Privacy Policy
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Introduction
Please take a moment to read this Policy carefully. This Policy describes when, why and how Ledn Cayman SEZC Inc. (together with its affiliates and subsidiaries, “Ledn”) collects, uses, discloses, and protects your personal information.
By accessing or using Ledn’s website at https://ledn.io/ and its subdomains, or Ledn’s mobile application which can be downloaded from the Apple App Store or Google Play Store (collectively, the “Platform”), you acknowledge that you have read, understood, and accept this Privacy Policy (this “Policy”) and consent to the practices described herein. You acknowledge that Ledn’s Terms of Service, found at found at https://ledn.io/legal/terms-of-service, is incorporated into this Policy by reference. If you do not agree with this Policy, you should not access or use the Platform.
As part of Ledn’s regular business operations, Ledn collects personal information from you to provide you with Ledn’s products and services. Ledn’s company culture is centered on transparency, integrity, and fairness. These values guide everything that Ledn does, including how Ledn gathers and uses your personal data and information.
Ledn will only use your personal information in accordance with this Policy unless otherwise required by applicable law. Ledn take steps to ensure that the personal information that Ledn collect about you is adequate, relevant, not excessive, and used for limited purposes. Ledn only collect the necessary information to originate, administer and process Ledn’s services (including as necessary to comply with Ledn’s legal and regulatory obligations).
Ledn’s services may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share personal information about you. If you follow a link to a third-party website or engage a third-party plugin or service, please note that these third parties have their own privacy policies and Ledn do not accept any responsibility or liability for those policies. Ledn do not control these third-party websites, and Ledn encourage you to read the Policy of every website you visit.
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What is personal information?
Personal information. Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information Ledn can reasonably use to, directly or indirectly, identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, username or other similar identifier, billing and account information, social insurance number, and any other identifier Ledn may use to contact you.
Non-personal information. Non-personal information does not directly or indirectly reveal your identity or directly relate to an identifiable individual. Examples of non-personal information are statistical or aggregate data. Statistical or aggregated data does not directly identify a specific person, but Ledn may derive non-personal statistical or aggregated data from personal information. For example, Ledn may aggregate personal information to calculate the percentage of users accessing a specific page on Ledn’s website.
Non-personal information also includes technical information such as your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access Ledn’s website, and usage details. Ledn also collect non-personal details about your website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from Ledn’s website (including date and time), pages, products and services 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), methods used to browse away from a page, or any phone number used to call Ledn’s customer service number.
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How does Ledn collect information about you?
3.1. Overview
Ledn uses three different methods to collect your information.
First, Ledn collects information when you provide it to Ledn through Ledn’s direct interactions with you, for example, by filling in forms or corresponding with Ledn through Ledn’s website or by phone, email, videocall, videoconference, instant messaging app, or otherwise. You also provide Ledn with information when you interact with Ledn through public websites, including social media and social networking websites.
Second, Ledn collects information through cookies and other automated technologies or interactions, as you navigate through Ledn’s website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Third, Ledn also collects information about you from third parties, as required or permitted by applicable law. Third-party sources may include public databases, credit bureaus identity verification partners, resellers and channel partners, support channel partners, joint marketing partners, and social media platforms. Additionally, Ledn receives personal information when you link a third-party service to Ledn. Such linkage may include interactions with Ledn’s social media sites. Please remember that third-party websites are governed by their own privacy policies, and you should review those privacy policies before using those sites.
3.2. Information you provide to Ledn
Ledn collects information from you by asking you directly for it, this includes when you interact with one of Ledn’s representatives or when you fill certain forms on Ledn’s website.
To establish an account and access Ledn’s services, Ledn will ask you to provide Ledn with some information about yourself. This information is either required by law (e.g., to verify your identity), necessary to provide the requested services (e.g., you will need to provide your wallet address if you would like to link that wallet to your Ledn account), or is relevant for certain specified purposes, described in greater detail below. As Ledn add new features and services, you may be asked to provide additional information. Ledn may ask you for information when you enter a contest or promotion sponsored by Ledn, and when you report a problem with Ledn’s website. Ledn may also ask you for additional information, or to confirm the information you previously provided to Ledn, if you make an unusual transaction or make an unusual request.
