wallets (including identifier, keys, characteristics, etc.) and digital assets held within the online account, data related to the monitoring of contracts, transactions, services provided and the commercial relationship, data related to invoices. Specific characteristics connected with the use of the copy trading service: photograph, data related to the profile, nationality, investment habits and performance / productivity of traders, seniority of a trader, subscription amount required by the trader from each follower, identification of a trader’s followers, number of followers / reports for each trader, ranking of the traders by the followers, identification of the trader followed by each follower, messages and comments shared between the traders and followers on the “blog” space.
  • Legal basis: With regard to the Personal Data of clients, such Processing is in principle necessary for the performance of the pre-contractual steps taken at the request of the client or an agreement entered into with this client. In addition, the secondary purposes of this Processing related to the management and monitoring of our relationship with our clients in the broadest sense of the term (including, in particular, the management and monitoring of client accounts, claims, or the completion and development of studies, analyses, reports and statistics, etc.) are necessary to ensure proper management. With regard to the Personal Data of points of contact at our clients’ premises, the Processing is necessary to manage and monitor our relationship with our clients in the broadest sense of the term, including for the organisation and proper performance of the tasks or services entrusted to us by said clients. Finally, with regard in particular to the management of the invoicing and keeping of the associated accounting, such Processing operations may stem from the legal obligations of the company. Specific characteristics connected with the use of your photograph: the collection of your photograph is not necessary for the use of the services and this data may only be collected and placed online if you consent thereto by inserting such a photograph in your profile and accordingly, the legal basis for the Processing of the photograph is the consent of the Data Subject.
  • Data retention period: The data is stored for the duration of our relationship*, and for such period thereafter as is necessary for the purpose of managing our relationship with our contacts in the broadest sense of the term, including for purposes under the terms and conditions specified below in g. of this paragraph 4.
  • *Special case: if the user does not log into his or her online account for a period of two years, and provided that no asset is held within this account, the company shall close and delete said account and the associated Data, without prejudice to the possibility for the company to retain some or all of this Data for other purposes under the terms and conditions stipulated in this paragraph 4.
  • Other Controllers: Users are informed that, as part of the use of the services accessible via the Website, particularly services making it possible to carry out digital asset transactions, their Personal Data may be processed by third parties acting in connection with said services, for example by Binance Token Club Co., Ltd. (hereinafter referred to as Binance Cloud), Stripe, Simplex or by aggregators or entities providing solutions to manage and/or automate operations and/or transactions. These third parties are independent entities from Lord BVI, and implement their own respective Personal Data Processing operations, for which they are sole Data Controllers as Lord BVI does not have any power to determine or control how such third parties may process Personal Data. Therefore, users are advised to consult the privacy policy of these entities and other documents that may be provided by said entities regarding the Personal Data Processing that they implement (refer in particular to the paragraph “Who are the Recipients of your Personal Data? How do we share your data?”). The same applies to project holders whose projects are presented on the Website and to which the user can subscribe: in such a case, project holders may be required to know / disclose the user’s Personal Data and to process it in connection with their own Processing, for which they are liable. Therefore, the user is advised to consult the privacy policies of these project holders and other documents that may be provided by them in relation to the Personal Data Processing that they implement.
  • Important notice: Given the use of services offered via the Website, the Personal Data of users may be processed and stored within the blockchains used for the management, monitoring and processing of digital asset transactions as they are necessary for the operation of said blockchains. Therefore, the user is informed that, in any event, such Processing is not the responsibility of Lord BVI, which does not manage nor control said blockchains, and as such does not have any power of determination nor control over the Processing of Personal Data which may be implemented in connection with said blockchains.

d. Management of our relationship with our partners, including our current or potential service providers and suppliers:

