Privacy Policy

Introduction

LondonLink LT UAB (“LondonLink” or the “Company”, also referred to as “we”, “us” or “our” in this Privacy Policy) respects customers’ privacy and is committed to protecting your personal data. This Privacy Policy sets out how the Company looks after your personal data when you visit our website or otherwise use our services. It also informs you about your privacy rights and how the law protects you.

This Privacy Policy is provided in an easy-to-read, sectioned format. Each section covers a specific area, each of which is listed below. Please also use the Glossary to understand the meaning of some of the less common terms used in this Policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how the Company collects and processes your personal data through your use of its services and/or its website www.londonlink.io. 

This website is not intended for anyone under 18 years of age and we do not knowingly collect any data relating to anyone under that age.

It is important that you read this Privacy Policy together with any other policies or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements any other policies or notices and is not intended to override them.

Controller

The Company is a data “controller” for the purposes of the General Data Protection Regulation (“GDPR”), and is responsible for determining the purposes and means of processing your personal data.

Contact

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact our Data Privacy Team by email at datarequest@londonlink.io.

You have the right to make a complaint at any time to: (1) the supervisory authority for data protection in Lithuania, which is where we are registered, or (2) if your habitual residence, your place of work or the place of the alleged infringement of the GDPR is in another EU member state, the supervisory authority for data protection in that state. The supervisory authority in Lithuania is the State Data Protection Inspectorate, whose address is: L. Sapiegos str. 17, 10312 Vilnius, Lithuania, whose e-mail address is: ada@ada.lt, and whose website is: https://vdai.lrv.lt/. We would appreciate the opportunity to consider and seek to resolve any complaint you may have before you approach the relevant supervisory authority so please contact us in the first instance.

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated on 17 September 2024.    

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes scans or photos of ID documentation, first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account, blockchain and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including wallet addresses. This definition also includes any screenshots/photos provided to us for transaction verification purposes.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your online usernames/aliases, purchases or orders made by you, your interests, preferences and feedback.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and third parties and your communication preferences.
• Compliance-related Data includes information provided or obtained when performing your due diligence due to applicable legal requirements (e.g., AML/CFT regulations), such as Politically Exposed Person (“PEP”) status, residential address, geo data, results of sanction screening, results of adverse media screening, sources of wealth information.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific service. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We may collect Special Categories of Personal Data and information about criminal convictions and offences about you in order and to the extent required to comply with applicable legal requirements (e.g., AML/CFT regulations) as discussed above.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract/provide the service we have or are trying to enter into with, or provide for, you. In this case, we may have to cancel a product or service you have with us. We will notify you if this is the case at the time.

3. How your personal data is collected

We use different methods to collect data from and about you, including through:

• Direct interactions. You may give us your Identity, Contact, Compliance-related and Financial Data by responding to our requests to do so for verification and/or operational reasons by corresponding with us through electronic means including (but not limited to) email, WhatsApp and other instant messaging applications in addition to by post, over the phone, in person or other direct interactions. This includes (but is not limited to) personal data you provide when you:
  • onboard with us;
  • create an account or upload documentation on our website;
  • open a trade or otherwise request our services (by conduct, in writing or verbally), including when using a third-party platform (such as online peer-to-peer trading websites);
  • subscribe to our publications or request marketing material to be sent to you;
  • engage us or open dialogue about how our services could benefit you; or
  • provide us with feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, IP address information and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For further information, please see our Cookie Policy.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including, but not limited to:
  • Technical Data from analytics providers such as Google;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  • Identity, Compliance-related Data and Contact Data from publicly available sources; and
  • Compliance-related Data from providers of blockchain analysis, watchlist screening providers and other proprietary data sets.

4. How we use your personal data

We will only use your personal data when the law permits us to do so. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;    
• when it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and    
• when we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, as/where appropriate.

Note that we may use your personal data for more than one lawful ground depending on the specific purpose for doing so. Please contact us if you require details about the specific legal ground that we are relying on to use your personal data, where more than one ground has been set out in the table below.

Promotional offers and marketing from us (not third parties)

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We will use the abovementioned information for this purpose only (a) for marketing our own similar goods or services, provided that you are given a clear, free and easily executable option to disagree or opt out of such use of contact information for the aforementioned purposes when these details are collected and if you initially did not object to such use of the data with each message sent; or (b) with your explicit prior consent.

You may receive marketing communications from us if you have requested information from us or received services from us or if you provided us with your details when you entered a competition or registered for a promotion.

Change of use of your data for marketing purposes

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have consented to receive marketing communications and would like to request a change to how we use your data for marketing purposes, please make a request by email to unsubscribe@londonlink.io

Opting out of our marketing messages

You can also ask us to stop sending you marketing messages at any time in writing. Where you opt out of receiving these marketing messages, this will not apply to personal data processed by us for different purposes.

If you would like to opt out of marketing, please email us at unsubscribe@londonlink.io.    

Third-party marketing

We will always request your express opt-in consent before we share your personal data outside the Company for third-party marketing purposes.

Opting out of third-party marketing

If you opt-in to third-party marketing, you will need to contact that third party directly if you wish to subsequently opt-out with them.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We will notify you about such compatible use. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please email datarequest@londonlink.io. 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:  

• Internal Third Parties as defined in the Glossary.
• External Third Parties as defined in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers that are data processors to use your personal data for their own purposes, and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may share your personal data within the Company and within the wider LondonLink group of companies (“LondonLink Group”) for one or more of the purposes explained in paragraph 4 above. At the time of writing, LondonLink Group consists of the Company, LondonLink OTC Limited (a company incorporated in the United Kingdom) and LondonLink LT UAB (a company incorporated in Lithuania).

We ensure your personal data is protected by requiring the Company and all companies in the LondonLink Group to enter into data processing agreements that contain strict data protection obligations.

We may also share your personal data with third parties, once again for one or more of the purposes explained in paragraph 4 above. Where those third parties are based in the European Union, the strict provisions of the EU GDPR will apply. Where those third parties are based outside of the European Union, we will ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the EU-U.S. Data Privacy Framework (EU-U.S. DPF) which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-U.S. Data Privacy Framework.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of Lithuania.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach, where we are legally required to do so.

We also have various internal good practice policies and guidelines, do's and don'ts and similar helpful information for contractors and employees.

8. Data retention

How long we will use your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to ten years after they cease being customers.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully using it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to use it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.    

For more information about these rights, please visit the website of the supervisory authority.

If you wish to exercise any of these rights, raise an issue or ask a data protection related question, please send an email to: datarequest@londonlink.io.

As above, you also have a right to lodge a complaint with the supervisory authority if you are in any way dissatisfied about how we process your personal data.

No fee usually required

You will not normally have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month (up to three months) if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we use your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a contract means using your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means using your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Third parties

Internal third parties

• Other LondonLink Group entities providing services for or on behalf of the Company.

External third parties

• Professional advisers acting as processors or joint/separate controllers including lawyers, bankers, auditors and insurers based in Lithuania or elsewhere who provide consultancy, banking, legal, insurance and accounting services.
• Tax authorities, regulators and other authorities acting as processors or joint/separate controllers based in Lithuania or elsewhere who may require reporting of processing activities in certain circumstances.
• Any third parties asked by the Company to undertake tasks for the purposes of customer onboarding, initial or ongoing verifications or due diligence, acting as processors or joint/separate controllers based in Lithuania or elsewhere on behalf of the Company.