Please note that Ledn may not be able to serve you as effectively or at all or offer you Ledn’s services if you choose not to share certain information with Ledn. Any information you provide to Ledn that is not required is voluntary. For example, you may provide Ledn with additional personal information if you select to designate beneficiaries to your account or if you safelist certain wallet addresses.
Ledn may collect the following types of information from you.
(a) Personal identification information: such as your full legal name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, information about family members, and email.
(b) Formal identification information: including government issued identity document such as passport, driver license, national or state identity card, tax identification number, social insurance number (or any comparable identification number issued by a government), social security card, passport number, driver license details, national identity card details, visa information, and/or any other information deemed necessary to comply with Ledn’s legal obligations under financial, anti-money laundering or counter terrorism financing laws.
(c) Employment information: including employment or occupation industry, office location, job title, and/or description of role, employer identification number (or comparable number issued by a government)
(d) Additional information: including responses to questions that Ledn is specifically required to ask or information that Ledn is required to obtain in order to meet Ledn’s regulatory, compliance or other legal obligations, such as questions about the source and the intended use of any funds or digital assets; proof of legal formation (e.g., articles of incorporation), personal identification information for all material beneficial owners; bank account information, payment card account number, transaction history, trading data; information about the transactions you made or intend to make.
(e) Other information: Ledn’s compliance team may request additional information from you, as may be required for compliance with law, regulations or Ledn’s internal policies. This may include information relating to travel history, relationship/marital status and criminal convictions or charges.
3.3. Information Ledn collects through cookies
As you navigate through and interact with Ledn’s website, Ledn uses cookies and other automatic data collection technologies to collect certain information about you, your equipment, browsing actions, and patterns, including details of your visits to Ledn’s website, traffic data, location data, logs, information about your computer and internet connection, including your IP address, operating system, and browser type and other communication data and the resources that you access and use on the website.
Cookies (or browser cookies) are small text files sent from a site to the hard drive of your device (e.g., computer or phone) to store bits of information related to you. First-party cookies are put on your device directly by Ledn’s website, which allows Ledn to collect analytical data and provide other useful functions that create a good user experience.
Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on Ledn’s site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information. Examples of such third-party cookies that Ledn’s website may use are Facebook, Twitter, LinkedIn, Google and Bing. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of Ledn’s website. Unless you have adjusted your browser setting so that it will refuse cookies, Ledn’s system will issue cookies when you visit Ledn’s website.
Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the website quicker, easier and smoother.
Certain features of Ledn’s website may use local stored objects (sometimes referred to as flash cookies) to collect and store information about your preferences and navigation to, from, and on Ledn’s website. Flash cookies are not managed by the same browser settings that are used for browser cookies.
Pages of Ledn’s website and Ledn’s emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that allow Ledn, among other things, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
3.4. Third party cookies
Some content or applications on Ledn’s website may be served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use Ledn’s website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. Ledn does not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
3.5. Publicly available information
Anyone can see the balance and transaction history of any public digital asset address (public key). Ledn, and any other person who can match your digital asset address to other information about you, may be able to identify you from a blockchain transaction. This is because information published on a blockchain can be correlated with information that Ledn and others may have. This may be the case even if Ledn, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of Ledn’s security, anti-fraud and/or identity verification and authentication checks, Ledn may conduct such analysis to collect and process such information about you. You acknowledge and agree to allow Ledn to perform such practices.
3.6. Online tracking and do not track signals
Ledn may, and Ledn may allow third party service providers to, use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of Ledn’s website. Ledn’s website currently does not respond to “do not track” signals and operates as described in this Policy whether or not a “do not track” signal is received. If Ledn does respond to “do not track” signals in the future, Ledn will describe how Ledn do so in an updated version of this Policy.
3.7. Children
Ledn’s services are not meant for persons under the age of majority or younger than 18 years. Ledn does not knowingly or intentionally collect personal information from such persons. If Ledn learns that Ledn has inadvertently gathered personal information about such a person, Ledn will take legally permissible measures to remove that information from Ledn’s records. Ledn will require such a user to close his or her account and will not allow the use of Ledn’s products and services. If you are the parent or guardian of a minor and you become aware that he or she has provided personal information to Ledn, please contact Ledn at privacy@ledn.io.