  • Purpose of the Processing: In order to manage our relationship with our partners, we collect Personal Data pertaining to our current and/or potential partners, and/or the members of their staff, and/or more generally our points of contact at the premises of our partners (e.g.: members of the partner’s staff, service providers/consultants at the partner’s, etc.). The purpose of this Processing is to search for new partners, manage, monitor and reply to requests made by partners, quotations, or service proposals, as well as to manage partners and/or our relations with said partners, including in particular to manage and monitor the performance of contracts, orders / services entrusted to us, deliveries, invoices, payments and transactions, associated accounting, especially the management and monitoring of partner accounts, the partner relationship in the broadest sense of the term and any claims or prelitigation/litigation.
  • Processed Data: Identity (title, full name), contact details (email address, mailing address, telephone number, etc.), relevant company and position, information about requests for partnerships, quotations and service proposals, details of orders / services / contracts, data related to payments and methods of payment, transaction data, contract monitoring and business relationship data, invoicing data.
  • Legal basis: With respect to the Personal Data of partners who are natural persons, such Processing is in principle necessary for the performance of pre-contractual steps taken at their request or a contract entered into by them with the company. With regard to the Personal Data of points of contact at the partners’ premises, the Processing is based on the need of the company to manage and monitor its relationship with its partners, especially for the organisation and proper performance of tasks or services that are entrusted to them. In any case, the secondary purposes of this Processing associated with the search for new partners and the management and monitoring of the company’s relationships with its partners in the broadest sense of the term (including in particular the management and monitoring of partner accounts, or any claims or prelitigation/litigation, etc.) are necessary for the company to search for new partners and to monitor the proper performance of the contracts entered into with the partners. Finally, with regard to in particular the management of invoices and the keeping of the associated accounting, such Processing may stem from the company’s legal obligations.
  • Data retention period: The Data is stored for the duration of the pre-contractual (for potential partners), contractual or commercial (for current partners) relationship with the company, and for such period thereafter as is necessary for the purpose of managing our relationship with our partners in the broadest sense of the term.

e. Compliance with legal and regulatory obligations (including accounting, tax and administrative obligations) related to the performance of contracts entered into by the company, and in general the company’s business operations:

  • Purpose of the Processing: In order to comply with the various legal or regulatory obligations that may be incumbent upon us (particularly our accounting, tax, administrative obligations, obligations related to combating money laundering and the financing of terrorism (KYC and/or KYT), etc.) arising from the performance of the contracts to which we are a party and more generally our business activities, we process the Personal Data of our contacts (including but not limited to, our clients, participants, partners, etc.) for the pursuit of this purpose, as well as to monitor our accounting, financial and budgetary position (including in particular the general and analytical accounting, the representation and monitoring of asset fluctuations or the recording of our financial and fiscal position, etc.).
  • Processed data: Identity (title, full name), contact details (mailing address, telephone number, email address), photograph, nationality, data related to payments and payment methods, transaction data, data related to the monitoring of contracts and relationship with our contacts, invoice data and in general potentially all data which may be processed as identified in this paragraph 4.
  • Legal basis: Such Processing is necessary to comply with our legal or regulatory obligations (in particular financial, tax and accounting documents) and more specifically our obligations regarding anti-money laundering and combating the financing of terrorism (ID documents, photographs, proof of address, proof of “life”, etc.). Moreover, the secondary purposes of this Processing associated with the monitoring of the accounting, financial and fiscal position of the company are necessary for the pursuit of the company’s to properly manage its accounting and financial position. The company may choose to disclose Personal Data to law enforcement and fiscal authorities (whether in the BVI or not) without prior notice to you, in its absolute discretion.
  • Data retention period: The Data is stored for the duration of the accounting period or tax year in progress increased by six months or such longer period as is required by the law. The Data is stored 5 years as of the end of the business relationship or relevant transactions with regard to the obligations associated with combatting money laundering and the financing of terrorism.

f. Organisation, management and monitoring of events:

  • Purpose of the Processing: We may process your Personal Data in connection with the management and monitoring of the events we offer (organisation of interventions, management, processing and monitoring of registrations, responses to enquiries, etc.).
  • Processed data: Identity, contact details, position and relevant company, information about registrations and participation in the events.
  • Legal basis: In general, the Processing of your Personal Data in this case is necessary for the organisation and management of events, and is therefore based on the performance of a contract to which you are a party (i.e. the event registration agreement).
  • Data retention period: The Data is stored during the period necessary for the organisation and monitoring of the event and for such period thereafter as is necessary for the purpose of managing our relationship with our contacts in the broadest sense of the term, and in particular for the purposes under the terms and conditions stipulated below in g. of this paragraph 4.

g. Prospecting / soliciting by email:

  • Purpose of the Processing: We may process the Personal Data of our clients, prospects and in general contacts for the purposes of carrying out our commercial, communication, solicitation, prospecting, loyalty or marketing operations (including technical operations of segmentation, targeting, etc.) by email, especially to send them information for this purpose via this means: offer of products and services likely to be of interest to them, news about us and/or our business activities (e.g.: newsletter), other prospecting information or materials, or studies, surveys, promotions or satisfaction surveys. We may also analyse the performance of our prospecting campaigns via “tracking” information related to your actions regarding the e-mails that we send.
  • Processed data: Identity, e-mail address, data related to the actions carried out in the emails (opening, clicks, etc.).
  • Legal basis:
    • When such operations are not subject to the prior consent of data subjects, i.e. in the case where they are (i) addressed to professionals, to a professional email address and in relation with the occupation of the recipient, or (ii) intended for clients and they relate to products or services offered by us which are similar to those already provided by us to said client, then such Processing is carried out based on our need to make our products and services known on the market, and more generally to carry out prospecting and solicitation operations in the broadest sense of the term, bearing in mind that the recipient of such prospecting has the right, in any event, to object to it at any time without having to provide any reason or explanation based on the terms and conditions stipulated below in the paragraph “What are your rights and how can you exercise them?”;
    • In other cases, such Processing is based on the consent of the Data Subject, whereby the Data Subject has the right not to consent thereto or, if the Data Subject consents thereto, to subsequently withdraw said consent at any time, without having to provide any reason or explanation based on the terms and conditions stipulated below in the paragraph “What are your rights and how can you exercise them?”.
  • Data retention period: The Data is stored for such period as is necessary after the end of our relationship, or the Data Subject’s last contact with us (for example, for a client, as of a transaction or the use / performance of a service, the end of a service provision agreement or general conditions binding us or the last contact from the client and, for a prospect, as of the last contact from said prospect (online request, email or letter sent by post, telephone call, or a click in an email sent to the prospect by the company, etc.)).
     

h. Use of cookies or other similar technologies to track browsing activities, including the performance and preparation of studies, analyses, reports and statistics, management and monitoring of the proper functioning of the Website, improvement of the user experience, provision of certain services or features on the Website, monitoring and measurement the audience and the performance of the Website, display of advertisements, possibly targeted advertisements (excluding social media or social media-related features):

  • Purpose of the Processing: In connection with your use of the Website and more generally our digital media (excluding social media or social-media related features), we process your Personal Data particularly in order to monitor browsing activity, including the performance and preparation of studies, analyses, reports and statistics, to manage and monitor the proper functioning and especially the security of our Website and improve the user experience, to provide certain services or certain features on the Site (for example, in order to assure the technical provision of the chatbox or to secure our contact forms), to monitor and measure the audience and performance of the Website. Your Personal Data may also be collected and processed in order to display to you, on the Website or on third-party Websites, advertisements, potentially targeted advertisements (or behavioural or programmatic advertisements) depending on your profile, your browsing, your location (refer to geolocated advertising) and your interactions with the Websites that you visit. This Personal Data is collected via cookies or other similar technologies the use of which is subject to your consent and is therefore optional.
  • Processed data: Session, login and web browsing data, including in particular information about your browser or device and its configuration (e.g.: device fingerprinting, unique device identifier, display resolution, operating system, IP address, web browser, device type, etc.), the history and more generally Website traffic and browsing information, information pertaining to the traceability of actions on and interactions with the Website, “identifier” type information associated with your device, your hardware or operating system, or “scoring” type information (e.g.: score bot designed to ensure that the user is not a robot), information related to your browsing preferences and use of the Website or even third party websites, location data (IP address and geographical area for example), information related to the network, your language or Personal Data (age, gender, areas of interests, etc.) that is not nominative (i.e. specific to the internet user’s identifier).
  • Legal basis: When the Processing of your Personal Data either has the exclusive purpose to enable or facilitate electronic communication or is strictly necessary for the provision of an online communication service at your express request, i.e. in general if this Processing is strictly necessary for the purposes of allowing you to browse our Website and to take advantage of the features offered thereon, it is based on the need to facilitate your browsing on our Website. In other cases, such Processing is in principle subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, and as a result you have the right not to consent thereto or, if you consent thereto, to subsequently withdraw your consent at any time without having to provide any reason or explanation. For more information about the cookies, trackers and other similar technologies used by us and by our partners on our Website, and on how to configure them, consult our “cookie policy”.
  • Maximum lifetime of cookies and retention of the Personal Data collected by this means: six months from the time the cookies are deposited in your browser or device (depending on the cookie or tracker in question – with regard to this aspect, consult our “cookie policy”).

