LIMITLEX PRIVACY POLICY

Last updated: 01 June 2018

This Privacy Policy explains how Limitlex Holding Ltd., a limited liability company organized and existing under the laws of England and Wales, with registered seat at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ, registration number 11206613 ("Limitlex" "we" or "us"), collects, uses, discloses and protects your personal information. This Privacy Policy explains which information we collect, how we use, process and protect your information and what options our users and participants have with regards to their personal information. Personal information is any information relating to natural person by which the natural person can be identified, directly or indirectly, in particular a name, an identification number, location data, an online identifier or different identities of that natural person.

This policy applies to information we collect when you access or use Limitlex Website, Limitlex Project, Limitlex Platform or any related services and products (collectively, "Limitlex Services") or otherwise interact with us as described below. We are compliant with applicable laws in the countries in which we operate. By using the Limitlex Services or interacting with us as described below, you confirm that you are aware of this Privacy Policy and that you agree with the collection, use and processing of your personal information in accordance with this Privacy Policy.

We may amend this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and by providing an additional notice, including, for example, by adding a statement to the homepage of the Limitlex Services or by sending you an email notification. We strongly encourage you to review the Privacy Policy whenever you are made aware of its changes to stay informed about our information practices and your privacy rights and choices.

1.     INFORMATION THAT WE COLLECT ABOUT YOU

We collect information you provide directly to us. For example, we collect information about you when you are filling in forms on the Website or by corresponding with us by phone, e-mail or otherwise. It also includes information you provide, when you register to use the Website, subscribe to our newsletter, submit a Know Your Customer (“KYC”) or other form, complete a transaction, enter a competition, participate in discussion boards or other social media functions on our site, participate in the ICO (as defined in the General term and conditions), when you report a problem with the Website or otherwise communicate with us.

The types of information, which is used for identification purposes and which we may be required to collect from you, are as follows:

·       First and last name for individuals or first and last name for representatives of legal entities;

·       Permanent and temporary residence address for individuals or registered office and business address for legal entities;

·       Contact information, such as your e-mail address and telephone number;

·       Date and place of birth;

·       Citizenship for individuals or country of registration for legal entities;

·       Identification number for individuals or registration number for legal entities;

·       Tax number;

·       Your photograph;

·       Copy of your identification document;

·       Copy of your utility bill or similar document as proof of your residency;

·       Your ETH, BTC or LTC address;

·       Your IBAN address, if you wish to contribute in FIAT;

·       Account information such as username and account preferences;

·       Any information that are required for the tax purposes namely your VAT identification number.

ETH, BTC or LTC address does not in itself allow us to identify an individual person and would as such in certain jurisdictions not be considered personal information. In such jurisdictions, if we do combine your ETH, BTC or LTC address with personal information, the combined information will be treated as personal information for as long as it remains combined.

We may also obtain information about you from third parties, such as identity verification services. We may also ask you for additional government-issued identification or other information to validate your identity as required by our policies and procedures. This is personal information that is collected on an individual basis and you disclose voluntarily.

Information we collect about you

When you access or use the Limitlex Services, we automatically collect information as follows:

·       Transaction information: we collect information about the LMX Token Private Pre-ICO event, Public Presale and Public Crowdsale transaction you complete via the Limitlex Services, including the amount of funds and LMX tokens associated with LMX Token Private Pre-ICO event, Public Presale and Public Crowdsale.

·       Device information: we collect information about the computer or mobile device you use to access the Limitlex Services, including device identifiers, mobile network information, type of operating system, type of hardware used and the type of browser used.

·       Server Log Information: We collect server log information when you use the Limitlex Services, which may include but is not limited to the date and time of visits, the pages viewed, your IP address, time zone setting, time spent at Limitlex website and the websites you visit just before and just after you visit our website, clickstream to, through and from our site (including date and time), information you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).

Information we receive from other sources.

·       Cookies and similar tracking technologies: we may use cookies, pixel tags, web beacons, and other tracking technologies to collect information about you when you interact with the Limitlex Services, including information about your browsing behaviour on our Limitlex Services.

What are cookies? Cookies are small text files that are placed on your computer by websites you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. They are typically stored on your computer’s hard drive. We use both session and persistent cookies. Session cookies expire when you log out of your account or close your browser. Persistent cookies remain on your computer or mobile device until you erase them or they otherwise expire. Most web browsers are set to accept cookies by default. You are free to decline most of our cookies if your browser or browser add-on permits, but choosing to remove or disable our cookies may interfere with your use and functionality of the Limitlex Services. Additionally, we may use certain persistent cookies that are not affected by your browser settings, but will use such cookies solely for identity verification and fraud prevention purposes. You may refuse cookies by turning them off in your browser, however, you should be aware that our website, like most other popular websites, may not work well with cookies disabled. For more information about cookies and how to block, delete or disable them, please refer to your browser instructions, or contact us at [email protected].

·       We may use third-party analytics companies (such as Google Analytics) and identity verification services. The information collected by these third parties may be used for purposes disclosed in their privacy policies, and by us to offer our services and comply with legal and regulatory requirements.

