Privacy Policy

1. Introduction

1.1. The purpose of this policy is to inform you about how we process your personal data, including, where it applies to our processing, 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”).

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://app.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”). Where the Services are provided by LN Markets, S.A.S. de C.V., a company incorporated in El Salvador, that entity acts as data controller for the personal data processed in connection with those Services, and the processing is also subject to the Salvadoran Ley de Protección de Datos Personales. LNM LLC and LN Markets, S.A.S. de C.V. have agreed their respective responsibilities under applicable data protection law.

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://cdn.lnmarkets.com/documents/privacy-policy.html. 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 claim.

1.6. Current version: 2.0. Effective date: 12 November 2026. Last updated: 12 November 2026. Previous versions are available on request at support@lnmarkets.com.

2. Purposes of Personal Information collection

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

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

2.3. Identity verification and anti-money laundering

We are required by applicable anti-money laundering, counter-terrorist financing and sanctions law to identify and verify our users, to monitor their transactions, to screen them against sanctions and politically exposed persons lists, and to report suspicious activity to the competent authorities.

Purposes. Verifying your identity and the authenticity of the documents you provide; assessing and monitoring the risk associated with your account; detecting and preventing fraud, money laundering, terrorist financing and sanctions evasion; complying with information requirements applicable to transfers of digital assets; and responding to requests from competent authorities.

Legal basis. Compliance with a legal obligation to which we are subject, under Article 6(1)(c) of the GDPR. Where we process biometric data for the purpose of uniquely identifying you, as described in Section 3.6, we do so on the basis of Article 9(2)(g) of the GDPR, the processing being necessary for reasons of substantial public interest on the basis of the anti-money laundering legislation applicable to us.

Retention. The records generated for these purposes are retained for the period set out in Section 6.7, including after your account is closed. These retention periods are imposed by law and prevail over any request for erasure.

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. Your e-mail address and your financial information. Where you complete identity verification, we also collect the information described in Sections 3.4 to 3.6.

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.

3.4. Identity verification data. Your full legal name, date of birth, nationality and country of residence; the type, number, issuing country and expiry date of your identity document, and an image of that document; a selfie or video recorded during a liveness check; your residential address and the document evidencing it; and the answers you provide to our financial questionnaire, including your trading experience, investment objectives, risk tolerance and expected trading activity.

3.5. Compliance and monitoring data. Information about the source of your funds and, where requested, your source of wealth, employment or income; the results of sanctions, politically exposed persons and adverse media screening; risk scores and alerts generated by our monitoring systems; the blockchain addresses associated with your deposits and withdrawals and the analytics performed on them; and the records of any internal investigation, decision or report arising from these checks.

3.6. Biometric data. The selfie or liveness check you provide is compared with the photograph on your identity document. This comparison involves the processing of biometric data for the purpose of uniquely identifying you, which is a special category of personal data under Article 9 of the GDPR. We process it only for the purpose described in Section 2.3, on the legal basis set out in that Section, and for no other purpose. We do not use it for facial recognition outside the verification process, we do not use it to identify you in any image other than the ones you submit, and we do not share it other than as described in Section 5.

3.7. Technical and connection data. Your IP address and the country it indicates, your device and browser type, and the date, time and technical details of your connections to the Services. We use this information to secure your Account, to detect and prevent fraud and abuse, and to verify that you are not accessing the Services from a jurisdiction in which they are not available.

4. Cookies

For more information on cookies management, please consult https://cdn.lnmarkets.com/documents/cookies.html.

5. Who has access to your personal information

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

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, except where we are required to retain it for a longer period under anti-money laundering law, in which case the period set out in Section 6.7 applies.

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:

6.7. Retention periods.

Data Retention period
Identity verification records, including identity documents, selfie or liveness check, proof of address and questionnaire answers 15 years from the end of the business relationship
Transaction records and the information accompanying transfers 15 years from the date of the transaction
Screening results, alerts, internal investigations and reports to the authorities 15 years from the date of the record
Account and profile data Duration of the account, then as above
Connection logs 1 year
Customer support correspondence 5 years
Marketing data 3 years from last contact, or until consent is withdrawn

These periods are imposed by the anti-money laundering legislation applicable to us. Where more than one period applies to the same record, the longest applies.

7. Your rights

The exercise of these rights is limited where we are required to retain or to refrain from disclosing information under anti-money laundering, counter-terrorist financing or sanctions law. In particular, we cannot erase records that we are required to retain under Section 6.7, and we may be prohibited by law from confirming or denying the existence of a report made to a competent authority, or from providing access to the data underlying such a report. 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. Note in particular that we cannot comply with a request for erasure in respect of records retained under Section 6.7 for the duration of the applicable retention period;

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:

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 (the supervisory authority of the country in which you reside or in which the alleged infringement took place), 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: support@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: support@lnmarkets.com.