i. Use of cookies or other similar technologies to monitor browsing, including the performance and preparation of studies, analyses, reports and statistics, the provision and monitoring of social media interactivity features, the improvement of the user experience, the monitoring and measurement of the audience and the performance of the company’s social media pages, and the display of advertisements, possibly targeted advertisements (social media and social media-related features): 

  • Purpose of the Processing: In order to provide interactivity features between our Website and social media and to monitor, understand and study the use of our social media pages and interactions between our Website and social media, we may provide links to our social media pages on our Website, configure said social media pages as administrator or give you the option to use on these platforms tools created/offered by the social media sites. In this case, we process your Personal Data in particular to provide you with the aforementioned interactivity features (for example, access buttons to social media pages, etc.), as well as to improve your user experience, measure the audience and performance of our social media pages and interactions between our Website and said media, and establish browsing statistics. Your Personal Data may also be collected and processed in order to display advertisements to you on the social media pages, possibly targeted advertisements (or behavioural or programmatic advertisements) depending on your profile, browsing, location (i.e. geolocated advertising) and your interactions with our social media pages as well as our Website or with the other websites that you visit. This Personal Data is collected via cookies or other similar technologies, the use of which is subject to your consent and is therefore optional.
  • Processed data: Session, login and web browsing data, including in particular information about your browser or device and its configuration (e.g.: device fingerprinting, unique device identifier, display resolution, operating system, IP address, web browser, device type, etc.), the history and more generally traffic and browsing information regarding our Website and our social media pages, information pertaining to the traceability of actions on and interactions with the Website, or with the company’s social media pages or between the Website and social media, “identifier” type information associated with your device, your hardware, social media or your operating system, or “scoring” type information (e.g.: score bot aimed at ensuring that the user is not a robot), information related to your browsing preferences and use of the Website, the company’s social media pages or even third party websites, location data (IP address and geographical area for example), information related to the network, your language or Personal Data (age, gender, areas of interests, etc.) that is not nominative (i.e. specific to the internet user’s identifier).
  • Legal basis: Such Processing is in principle subject to your prior consent to the use of cookies and other similar technologies for the aforementioned purposes, and as a result you may choose not to consent thereto or, if you consent thereto, to subsequently withdraw your consent at any time without having to provide any reason or explanation. For more information about the cookies, trackers and other similar technologies used by us, consult our “cookie policy”.
  • Joint Data Controllers: When our setting of a social media tool has an impact on the nature of the Personal Data processed or the characteristics of this Processing, and more specifically when it can be considered that the company contributed to jointly determining the purposes and/or the means of processing of your Personal Data, we may be jointly responsible for the Processing of your Personal Data with the social network in question. In this case, the social network, which primarily determines the purpose and the methods of Processing, as well as the nature and manner of depositing cookies, has the primary responsibility for Processing and we recommend that you consult the privacy policies and the cookie policies of these third parties for detailed information about their Personal Data collection and Processing practices. The social networks in question are Instagram, Facebook, Pinterest, YouTube, Twitter and LinkedIn. Therefore, you are informed that the publishing entities of these social networks may be Data Controllers jointly with us. For more information about the way these entities process your Personal Data, please consult their respective privacy and cookie policies.
  • Maximum lifetime of cookies and retention of Personal Data collected via this method: six months from the time the cookies are deposited in your browser or device (depending on the type of cookie or tracker in question – in this respect, refer to our “cookie policy”).

j. Management by the company of requests to exercise their rights from Data Subjects in relation to the protection of Personal Data

  • Purpose of the Processing: In order to manage and reply to your requests to exercise your rights regarding the protection of Personal Data as described in the paragraph “What are your rights and how can you exercise them” of this policy (e.g.: reply to requests for exercise of their rights by Data Subjects, taking into account the consequences arising therefrom including management of objections to prospecting, etc.), we may process your Personal Data in connection with this purpose.
  • Processed data: Identity (title, full name), contact details (email address, telephone number, mailing address, etc., depending on the information disclosed by the requesting party), content of the request, correspondence and reply, and in general potentially all data which may be processed as identified in this paragraph 4, additional information or copy of an ID document but only when required (i.e. reasonable doubts as to the identity of the requesting party).
  • Legal basis: Such Processing is necessary for the company to reply to your requests to exercise your aforementioned rights.
  • Data retention period: The time required to process the request and then, if necessary, storage of the Data needed to take into account the exercise of said rights for a period of three years as from the request sent by the Data Subject to the company, it being specified that if an objection to prospecting is made, your data will be stored for this purpose within an objection list for such period as is necessary, and that when the copy of an ID document is collected in connection with a request to exercise your rights, it is:
    • Immediately deleted if it was disclosed by you even though the request does not require the sending of such an ID document;
    • Deleted as soon as the identity of the person making the request is checked whenever the situation requires such a check.