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Why does Ledn collect your information and how do Ledn uses it?
The information collected and the practices described in this Policy are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, comply with various legal and regulatory obligations, and help Ledn maintain and improve Ledn’s services and products.
4.1. To maintain legal and regulatory compliance
Most of Ledn’s services are subject to laws and regulations requiring Ledn to collect, use, and store your personal information in certain ways. For example, Ledn must identify and verify customers using Ledn’s services in order to comply with anti-money laundering and counter terrorism financing laws across the jurisdictions in which Ledn operates. This may include the collection and storage of your photo identification and other documents you provide to Ledn.
In addition, Ledn uses third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. Ledn may require you to provide additional information which Ledn may use in collaboration with service providers acting on Ledn’s behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, Ledn may have to close your account.
4.2. To protect you and Ledn
Ledn processes your personal information in order to administer and protect Ledn’s business, prevent and mitigate fraud, criminal activity, or misuses of Ledn’s services, and to ensure the security of Ledn’s systems, architecture and networks, and to protect you against account compromise or funds loss.
4.3. Enforce the terms of Ledn’s agreements
Ledn processes and uses your personal information to actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce Ledn’s agreements with you and third parties, and/or prevent and detect violations of Ledn’s posted user agreements and terms of service. In addition, Ledn may process your information in order to collect fees based on your use of Ledn’s services.
4.4. To provide you with Ledn’s services and keep you informed
Ledn processes your personal information to provide Ledn’s services to you. For example, when you want to store digital assets on Ledn’s platform, Ledn requires certain information such as your identification, contact information, and payment information. Ledn generally cannot provide you with Ledn’s services without such information. Third parties such as identity verification services may also access and/or collect your personal information when providing identity verification and/or fraud prevention services.
Ledn sends administrative or account-related information to you to keep you updated about Ledn’s services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use Ledn’s services. You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.
4.5. To provide you with customer service and support and for quality control
Ledn processes your personal information when you contact Ledn to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, Ledn cannot respond to your requests and ensure your uninterrupted use of Ledn’s services. Ledn also processes your personal information for quality control and staff training to make sure Ledn continues to provide you with accurate information and quality services.
4.6. To engage in marketing and promotional activities
Ledn may send you marketing communications (e.g., emails or mobile notifications) to inform you about Ledn’s events or Ledn’s partner events; to deliver targeted marketing; and to provide you with promotional offers. Ledn’s marketing will be conducted in accordance with your marketing preferences and as permitted by applicable law.
4.7. To enhance your experience and for development purposes
Ledn processes your personal information to better understand the way you use and interact with Ledn’s services. In addition, Ledn uses such information to customise, measure, and improve Ledn’s services and to develop new services. This processing is essential to ensure your continued enjoyment and satisfaction.
Ledn processes your personal information to provide a personalized experience, and implement the preferences you request. For example, you may choose to provide Ledn with access to certain personal information stored by third parties. Without such processing, Ledn may not be able to ensure your continued enjoyment of part or all of Ledn’s services.
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What is the legal basis that allows Ledn to collect and process your information?
At the time that your personal information is collected, Ledn relies on the following legal bases for processing your information. Ledn will generally only collect or process your data where Ledn is legally required to, where processing is necessary to perform any contracts Ledn entered with you (or to take steps at your request prior to entering into a contract with you), for Ledn’s legitimate interests to operate Ledn’s business or to protect Ledn’s or your property, rights, or safety, or where Ledn have obtained your consent to do so. When Ledn collects or processes your personal information based on Ledn’s legitimate interests, Ledn ensures that Ledn considers and balances any potential impact on you and your rights under privacy protection laws. Ledn values you and your privacy rights and interests.
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With whom do Ledn share your information?
6.1. Ledn’s Affiliates
Ledn may share personal information with Ledn’s affiliates that distribute or market Ledn’s products using this information in accordance with this Policy.
