Privacy Policy

1. Introduction

1.1. The purpose of this policy is to inform you about how we process your personal data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and French Data Protection Law n° 78-17 of 6 January 1978 (together the "Applicable Regulations").

1.2. The proper handling of personal data is extremely important to us. We therefore take your privacy seriously when processing and protecting your personal data. We want you (hereinafter: «user») to understand how and why, we process, use, and share your personal information (hereinafter: «Personal Information», «Personal Data», «PI», «PD») when you use our website https://lnmarkets.com or software, applications and other online products and services (collectively, the «Services») or when you otherwise interact with us or receive a communication from us.

1.3. The data controller is LNM LLC, a Limited Liability Company, registered with the Registry of Trade and Companies of Saint Vincent and the Grenadines under the number 2286 LLC 2022 and whose head office is located at First Floor, SVG Teachers Credit Union Uptown Building, Corner of James and Middle Street, Kingstown P. O., St. Vincent and the Grenadines (“Us” or “We”).

1.4. We may revise this Privacy Policy from time to time. The current version of the policy will govern our processing of your personal data and will always be available at https://lnmarkets.com. If we make a change to this policy that, in our sole discretion, is material, we may notify you via an email to the email address associated with your account. If required by law, we will request your permission or give you the opportunity to opt out of any new uses of your Personal Information.

1.5. LNM collects and processes personal information that is necessary for legitimate business purposes, which will be disclosed to any person whose personal data is being collected, held or processed (hereinafter: «data subject») at the time of collection. We retain your Personal Data for as long as it is required to satisfy the purpose for which they were collected and used, unless a longer period is necessary for our legal obligations or to defend a legal.

2. Purposes of Personal Information collection

2.1. We may use the information we have about you for the following purposes:

• To provide you with our services available on our Platform.
• Performance of a contract to which you are party and/or taking steps at your request prior to entering into a contract.
• When you have created your account: personal data are retained for the duration of your account. Your connection logs are kept for 1 year. If your account is inactive for a period of 2 years, it will be deleted if you do not respond to our reactivation email. In addition, personal data may be archived for probationary purposes for a period of 5 years.
• To send newsletters, requests and direct marketing mailings.
• For our customers: our legitimate interest in winning customer loyalty and informing our customers of our latest news. For our prospects: your consent.
• Personal data are retained for a period of 3 years starting from the last contact with us (e.g. communication, action) or until you withdraw your consent.
• To answer to your information request and other inquiries.
• Our legitimate interest in responding to your inquiries.
• Personal data are retained during the processing of your request and is deleted once the request has been processed.
• To process data subjects’ requests to exercise their rights.
• Our legitimate interest in responding to your requests and keeping records of them.
• If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we keep this information for 3 years. The information allowing the management of your requests to exercise your rights under the GDPR will be kept for 3 years from the date of the request.

2.2. We inform you, when collecting your personal data, whether some of these data are mandatory or optional.

3. What Personal Information we collect and store

As part of our business we may collect, use, store and transfer different kinds of personal data about you:

3.1. Customer-specific information. e-mail address, financial information.

3.2. Actions you take. We collect information about the actions you take when using the Services. This include Products you trade with us; historical data about the trades and investments you have made; Your preference for certain types of products and services. It also includes your interactions with other users or projects.

3.3. Other information. You may choose to provide other information directly to us. For example, we may collect information when you request customer support or otherwise communicate with us. You may provide us with the information about your e-mail to receive mailings and to confirm transactions.

4. Cookies

For more information on cookies management, please consult our Cookies Policy.

5. How we may use your personal information

The following categories of recipients will have access to your personal data:

• The staff of our Company;
• Our processors: hosting provider, CRM tool, mailing provider, audience measurement tool, payment service provider, cookie management tool;
• If applicable: public and private organisations, exclusively to comply with our legal obligations.

6. How we store your personal data

6.1. We hold personal information in a combination of secure computer storage facilities and paper-based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

6.2. When we consider that personal information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.

6.3. However, we may need to maintain records for a significant period of time.

6.4. Personal data provided by you as a prospective client during account opening registration in case the registration was never completed or your account opening application was rejected, will be maintained for six months unless there is a regulatory reason requiring us to keep it for a longer period of time.

6.5. Where you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.

6.6. Your personal data is hosted for the duration of the processing on the servers of the company Amazon Web Services located in the European Union. As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

• Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or
• The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or
• The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

7. Your rights

Please note that these rights do not apply in all circumstances. You are entitled to:

7.1. request access to your personal data (commonly known as a “data subject access request”);

7.2. request correction of the personal data that we hold about you;

7.3. request erasure of your personal data. 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;

7.4. 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.

7.5. 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:

• if you want us to establish the data's accuracy;
• where our use of the data is unlawful, but you do not want us to erase it;
• 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
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

7.6. 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.

7.7. Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

7.8. Right to define instructions related to the retention, deletion and communication of your personal data after your death.

7.9. Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

7.10. Please complete the personal data request by email using the registered email address you disclosed to us, to the following email address: hello@lnmarkets.com.

7.11. We may charge you a reasonable fee when a request is manifestly unfounded, excessive or repetitive, or we receive a request to provide further copies of the same data. In this case we will send you a fee request which you will have to accept prior to us processing your request. Alternatively, we may refuse to comply with your request in these circumstances. We may ask you to provide us with additional information or documents to prove your identity.

8. Contact us

If you have any questions about this Privacy Policy, please feel free to contact us or to write to us at e-mail: hello@lnmarkets.com.