k. Management and monitoring of prelitigation and litigation

  • Purpose of the Processing: Such Processing of your Personal Data is carried out for:
  • The management and monitoring of prelitigation and litigation (including commercial litigation/litigation with clients, with partners / service providers / suppliers, with contacts in the broadest sense of the term, etc.), including in particular the preparation, exercise and monitoring of disputes and the enforcement of the decisions rendered;
  • The management and monitoring of actions aimed at the establishment, exercise or defence of a right in court (including, as applicable, the enforcement of the decisions rendered).
  • Processed data: Identity (title, full name), civil status, economic and financial information, information relating to the defendants, victims, witnesses, judicial officers appointed in the dispute / in the proceedings (full name, contact details, date of birth, etc.), history of correspondence with the company (e.g.: reminder letters, formal notices, writings and procedural documents, etc.), information on the financial situation as well as the economic and financial information related to the dispute and to the persons involved, “special” data, etc. and more generally any information if it is necessary with regard to the subject matter of the dispute, including, as applicable, data relating to criminal convictions, offences or security measures, the disputes facts at the origin of the proceedings, the information, documents and exhibits collected to establish or refute the facts that may be alleged (findings, testimony, attestation, formal notice, report, logs taken from a tool for securing computer resources, fact finding sheet, complaint, medical certificate), the characteristics and details of the prelitigation as well as the litigation (e.g.: starting and closing date of the dispute, court to which the matter is referred, date of summons, date of hearing, state of the proceedings, nature and subject matter of the claims, allegations, arguments, observations and opinions of legal representatives, date of the judgment), the date, nature, reasons, amounts and any staggered payments of the awards, comments on the description and follow-up of the proceedings, etc., and in general potentially all data which may be processed as identified in this paragraph 4 if necessary.
  • Legal basis: Such Processing of your Personal Data by the company is based on the needs of the company in order to preserve / assert its interests and rights in court, particularly in the performance of relations with its clients (current or potential), partners (current or potential), contacts, candidates, etc. Moreover, as part of this Processing, “special” Personal Data may be processed for the aforementioned purposes if it is strictly necessary for these purposes and the establishment, exercise or defence of a legal right. Similarly, data pertaining to offences, convictions or security measures may be processed in order to help us prepare and, as applicable, exercise and monitor a legal action as victim, respondent or on behalf of a victim or respondent, and to enforce the decision rendered.
  • Data retention period: The Data is stored beyond the time periods mentioned above for each of the other purposes, in the form of archives, during the limitation periods , particularly for evidence purposes (in general, five years).
    • In the case of prelitigation initiated before the end of the aforementioned periods and which requires the storage of Personal Data in order to establish, exercise or defend the rights of the company, said Data shall be stored until the amicable settlement of the dispute (including its enforcement as applicable) or, failing this, will be deleted as soon as the corresponding legal action is time-barred.
    • In the case of litigation / proceedings, especially legal proceedings, initiated before the end of the above periods and which requires the retention of Personal Data especially to establish, exercise or defend the company’s rights, this Data shall be retained for the period of said proceedings until all ordinary or extraordinary remedies against the decision rendered are no longer possible. The decisions rendered may be stored by the company until full enforcement of the decision, or as permanent archives.

4.2 It is specified that your Personal Data may however be kept longer than the aforementioned periods:

  • After obtaining your consent; or
  • In the form of archives, to comply with any legal and regulatory obligations to be met by the company or during the legal limitation periods especially for evidence purposes

4.3 Moreover, users are informed that, despite the deletion by the company of Personal Data within its own computer systems or databases, in accordance with the foregoing, some Personal Data however cannot be erased, and therefore deleted, within the blockchains used for the management, monitoring and processing of digital asset transactions, as they are essential for the operation of said blockchains. In any case, their retention / storage is not the responsibility of Lord BVI, which does not manage or control said blockchains, and therefore has no power to determine or control the Processing of Personal Data which may be implemented in connection with said blockchains, or delete the Data within said blockchains.