6.2. Service Providers
Ledn engages, and to the extent permissible by applicable law Ledn may share your personal information with, financial, accounting, legal, marketing, communication and technology companies to provide services such as data processing, proof-of-reserves attestations, administrative services, regulatory support, legal services, liquidity services, bank services, cloud storage, authentication support, payment processing, technical support, sales, client support, data hosting, marketing analytics auditors, accountant , cryptocurrency exchange and custodians, cryptocurrency forensic analysis services.
6.3. Regulatory and Government Authorities
Ledn may share your personal information with law enforcement, regulatory agencies, and self-regulatory agencies to help prevent fraud, for legal proceedings, or as otherwise required by law. Ledn is also legally obligated to report certain transactions if Ledn has reasonable grounds to suspect that the transaction or attempted transaction is related to the commission of a money laundering offence or a terrorist activity financing offence.
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Why does Ledn share your information with others?
Ledn may share your information in order to be able to process certain transactions. Ledn may disclose personal information to third parties in order to administer or process a transaction, product or service you have authorized or requested, or in the context of facilitating the execution of a transaction. This includes sharing your information with financial institutions with which Ledn partners with to process payments which you have authorized.
Ledn may share your information in order to meet Ledn’s legal obligations, including Ledn’s know-your-customer and anti-money-laundering obligations. Ledn is required to validate Ledn’s clients’ identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal information that you provide to Ledn during the account opening process is passed to these service providers at account opening and on an ongoing basis thereafter.
Ledn may share your information in order to protect Ledn’s legal rights. Ledn may disclose or transfer information Ledn collects upon account closing where you have a deficient balance.
Ledn may also share or transfer your personal information, in accordance with applicable law, to a buyer of Ledn’s company, or substantially all of its assets. You acknowledge that such transfers may occur, and that any purchaser of or successor to Ledn’s business or its assets may continue to collect, use and disclose your information as set forth in this Policy.
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Where does Ledn store and process your personal information?
Ledn may transfer your personal information outside your home jurisdiction to Ledn’s affiliates, service providers and business partners who are engaged on Ledn’s behalf. To the extent that Ledn transfers your personal information outside of your home jurisdiction, Ledn will ensure that the transfer is lawful and that all persons to whom Ledn transfers such data are obliged to comply with all applicable laws, rules and regulations.
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How does Ledn protect your personal information?
Ledn is strongly committed to keeping your personal information safe. This commitment exists throughout the lifecycle of your personal data, starting with the design of Ledn’s services. Ledn protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations. For example, Ledn uses computer safeguards such as firewalls and data encryption, Ledn enforces physical access controls to Ledn’s physical sites and files, and Ledn authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
However, Ledn cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering for an account with Ledn it is important to choose a password of sufficient length and complexity, to not reveal this password to any other person, and to immediately notify Ledn if you become aware of any unauthorized access to or use of your account.
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Ledn’s data retention policy
If you close your Ledn Account, Ledn will mark your account in Ledn’s database as “closed,” but will keep your account information in Ledn’s database in accordance with Ledn’s retention policy. If you require more information about Ledn’s retention policy please contact Ledn at privacy@ledn.io. This is necessary in order to deter fraud and to ensure that Ledn meets all Ledn’s legal and regulatory obligations. However, if you close your account, your personal information will not be used by Ledn for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Policy.
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Your privacy rights
11.1. Right to Access
You may request Ledn to provide you with a copy of the personal information Ledn holds about you and certain information about Ledn’s processing of this information.
11.2. Rectification
It is important to Ledn that your personal information is up to date. Ledn will take all reasonable steps to make sure that your personal information remains accurate, complete and up to date. If the personal information Ledn holds about you is inaccurate or incomplete, you are entitled to have it rectified. If Ledn has disclosed your personal information to others, Ledn will let them know about such rectification where possible. If you ask Ledn, if possible and lawful to do so, Ledn will also inform you with whom Ledn have shared your personal information so that you can contact them directly.
11.3. Right to Erasure
You may request Ledn to delete your personal information from Ledn’s records subject to certain exceptions. For example, Ledn may deny your request if retaining your personal information is required under certain circumstances, such as complying with a legal obligation; establishing, exercising or defending legal claims; or performing a task in the public interest or in the exercise of official authority.
