Privacy Policy

Let’s get to know the guidelines regarding how we collect information and data from our USERS and visitors and how we protect them. The purpose of this document is to help you make informed decisions about sharing information with us and using the platform.

By accepting this PRIVACY POLICY, the USER agrees that it may be subject to changes over time, and it is their sole responsibility to periodically check it, especially before using the SERVICES. If LUX CAPITAL, LLC informs the USER of changes to the PRIVACY POLICY, it will do so out of sheer generosity.

The concepts and expressions used in the Privacy Policy are the same as in these Terms of Use.

ACCEPTANCE

By expressing “Acceptance” to the Terms of Use, of which this Privacy Policy is an integral part, the USER expressly declares that they have read and understood all the rights and obligations specified herein, and agrees and is subject to all the provisions of this instrument.

This Privacy Policy covers the treatment given by LUX CAPITAL, LLC to information capable of identifying USERS, as well as their data when they visit and register with the Platform, providing information that will be kept by the company for a period of 5 (five) years.

Furthermore, LUX CAPITAL, LLC, in order to implement transparency and additional access controls, the rights granted to USERS will only be:

1) Right of access – the right to be informed and request access to the personal data that we process about the USER;

2) Right to rectification – the right to request that LUX CAPITAL, LLC change or update the USER’s personal data whenever they are incorrect and/or incomplete;

3) Right to deletion of information – the right to ask us to delete your personal data;

4) Right to restrictions – the right to request that we temporarily or permanently stop processing all or some of your personal data;

5) Right to object – the right to object at any time to the processing of your personal data for reasons relating to your particular situation; and the right to object to your personal data being processed for direct marketing purposes;

6) Right to data portability – the right to request a copy of your personal data in electronic format;

7) Right not to be subject to automated decisions – the right not to be subject to a decision based solely on an automated decision, including profiling, where the decision may have a legal effect on you or produce an equally significant effect.

INFORMATION COLLECTED

Our platform collects personal information from USERS:

When registering on the PLATFORM, processing the following data that may be provided by USERS: full name, birth data, country of tax domicile, email, telephone, full address (including city, state, country), identification document numbers. In the case of legal entities, all data contained in the company’s articles of association.

When filling out any contact form, all data entered by USERS will be processed.

When voluntarily sending information by email to USERS, data that is also limited to this information.

When accessing the LUX CAPITAL, LLC platform, through cookies and other technologies, URL data, the USER’s IP address, data from their visit, screens visited on the LUX CAPITAL, LLC page, interaction patterns (such as screen actions, clicks, touches) will be processed, even as a way of confirming the USER’s own choices and actions.

PURPOSE OF DATA PROCESSED

The USER agrees and authorizes the use of the data processed for the following purposes:

1)        The data found is in compliance with that described in item “1.” above – for mandatory customer analysis (KYC and AML policies) and to enable access to the services made available on the platform;

2)        The data found as described in items “1 and 2” above – for sending newsletters and information;

3)        The data found as described in item “3” above – to respond to user requests;

4)        The data found as described in items “1” and “4” above – for research and analysis, to improve our technology, to record access, improve security tools, to identify the USER and services.

I – PERSONAL DATA COLLECTED

1.1. By accessing the Platform through a computer, mobile device, tablet or any other access, the User consents to the personal data below being collected, stored, used and processed by LUX CAPITAL, LLC, under the terms of this Privacy Policy.

1.2. LUX CAPITAL, LLC may collect the IP address and information from the Access Device, namely: identifier, name and type of device, operating system, location, mobile and Wi-Fi network information and standard web log information, browser used, traffic to/from the Platform and the pages accessed within the Platform.

1.3 Additionally, information on all activities carried out on the Platform by the User will also be collected.

1.4. The User authorizes LUX CAPITAL, LLC to share the data collected and processed under the terms of this Privacy Policy with other companies that are partners of LUX CAPITAL, LLC, identity verification services, whether document, iris, fingerprints, image or voice, service providers contracted by LUX CAPITAL, LLC, financial institutions that are partners of LUX CAPITAL, LLC, potential investors of LUX CAPITAL, LLC and government authorities upon legal request. Such entities may retain the User’s personal information and data for their activities and shall be fully responsible for the safekeeping, storage and use of the data.

1.5. Except in the case of a legal request, the data protected by this Privacy Policy shall only be shared after the signing of a confidentiality agreement requiring third parties who have access to the User’s data to act with the same degree of diligence and protection as LUX CAPITAL, LLC itself.