5. Who are the Recipients of your Personal Data? How do we share your Data?

5.1 We make sure that only persons authorised can access your Personal Data when, depending on the specific purposes, this access is necessary for the performance of their duties and/or assignments, namely the authorised personnel of the company and of the entities of the group to which the company belongs (including, in the broadest sense of the term, the staff members, employees, interns, temporary workers, internal or external consultants, etc.), especially those in charge of aspects such as marketing and communication, sales, client relations and prospects, administration, finance and legal, development, IT, projects, etc. 

5.2 External Recipients may also receive your Personal Data, namely:

  • The departments or entities in charge of the control of our company (auditors, departments or entities responsible for the internal or external control procedures, bodies authorised to carry out controls, etc.);
  • The personnel of our consultants (legal, financial, accounting, etc.);
  • The personnel of our partners, including our service providers and suppliers;
  • The personnel of our contractual or commercial partners and third-party companies, including but not limited to social media publishers, publishers of third-party websites or publishers of cookies used on our Website, for example for prospecting, communication, etc., or in the management of our digital marketing activities, for the operation of our Website in the broadest sense of the term (e.g.: provision and proper functioning of the features offered thereon, performance, security, etc.), as well as the service providers to whom the identity check services (KYC) and/or the transaction check (KYT) services are entrusted, such as Synaps and Scorechain;
  • It is also specified for reference purposes that if you post content disclosing your Personal Data on the internet, particularly on our Website or on the company’s social media pages, this content may of course be accessible to any internet user;
  • The personnel of technical or other service providers involved in activities or tasks for which access to Personal Data is strictly necessary and/or justified. This category of Recipients may also include any application, computer program or tool publisher or any payment or check service provider (including identity) which would be used in connection with our activities or to provide you with services accessible via the Website, or any provider of IT services or provider of maintenance services for applications, computer programs and/or tools that we use and in which your Personal Data may be processed;
  • Clients (including their personnel) of the company and in general the users for certain Personal Data, for example with regard to the Personal Data included in the profiles placed online by traders in connection with their participation in the copy trading service or with regard to the data of project holders placed online in connection with the services offered to said project ;
  • The personnel of social and tax bodies authorised to receive, in certain cases, the Personal Data;
  • The personnel of the bodies, judicial officers and ministerial officers, carrying out their duties including their debt recovery duties;
  • As applicable, the personnel of the organisation tasked with managing the list of persons who have objected to cold calling;
  • Judicial officers, ministerial officers and, as applicable, the personnel of the courts or authorities with jurisdiction to enable the sale or transfer of all or part of our activities or assets, or in the management and monitoring of prelitigation and/or litigation procedures;
  • Our insurers and/or insurance brokers (including their personnel).

5.3 Certain partners or third parties (including their personnel) are also Recipients of your Personal Data when you use the services accessible via the Website, namely:

  • Binance Cloud, third-party entity independent from Lord BVI, which develops, provides, maintains, updates, operates and administers the Exchange Platform (powered by Binance Cloud) – i.e. the online digital asset exchange platform - accessible from the Website, it being specified that as part of using this platform, the users of said platform (it being specified that they may be a user of the Website or third party to the Website) may be Recipients of some of your Personal Data;
  • Simplex, third-party entity independent from Lord BVI, which offers users a service accessible from the Website allowing them to carry out certain digital asset transactions;
  • Stripe, third-party entity independent from Lord BVI, acting as payment service provider, which provides a payment module on the Website that is used by traders and followers in connection with the use of the copy trading service;
  • Third parties such as aggregators or entities providing solutions for the management and/or automation of operations and/or transactions, which may for example be referenced on the Website, it being specified that said third parties are independent third parties from Lord BVI;
  • Project holders whose projects are presented on the Website and to which the user may subscribe, it being specified that said project holders are independent third parties from Lord BVI.

In this respect, it is specified that Lord BVI is not liable for the Processing of Personal Data that may be implemented by said partners and third parties (or any Recipient) as the latter carry out their own respective Personal Data Processing, for which they are respectively sole Data Controllers. Lord BVI has no power to determine or control said Processing. For information, the user is advised to consult the privacy policies of these entities and other documents that may be provided by them in relation to their Processing of Personal Data, i.e.:

5.4 Furthermore, given the nature of the services offered and/or accessible via our Website, your Personal Data may naturally be disclosed, stored, recorded within the various blockchains used for the management, monitoring and processing of digital asset transactions that you carry out, as they are required for the operation of said blockchains, it being reminded that Lord BVI does not manage or control said blockchains, and therefore has no power to determine or control the Processing of Personal Data which may be implemented in connection with said blockchains, and these Processing operations are in no way Lord BVI’s responsibility.

5.5 We may also be required to disclose your Personal Data in the event of legitimate requests from public or authorised authorities (whether in the BVI or not), including to meet requirements regarding compliance with the law on Personal Data, national security, the fight against fraud, money laundering and the financing of terrorism or more broadly, compliance with applicable legal or regulatory provisions. Your Personal Data may therefore be disclosed to any authority authorised to have access thereto, especially in case of requisition from public, police or administrative authorities. In these cases, we will examine the applicable provisions, the nature of the request, as well as its legitimacy and the proportionality of the requested information. Lastly, we reserve the right to report to the public authorities the activities that we consider in good faith to be illegal and alleged abuses. 

5.6 It is specified that the Recipients referred to above are not necessarily Recipients of all of your Personal Data but only of the data required for the purpose involving such disclosure.

5.7 It may be necessary or desirable for us to transfer your Personal Data to another jurisdiction and we reserve the right to do so, even though that jurisdiction may not provide the same degree of protection for your personal data as the BVI and may not be adequate from a data protection standpoint. If we do transfer your Personal Data to any other jurisdiction, we shall do so in accordance with BVI law.

6. What are your rights and how can you exercise them?

In accordance with the terms and conditions and the limits laid down by the legal and regulatory provisions on the protection of Personal Data, you have the following rights regarding your Data:

  • Right of access: You may obtain confirmation as to whether your Personal Data is processed by the company and, if so, you have a right to access your Personal Data as well as certain information relating to the Processing of your Personal Data and the characteristics of such Processing operations;
  • Right to rectification: You can ask for the rectification of your Personal Data to the extent you consider it to be incomplete or inaccurate;
  • Right to erasure: You may, in some cases, request the erasure of your Personal Data (except, for example, if it is required for the performance of your contractual relationship with the company, or if it is required by the company to fulfil its legal or regulatory obligations or to establish or exercise its rights);
  • Right to the restriction of Processing: You may request that the Processing of your Personal Data be restricted, for example, from marketing, allowing you to request in certain cases the marking of your Personal Data in order to restrict its future Processing;
  • Right to withdraw your consent: You may withdraw your consent if the Processing is carried out on the basis of your consent; however the withdrawal of such consent shall not infringe on the lawfulness of the Processing based on consent carried out before its withdrawal;
In addition, under certain circumstances and subject to certain conditions, you have a Right to object whereby you may object to the Processing of your Personal Data for reasons related to your specific situation, bearing in mind that in the case of prospecting or marketing purposes, including profiling operations that would be related to such prospecting, you have an absolute right to object, and this right may be exercised at any time, by writing to us, without having to provide any reason or explanation. 

In addition, under certain circumstances and subject to certain conditions, you have a Right to object whereby you may object to the Processing of your Personal Data for reasons related to your specific situation, bearing in mind that in the case of prospecting or marketing purposes, including profiling operations that would be related to such prospecting, you have an absolute right to object, and this right may be exercised at any time, by writing to us, without having to provide any reason or explanation. 

Important notice: The exercise of these rights is nevertheless limited, with regard to Personal Data that may be necessary for the operation of a blockchain (i.e.in particular to the Data retained / stored within the blockchains used for the management, monitoring and processing of digital asset transactions). Indeed, this Data required for the operation of blockchains cannot be modified or erased during the lifetime of the blockchain in question. In addition, the retention / storage of said Data in said blockchains is not the responsibility of Lord BVI, which does not manage nor control said blockchains, and therefore has no power to determine or control the Processing of Personal Data which may be implemented in connection with said blockchains, nor to pass on the exercise by Data Subjects of their rights to said blockchains.

6.2 With regard to the Processing of your Personal Data carried out by the company, these rights are exercised i) by email sent to the following address: contact@lordtoken.com or ii) by courier to the following address: Lord BVI Ltd, 171 Main Street, PO Box 92, Road Town, Tortola, British Virgin Islands, VG 1110. In any event, in case of reasonable doubt as to the identity of the person making such a request for the exercise of his or her rights, the company may always request the provision of additional information necessary to confirm the identity of the Data Subject and request, for this purpose, when the situation so requires, the photocopy of an identity document bearing the holder’s signature. In such a case, the time limits for a reply will be suspended pending the receipt of the additional information needed to identify the Data Subject. 