11.4. Right to Data Portability
You may request Ledn to transfer a machine-readable copy of your personal information to you or a third party of your choice. Ledn will provide you, or a third party, your personal information in a machine-readable format. This right only applies to personal information you have consented for Ledn to use.
11.5. Right to Restrict Processing
You may request Ledn to restrict or suppress the processing of your personal information under certain circumstances, for example: to establish the accuracy of the personal information; where the processing is unlawful, but you do not want your personal information erased; where Ledn no longer needs to process your personal information, but the information must be retained for legal reasons; and where you have objected to Ledn’s processing your personal information, but Ledn needs to determine whether Ledn’s legitimate interest overrides your objection.
11.6. Right to Object
You may object to Ledn’s reliance on Ledn’s legitimate interests as the basis of Ledn’s processing of your personal information that impacts your rights. You also may object to Ledn’s processing of your personal information for direct marketing purposes.
11.7. Right to Withdraw Consent
You may withdraw your consent at any time where Ledn is relying on it to process your personal information. Withdrawing your consent does not affect the lawfulness of Ledn’s processing of your personal information prior to such withdrawal.
11.8. Right not to sell
Ledn will never sell or rent your personal information to any third parties without your explicit consent.
11.9. Jurisdictional specific privacy rights
Depending on the jurisdiction where you reside, you may have certain additional statutory rights over the personal information Ledn collects about you. You may exercise these rights at any time by contacting Ledn. Note that Ledn may refuse to grant your requests in whole or in part as permitted by applicable law.
11.10 Additional information
The Cayman Islands Data Protection Act, 2017 (as amended, the "DPA") applies to any affiliates and subsidiaries of Ledn that are organised in the Cayman Islands. Where you engage the services of such an entity, that entity is a data controller with respect to your personal data and shall process your personal data in accordance with the requirements of the DPA. Subject to complying with the DPA, the entity may also share your personal data with its affiliates, its service providers and applicable regulatory and governmental authorities from time to time. Any transfer of your personal data outside of the Cayman Islands will be carried out in accordance with the DPA. You have certain rights under the DPA with respect to your personal data, including the right to: (a) be informed about the purposes for which your personal data are processed; (b) access your personal data; (c) stop direct marketing; (d) restrict the processing of your personal data; (e) have incomplete or inaccurate personal data corrected; (f) ask Ledn to stop processing your personal data; (g) be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you); (h) complain to the Cayman Islands Data Protection Ombudsman; and (i) require Ledn to delete your personal data in some limited circumstances.
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Changes to this Policy
This Policy is reviewed and updated regularly to ensure that any new obligations and technologies, as well as any changes to Ledn’s business operations and practices are taken into consideration, and that it remains abreast of the changing regulatory environment.
Any personal information Ledn holds will be governed by Ledn’s most recent Policy. Your continued use of this website after Ledn make changes indicates that you accept and consent to those changes, so please check the Policy periodically for updates. To the extent possible, Ledn will endeavour to notify you in advance of any material changes to this Policy and obtain your consent to any new ways that Ledn collects, uses, and discloses your personal information.
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Contact Ledn
Ledn would like to hear from you if you have any questions, comments or complaints about this Policy or Ledn’s privacy practices. You can contact Ledn at privacy@ledn.io.
Ledn tries to respond to requests within 30 days. Occasionally, it may take Ledn longer than that if your request is particularly complex, if you have made several requests, or if Ledn requires additional information from you to process your request. In this case, Ledn will notify you within the 30-day period and keep you updated. If you have a Ledn Account, Ledn may deliver Ledn’s response to that account. If you do not have a Ledn Account, Ledn will deliver Ledn’s response by mail or electronically. If Ledn cannot comply with your request, Ledn will provide a detailed explanation of why Ledn cannot comply.
Ledn is committed to resolving any complaints about Ledn’s processing of your personal information in a fair and equitable manner that takes into account your privacy rights and interests. Where you are not satisfied with the actions Ledn take to rectify a matter, or with the explanations given, you will be informed of your further rights including the right to file a complaint with the appropriate regulatory agency and body, and will be given clear direction as to how to do so.
Last updated: 08/03/2023