1.6. In the event of suspension, termination of use of the Platform and its Services or termination of the Terms and Conditions of Use of the Platform, whether by the User or by LUX CAPITAL, LLC, the User is aware that his/her registration will be cancelled and his/her data may be stored and maintained by LUX CAPITAL, LLC for five years. After this period, all of the User’s data shall be permanently deleted from the LUX CAPITAL, LLC database.

II. FORM OF DATA COLLECTION AND USE OF COOKIES OR SIMILAR TOOLS

2.1. The User is aware and agrees that the aforementioned data will be collected upon completion of the registration on the LUX CAPITAL, LLC Platform, the User’s access to the Platform, the use of cookies or other similar technologies to collect data about the User.

2.2. Cookies are small text files sent to the User’s computer or other Access Device in order to allow LUX CAPITAL, LLC to personalize the experience on the Platform.

2.3. Most web browsers are configured to accept cookies. The User may, at any time, block, delete or disable the use of cookies if their browser allows it, but should be aware that this choice may interfere with the use and functionality of the Platform and its Services.

2.4. The User may encounter cookies or other similar mechanisms on third-party platforms, applications or advertisements that are not controlled by LUX CAPITAL, LLC and are not subject to this Privacy Policy.

III. USE OF COLLECTED DATA

3.1. The data collected by LUX CAPITAL, LLC may be used to:

(i) prevent and investigate potentially prohibited or illegal activities and/or violations of the Platform’s Terms and Conditions of Use;

(ii) identify possible account violations by unauthorized third parties, such as hackers and fraudsters in general, by malicious software or activity that may financially or otherwise harm Users;

(iii) provide better Service and support to the User;

(iv) process transactions and send notifications about User Transactions;

(v) resolve disputes and troubleshoot problems;

(vi) customize, measure and improve the Platform and its Services, as well as the content and layout of the platform and application, always for the benefit of the User;

(vii) provide notices of Service updates and promotional offers;

(viii) verify the User’s identity when requesting to open an account and carry out transactions through the Platform, comparing the data collected by LUX CAPITAL, LLC in all User interactions in order to verify possible attempts at unauthorized use of the User’s account; and

(ix) comply with other legal and regulatory obligations imposed on the Platform.

IV. PROTECTION AND STORAGE OF USER DATA

4.1. All data provided by the User or collected through their access to the Platform will be protected under the terms of this Privacy Policy as long as they are capable of being associated with and identified as an individual. This Privacy Policy does not apply to anonymized data, since such data does not identify the User.

4.2. The User’s account on the Platform will be protected by a personal and non-transferable password, in order to guarantee their security and privacy. The password must be chosen by the User appropriately, and it is the User’s responsibility to (i) prevent third parties from accessing their computer or other devices while using the Platform; and (ii) disconnect from the Platform when access is terminated, in addition to the prohibitions/responsibilities stipulated in the terms of use.

4.3. LUX CAPITAL, LLC will never request the User’s password to access the Platform by any means other than the Platform itself. In case of suspicion of unauthorized access by third parties to your personal account on the Platform, improper use of your access email, password, or any unrecognized activity, the User must immediately (i) request a change of your password on the Platform; and (ii) notify LUX CAPITAL, LLC, through the service channels available on the platform, so that LUX CAPITAL, LLC can take the necessary measures.

4.4. The transmission of information over the internet may not be completely secure given the possibility of unauthorized access or use, hardware or software failure, and other factors that may compromise the security of the User’s information at any time. To prevent unauthorized access to User data, LUX CAPITAL, LLC uses security solutions to monitor and prevent invasions of LUX CAPITAL, LLC’s servers. Furthermore, all communication through the Platform is encrypted and sensitive data is stored in databases protected by the most current protection technologies.

4.5. The User acknowledges being solely responsible for the transmission of his/her personal information on the Platform. LUX CAPITAL, LLC is not responsible for security breaches that occur due to the Access Device used by the User to access the Platform, as well as for damages or problems resulting from delays, interruptions or blocking of data transmissions due to fluctuations in the User’s internet connection.

4.6. The User’s data collected when accessing or using the Platform and/or contracting the Services will be stored on the servers of LUX CAPITAL, LLC.

4.7. By accessing and using the Platform and sending us their personal data, the User agrees to the transfer, storage, processing and use of their data in the format set out in this Privacy Policy.

Text updated on 04/27/2023