We will respond as promptly as possible and, in any event, within a maximum period of one month as from the receipt of any request. If necessary, we may extend this time period by two months, given the complexity and the number of requests received, in which case the requesting party will be informed thereof.

The request can be made by the Data Subject or by a person specially appointed for this purpose by the Data Subject, provided that this representative proves his or her identity and the identity of the Data Subject, the mandate as well as the duration and specific subject matter of said mandate. The mandate shall also specify if the representative can receive the reply.

6.3 Furthermore and for reference purposes, we can, in certain cases, be considered as jointly liable for the Processing of your Personal Data with the publishers of social media sites within which we have dedicated pages or with whom we offer interactions (i.e. the details of the purposes above). Depending on the social media site in question, our joint data controllers can be the publishers of Facebook, Instagram, Twitter, LinkedIn, YouTube and Pinterest. For more information about the way these entities process your Personal Data, you are advised to consult their respective privacy and cookie policies.

In these cases, in order to exercise your aforementioned rights, you can also consult your account settings on the aforementioned social media sites and contact the publishing entities based on the terms and conditions specified in their respective privacy and cookie policies.

6.4 You also have in any event the right to lodge a complaint with the competent data protection authority if you believe that the Processing of your Personal Data is not carried out in accordance with the legal and regulatory provisions on Personal Data.

7. How is your Personal Data secured?

7.1 The company implements appropriate organisational and technical security measures, in particular with regard to the categories of Personal Data processed, the state of knowledge, the implementation costs and the nature, scope, context and purposes of the Processing as well as the risks - with varying degrees of likelihood and severity - for the rights and freedom of natural persons, in order to protect your Personal Data against malicious intrusion, loss, alteration or disclosure to unauthorised third parties, and more generally to protect the security and confidentiality of such Personal Data and ensure a level of security appropriate to the risk. 

Due to the difficulties specific to carrying out business on the internet and the risks, of which you are aware, arising from the electronic transmission of data, the company cannot, however, be bound by any performance obligation.

In the event of difficulties, the company undertakes to mitigate the risks and take all appropriate measures, in accordance with its legal and regulatory obligations.

7.2 When developing, designing, selecting and using our services offered on the Website which are based on the Processing of Personal Data, the company takes into account the right to the protection of Personal Data by default and by design (refer to “Privacy by design and by default” principles).

7.3 The access to your Personal Data is limited to our employees or partners and more generally to the Recipients referred to above, who are authorised and who need to know the Data for the performance of their duties and/or tasks. 

7.4 If all or part of the Processing of Personal Data is carried out by a Data Processor, the company contractually requires its Data Processors to provide security guarantees, in particular confidentiality guarantees, with regard to Personal Data to which they may have access (appropriate technical and organisational measures for the protection of such Data).

8. What are the links from our Website to third-party websites?

8.1 Please be informed that our digital media (in particular our Website or our social media pages) may provide or include links to third-party websites, including social media sites. We do not control the activity of these websites and the policies that they apply in relation to the protection of your Personal Data and your rights, and we cannot control them. We invite you to examine the guarantees offered by these websites before any interaction with them. In this respect, we draw your attention to the fact that the privacy policy of these websites may differ from that of the company and that it is your responsibility to review said policy. 

8.2 If you post content disclosing your Personal Data on the internet, and in particular on social media sites, including social media pages of the company, such content may be accessible to any internet user, and may be collected or used by third parties, for purposes that are not our responsibility. In any case, the company shall not be held liable if the Personal Data Processing implemented via one of these third-party websites violates the applicable legal and regulatory provisions. 

9. Can changes be made to this privacy policy?

9.1 This privacy policy may be amended at any time, and such amendments shall take effect on the date of publication of the corresponding update. 

9.2 In the event of a change, the new privacy policy shall be posted on the Website. In addition, all Personal Data collection forms included on our Website will provide a link to this policy. 

9.3 We invite you to consult this privacy policy regularly.

10. What is the Website’s cookie policy?

10.1 Cookies and other trackers or similar technologies may be placed and/or read in your browser or device when you visit the Website.

10.2 Click here to consult our “cookie policy”, which is also accessible via a link in the footer of all pages of our Website.

Date of last update : 07/03/2022