PRIVACY POLICY

1. GENERAL PROVISIONS

This Privacy Policy governs your acquisition and use of $Lopes tokens as well as all features related to the $Lopes-Ecosystem including products, services, content, technologies, or functions offered by Leandro Lopes AG and all related sites, applications, and services (collectively „ $Lopes Services„) including, without limitation, when you provide any information to us in relation to your use of $Lopes Services.

Our website is not intended for children under the age of 18. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our website or on or through any of its features/register on the website, make any purchases through the website, use any of the interactive or public comment features of the website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we find out we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@leandrolopes.com

You accept and consent to this Privacy Policy when you sign up for, access, or use our Services. By accepting and consenting to this Privacy Policy, you expressly consent to our use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

In order to operate our Services, to meet out regulatory obligations and to reduce the risk of online fraud, Leandro Lopes AG („we”, „our”, „us” or „the Company”), as a data collector and controller, must ask you to provide us with information about yourself, including your personal details, and information about financial background and situation or payment options that may be connected to your use of $Lopes Services, as well as any other types of information specified in this Policy.

By consenting to and agreeing to the terms of this Privacy Policy, you expressly consent and agree to us processing your data in the manner set out herein. This Privacy Policy describes the information we collect and how we use that information. The Company takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. For the purposes of this Privacy Policy, the term „information” means any confidential and/or personally identifiable information or other information related to your use of our services.

We will not sell or rent your information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer $Lopes Services to our users and to enhance the quality of our Services from time to time, and protect the interests of our users, we will in limited circumstances share some of your information with third parties under strict restrictions, as described in greater detail in the following sections of this Policy. It is important for you to review this Privacy Policy as it applies to all $Lopes Services.

This Privacy Policy is intended to govern the use of $Lopes Services by our users (including, without limitation those who may use our Services in the course of their trade or business) unless otherwise agreed through contract.

Personal information or data refers to any information that can be associated with a specific person and can be used to identify that person, directly or indirectly, in particular by reference to required information that the user provides to the Company to gain access to and use our Services (hereinafter „Personal Data“ or „Personal Information)“.

The Company is aware of the importance of how Personal Data is handled and will observe all applicable data protection laws, in particular the General Data Protection Regulation (EU) 2016/679 (hereinafter: GDPR).

Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.

Changes to this Privacy Policy: All future changes to this Privacy Policy are incorporated by reference into the Terms and Conditions (our contract) with you and will take effect as specified in the Policy Updates, when they may occur. „Policy Update” means a prior notice of changes to any of your agreements with the Company, which we may make available to you in writing, including in electronic form. If you disagree with the terms of this Privacy Policy, please do not register for or use the $Lopes Services.

Notification of Changes: This Privacy Policy may be revised over time, for example, as new features are added to $Lopes Services, or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website. Unless we have legal grounds to do otherwise, we will provide you with at least 30 days’ prior notice of the effective date of the revised Privacy Policy. We may post the notice on our website and/or send the notice by email. As of the effective date of the revised Privacy Policy, you will be considered as having consented to all changes to the Privacy Policy. If you disagree with the terms of this Privacy Policy, you may close your contractual relationship with us at any time.

Third Party Websites: Some pages on the Leandro Lopes website may include links to third-party websites. These sites are governed by their own privacy statements, and the Company is not responsible for their operations, including, but not limited to, their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.

2. COOKIE POLICY

When you access our website, or use our Services, we (including companies we work with, as the case may be) may place small data files on your computer or other devices. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We use Cookies to recognize you as a customer, customize our Services, content and advertising, measure promotional effectiveness, mitigate risk and prevent fraud, and to promote trust and safety across our sites and $Lopes Services.

Most web browsers are set to accept cookies by default. You are free to decline most of the cookies if the browser or browser add-on permits. Choosing to remove or disable cookies may interfere with the use and functionality of the Services. Additionally, the Company may use certain persistent cookies that are not affected by browser settings but will use such cookies solely for identity verification and fraud prevention purposes.

3. INFORMATION COLLECTED BY THE COMPANY

Information collected from users: To register for and use the $Lopes Services, you must provide your full name, address, phone number, the details of your identification document, and email address.

We may also require you to provide us with other commercial and/or identification information depending on the payment amounts or as is otherwise required in order for us to comply with our anti-money laundering and risk management obligations.

Using your device: When you use $Lopes Services on any device, we may additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data.

Photographs: If you use certain functionalities provided by us, we may ask you to upload a picture of you in order to provide you with these specific services. Your face must be recognizable.

Transaction Information: When you use $Lopes Services to send funds to someone else or request money from someone else, as the case may be, we may ask you to provide information related to that transaction. This information includes the amount and type of the transaction, transactional details and the details pertaining to the identity of the third party.

Information About Users From Third Parties: In order to comply with our legal obligations in particular with respect to the avoidance of anti-money laundering and enforce our Terms and Conditions, we verify and validate information provided to us by users with a number of 3rd parties, such as financial partners, fraud agencies, data vendors, as well as using information available through internet and publicly accessible social network data. In the course of such verification, we may receive personally identifiable information about our users from such services and sources.

If you send major payment volumes or display inconsistent transactional patterns, or if you have a limited transactional history with us, in some circumstances we will conduct a background check on you by obtaining information about you and your activities, and potentially (if legally permitted) also about your business partners, from a credit reference or fraud agency.

We may also collect public information about your activities and your behavior on social media platforms (such as the email address and the number of “likes” and “followers”), to the extent relevant to make anti-money laundering assessments.

Examples of information we automatically collect about you may include:

• the Internet protocol (IP) address used, information about your device and its location, as well as the details about your internet provider or mobile phone operator;
• your login, e-mail address, password and the outcome of the strong authentication methods you use;
• your interaction with our services, for example, the content you viewed, uploaded or downloaded, your transactional history;
• your (URL) clickstream to, through and from our website (including date and time); cookie number, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
• phone numbers used to call our customer service number.

Additional Verification: If we cannot verify the information that you provide, we may ask you to upload or send us additional confirmation or to answer additional questions online to help verify your information.

Website Traffic Information: Because of the way internet communication standards work, when you arrive at or leave the $Lopes website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser you use and the times you access our website.

Communications: When you communicate with us for customer service or other purposes (e.g., by emails, calls, tweets, etc.), we may retain such information and our responses to you in the records.

Questionnaires, Surveys, Sweepstakes and Profile Data: From time to time, we offer optional questionnaires, surveys, online competitions and sweepstakes to our users for such purposes as collecting demographic information or assessing users’ interests and needs. If we collect personally identifiable information from our users in these questionnaires, surveys, and sweepstakes, the users will be given notice of how the information will be used prior to their participation in the survey, questionnaire or sweepstake.

Some of this information, for example, indicating your racial origin or biometrical details, is considered especially sensitive, from the point of view of data protection, and we will use and process this information in strict accordance with the law.

4. HOW THE COMPANY MAY USE CUSTOMER INFORMATION

Below is a summary of how company may use customer information collected from our users or about our users.

Internal Uses: We collect, store and process your information on servers located in the European Economic Area. Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:

• Process and execute your transactions (payments, token transfer) and provide the $Lopes Services;
• Verify your identity, and perform password reset processes;
• Resolve disputes, collect fees, and troubleshoot problems;
• Manage risks, or to detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities;
• Detect, prevent or remediate violations of policies or applicable user agreements;
• Provide you with customer support services;
• Improve the $Lopes Services by customizing your user experience;
• Measure the performance of $Lopes Services and improve the content and layout of our website and user interfaces;
• Manage and protect our information technology infrastructure;
• Provide targeted marketing and advertising (if you opted in to receive them), provide service updates, and deliver promotional offers based on the communication preferences; and
• erform online security, compliance, risk assessment, compare information for accuracy, and verify it with third parties, as the case may be.

Questionnaires, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use such information to improve our Services, send your marketing or advertising profile preferences, or as otherwise explained in detail in the survey or campaign itself.

Our Contact with Customers: We communicate with our users on a regular basis via email and chats to provide requested services. We may also communicate with our users by phone or using VOIP technologies to:

• Resolve customer complaints or claims made by users;
• Respond to requests for customer service;
• Confirm information concerning a user’s identity;
• Conduct customer surveys; and
• Investigate suspicious transactions.

We use your email to confirm your registrations, to send you notices and confirmations related thereto, to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be informational in nature, and not promotional.

We may also use your email address to send you other types of communications that you can control, including “news”, “customer surveys”. You can choose whether to receive some, all, or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your registration account and then selecting settings and updating your communicational preferences.

5. MARKETING

The Company may use your Personal Data to form a view on what we believe might enhance your user experience or present you with information that may be of interest to you.

If you don’t wish to receive marketing communications from us, or to participate in our ad-customization programs, simply update your preferences.

If you would like to change your personal communication preferences or opt-out from receiving any marketing communications from us, you can do so by adjusting your preferences in the communication preferences profile section or by contacting us at: info@leandrolopes.com.

6. DISCLOSURE OF YOUR PERSONAL DATA

The Company will not transfer, disclose, sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Privacy Policy.

Specifically, you consent to and direct the Company to do any and all of the following with your information:

• Disclose necessary information to: the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies, departments, regulatory authorities, self-regulatory authorities or organizations and other third parties, that (i) we are legally compelled and permitted to comply with, including but without limitation the US Foreign Account Tax Compliance Act (“FATCA Law”) and with the OECD common reporting standard (“CRS Law”) as implemented in the Liechtenstein regulatory framework; (ii) we have reason to believe it is appropriate for us to cooperate with governmental agencies or payment or processing partners in investigations of fraud or other illegal activity or potential illegal activity, to the fullest extent permitted by law, or (iii) to conduct investigations of violations of our Terms and Conditions (including without limitation, your funding source or transactional history). If you are covered by the FATCA or CRS Law, we are required to give you notice of the information about you that we may transfer to various authorities. If we believe you may be subject to these regulations, we may notify you separately.
• We and other organizations, including financial institutions that cooperate with the Company, may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing).
• Disclose necessary information to technical service providers, auditors, customer services providers, credit reference and fraud agencies, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties, in order to provide our services to you our pursue our other legitimate interests.
• Disclose necessary information to your legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
• Disclose aggregated (i.e.: anonymized) statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in a certain city. However, this aggregated information is not tied to personal information.
• Share necessary Registration Information with unaffiliated third parties (listed below) for the following purposes:
  • Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk, as permitted by applicable law.
  • Customer Service: for customer service purposes (e.g., billing or transactional).
  • Legal & Compliance: to help us and our partners comply with anti-money laundering and counter-terrorist financing verification requirements, as permitted by applicable law.
  • Service Providers: to enable service providers under contract with us to support our business operations, namely fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
  • Mergers or Acquisitions: As with any other business, it is possible that in the future the Company could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by the Company, including customer information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended.

7. STORAGE SECURITY & INTERNATIONAL TRANSFERS

The Company is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities, and who have committed themselves to confidentiality undertakings.

The security of your wallet which you open in order to receive $Slopes tokens relies on the protection of your private key. You may not share your private key with anyone. The Company’s representatives will never ask you for your password, so any email or other communication requesting your private key should be treated as unauthorized and suspicious and forwarded to us. If you do share your private key with a third party for any reason, including because the third party has promised to provide you additional services, the third party will have access to your wallet and your personal information, and you may be responsible for actions taken using your private key. If you believe someone else has obtained access to your private key, please change it immediately, and also contact us right away.

The Company is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information if your data is transferred outside of the EEA. In this regard, transfers to non-EEA countries may notably be carried out on the basis of adequate contractual arrangements, a copy of which may be obtained by you by simple request sent to the Company.

The Personal Data that we collect from you will be transferred to and stored at a destination inside the European Economic Area (EEA). As we provide an international service, your Personal Data may be processed outside of the EEA in order for us to fulfil our contract with you to provide the $Lopes Services.

All information you provide to us is stored on our secure servers, encrypted at rest. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Certain $Lopes Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

8. DATA RETENTION

The Company is obligated under the Liechtenstein’s Law of 11th December 2008 on Professional Due diligence for the Prevention of Money Laundering, Organized Crime and Financing of Terrorism, no. 952.1 to retain personal data about you and your $Lopes transactions for a period of minimum ten years from the conclusion of the transaction or from their preparation. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 10 years after the termination of our business relationship, unless there are other legal obligations that require us to retain your information longer.

9. YOUR LEGAL RIGHTS

You have a right to:

• Access the personal data we hold about you, or to get a copy of it,
• Make us correct inaccurate data about you,
• Ask us to delete your data, though for legal reasons we might not always be able to do it, due to various AML, data retention and financial reporting requirements applicable to us,
• Object to us using your data for marketing communications,
• Withdraw any specific consent or permission you’ve previously given us (for example, in relation to a specific promotion).

Please know that if you have any questions or objections as to how we collect and process your personal information, please contact us at info@leandrolopes.com.

• You can add or update your personal information by login into your registration profile and following the instructions. When you update information, we usually keep a copy of the previous version for our records.
• If you don’t want to receive marketing emails or other communications from us, please adjust your registration profile settings.
• If you want to browse our websites anonymously, you may do so by logging out of your registration and disabling cookies on your browser. Your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies.

Our regulatory team is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information, make changes or have any questions about this privacy statement, the Company’s information practices, or data protection, you can write to us at info@leandrolopes.com

By writing to the above address, and subject to certain conditions set out by applicable data protection laws, you may also exercise your rights to:

• object to the processing of your information;
• ask for erasure of your information;
• ask for portability of your information;
• object to the use of your information for marketing purposes.

Request of transfer of your personal data to you. You can review and download your registration information via access to our website. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month 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.

You will not have to pay a fee to access your personal data or other provided information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

If your request is clearly unfounded, repetitive or excessive we may refuse to comply with your request in these circumstances.

10. HOW TO CONTACT US OR RAISE A COMPLAINT

If you have questions about this privacy policy, including any information requests or potential complaints, you may use the contact details set out below:

Full name of legal entity: Leandro Lopes AG

Registration number: FL-0002.684.842-9

Email address: contact@leandrolopes.io

Postal address: Schaanerstrasse 13, 9490 Vaduz, Liechtenstein

If you are not satisfied by the way in which we address your concerns or how we handle your personal information, you have the right to lodge a complaint with the Liechtenstein’s Data protection Office at any time.