2.     USE OF INFORMATION

We may use your information as follows:

·       Provide the Limitlex Services and customer support;

·       Process and send notices about your LMX Token Private Pre-ICO event, Public Presale and Public Crowdsale transactions;

·       Manage your account(s) and send technical notices, updates, security alerts and support and administrative messages;

·       Resolve disputes, troubleshoot problems and help us respond to your customer service requests and support needs;

·       Prevent potentially prohibited or illegal activities and enforce our user agreements;

·       Personalize, measure and improve the Limitlex Services;

·       Deliver marketing and promotional offers on behalf of Limitlex and others via e-mail;

·       Carry out prize competitions we might organise;

·       To help understand your needs and provide you with better service; and

·       Carry out any other purpose for which the information was collected, to the extent such purpose is necessarily contemplated by the provision of Limitlex Services or as otherwise notified in the Limitlex Services at the time of collection.

You may opt out of receiving promotional communications from us by following the instructions in those communications. You may also opt out of receiving our newsletter or certain administrative emails. If you opt out of receiving promotional communications, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

3.     PROCESSING OF INFORMATION

By accessing or using the Limitlex Services or otherwise providing information to us, you consent to the collecting and processing of information as described in this Privacy Policy.

We retain personal information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. In accordance with our record keeping obligations, we will retain account and personal information for at least 5 years after an account is closed.

4.     DISCLOSURE OF INFORMATION

We take your privacy very seriously and we will disclose it to third parties only if it is absolutely necessary to do so, if they are trusted and/or under a non-disclosure agreement with us, or if you expressively allow us to do so.

We will only use and disclose your personal information internally in order to:

·       Understand and meet your needs and preferences;

·       Develop new and enhance existing service and product offerings;

·       Manage and develop our business and operations;

·       Carry out any purposes for which we have received your consent; and

·       Meet legal and regulatory requirements.

We may disclose any information we collect about you, whether you are a current or former customer, with law enforcement, data protection authorities, government officials, and other authorities, when:

·       Compelled by subpoena, court order or other legal procedure;

·       We believe the disclosure is necessary to prevent physical harm or financial loss;

·       Disclosure is necessary to report suspected illegal activity;

·       Disclosure is necessary to investigate violations of this Privacy Policy or our Terms of Use.

·       We obtain your consent or at your direction.

Other than in connection with a merger, sale of Limitlex's assets, financing or acquisition, we will not sell or rent any of your information to third parties for their own marketing purposes.

5.     SECURITY

We are committed to protecting the personal information we collect when you use Limitlex Website, Limitlex Project, Limitlex Platform or any related services and products. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We also authorize access to personal information only for those employees, who require it to fulfil their job responsibilities. We take reasonable steps to protect the security of the information communicated through Limitlex Website. However, no computer security system is entirely fool proof and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the data you submit to or receive from us through the Internet or for any unauthorized access or use of that information and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received or that it will not be altered before or after its transmission to us. You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns (collectively, “Limitlex Parties”) liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided through Limitlex Website.

6.     EMAIL MAILING LISTS

We operate an email mailing list program, used to inform subscribers about products, services and / or news we supply / publish. You can subscribe through an online automated process, where you have given your explicit permission. Your personal details are collected, processed, managed and stored in accordance with the regulations listed above. You can unsubscribe at any time through an automated online service, or if not available, other means as detailed in the footer of sent marketing messages. The type and content of marketing messages you receive, and if they may contain third party content, is clearly outlined at the point of subscription.

Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies for tracking your activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic data, demographics and already stored personal data.

7.     SOCIAL MEDIA

There may be instances, where Limitlex Website features social sharing buttons, which help share web content directly from web pages to respective social media platforms, links to social media and other integrated tools. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about social media privacy and usage policies on their own websites.

While we may have official profiles on social media platforms, you are advised to verify authenticity of such profiles before engaging with or sharing information with such profiles. We will never ask for your passwords or personal details on social media platforms. You are advised to conduct yourself appropriately when engaging with us on social media.

8.     EXTERNAL WEBSITE LINKS

Although we only look to include quality, safe and relevant external links, you are advised to adopt a policy of caution before clicking any external web links, mentioned throughout Limitlex Website (external links are clickable text / banner / image links to other websites). We cannot guarantee or verify the contents of any externally linked website despite our best efforts. You should therefore note, that you click on external links at your own risk and that we cannot be held liable for any damages or implications caused by visiting any external links mentioned. If you follow a link to another website, you will leave Limitlex Website and this Privacy Policy will not apply to your use of and activity on those other websites.

9.     ACCOUNT INFORMATION AND ACCESS TO INFORMATION

You may access and review or update your online account information at any time by logging into your account. If you want to close your account, please contact us at [email protected]. However, please note that if you close your account, we may retain your information as required by law or for our legitimate business purposes, such as to collect fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or enforce our user agreements.

You have a right to access the information we hold about you. We may ask you to pay a fee before providing you with this information.

10. CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected]