Last updated: 1/2/2022
This LYPTOEX Privacy Policy explains how information about you is collected, used and disclosed by LYPTOEX Ltd. (“LYPTOEX,” “we”, “our” or “us”). This Privacy Policy applies to information we collect when you use our platform and/or services (“Platform” and “Services” respectively).
Occasionally we may, at our discretion, make changes to the Privacy Policy by posting a revised version and updating the ‘Effective Date’ above. The revised version will be effective on the “Effective Date” listed. If and when such notice is required by law, we may notify you at our own discretion through one of our channels. Where your explicit consent is not needed, your continued access or use of our Platform and/or Services constitutes your acceptance of the latest Privacy Policy. You are thus encouraged to periodically review this page.
The information published herein is limited to the collection and use of information with respect to your use of our website hosted at https://lyptoex.net/, the Platform and related Services. It is important that you read this Privacy Policy together with any other privacy notice or policy 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 the other notices and is not intended to override them.
Please read this Privacy Policy carefully before accessing or using our website or Services. By entering, connecting to, accessing or using the website or Services and/or submitting your information in the registration procedure, you acknowledge that you have read and understood this Privacy Policy.
IF YOU OBJECT TO THIS PRIVACY POLICY, PLEASE DO NOT ENTER, CONNECT TO, ACCESS OR USE THE WEBSITE, PLATFORM OR SERVICES IN ANY MANNER.
Who we are
“LYPTOEX” refers to the company LYPTOEX Limited, with the registered office at Level 3 207 Regent Street, W1B 3HH, London, United Kingdom, and is a data controller in respect of personal data under this Privacy Policy.
Under relevant data protection legislation, including but not limited to the General Data Protection Regulation (“GDPR”), the UK GDPR and the Data Protection Act 2018 (the “Legislation”), the controller is the party that, alone or jointly with others, determines the purposes and means of the processing of personal data. “Controller”, “processor”, “personal data” are as defined in the Legislation.
For any clarification, question or requirement related to your privacy and the processing of your personal data, please contact privacy@lyptoex.net.
Collection of Information
What personal data we may collect about you
Personal data means any information about an individual from which that person can be identified, directly or indirectly.
We will collect and process various types of personal data about you for the purposes described in this Privacy Policy, including:
- Account Data: your email address and password, as well as your communication preferences and communication with our support staff.
- Profile Data: data collected during application and KYC processes such as your name, address, phone number, a video recording of your face, citizenship, date of birth, gender and identification numbers (e.g. driver’s licence, passport).
- Transaction Data: details about your financial transactions and details of Services you have used.
- Technical Data: information about the device you use to access our Services, including IP address, operating system, time zone, country and language setting.
- Usage Data: information about when and how you use our Services (logs of interactions with our system).
We may 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 does not reveal your identity.
Unless explicitly informed during identification procedures, we do not collect special categories of personal data (sensitive data) including race, religion, sexual orientation, health, or genetic data.
How is your data collected
Information is gathered from you as follows:
- Direct interactions: You may give us personal data by filling in forms (e.g., creating an account, performing KYC, processing payment) or by communicating via post, phone, email, chat, transactions, or otherwise. Some fields are mandatory for legal or contractual compliance.
- Automated interactions: We may automatically collect Technical Data, Usage Data and Transaction Data while you use Services.
- Received from other sources: We may receive information about you from third parties, including our group entities, service providers, regulatory bodies, public sources, and data aggregators. We may combine this with data collected from you.
In particular, we may receive personal data from our subsidiary LYPTOEX d.o.o. (a Slovenian entity) which provides account information services and processes data on behalf of Salt Edge Ltd for bank-connected wallet services.
Users should not provide data on racial/ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, private health data, or sexual life or orientation.
LYPTOEX will only send direct marketing emails if you give explicit prior consent. Consent can be withdrawn at any time via your LYPTOEX interface.
LYPTOEX does not rely solely on automated onboarding or transaction monitoring for decision-making about your Services usage.
Information We Collect Automatically
- Log Information: browser type, access times, pages viewed, IP address, and referring page.
- Cookies and Tracking Technologies: We and providers use cookies; see our Cookie Policy for details.
- XRPL Wallet Information: When you create an XRPL wallet, your browser generates public/private keys. Public address is stored publicly, private key encrypted and inaccessible to us; loss of private key means loss of assets.
Use of Information
Our use of your personal data depends on the interaction but is always based on a lawful basis. Common legal bases include:
| Category of Personal Data | Purpose | Legal Basis | Retention Period |
|---|---|---|---|
| Account Data, Profile Data, Transaction Data | Fulfilment of Services — performance of contract, managing our relationship, notifying changes | Contractual obligation and legitimate interest | Duration of agreement + time to make legal claims |
| Account Data, Profile Data, Transaction Data | Support services — respond to your queries | Contractual obligation and legitimate interest | Duration of agreement + time to make legal claims |
| Account Data, Usage Data | Marketing communications (emails, newsletters) | Consent or lawful right | Until consent withdrawn |
| Technical Data, Usage Data | User insight and analysis for improved services, personalized communication | Legitimate interest or consent | As necessary per regulation or until consent withdrawn |
| Profile Data, Transaction Data, Account Data | Compliance with legal and regulatory obligations (eg AML) | Legal obligation | As required by law |
| Account Data, Transaction Data, Technical Data, Usage Data | Safety and security and operations | Legitimate interest | As necessary per regulation |
| Transaction Data | Business sale or transfer | Legitimate interest and legal obligation | As required |
If data is used for new purposes not compatible with the original, we will notify you.
Right to Withdraw Consent
You can withdraw consent for personal data processing anytime, e.g., by unsubscribing from marketing emails or opting out. Transactional or relationship messages may still be sent.
Retention of Your Personal Data
Data is retained only as long as required for its purpose, legal/regulatory obligations, or to defend legal claims. Generally, data is kept for six (6) years after relationship end, or longer if required.
Sharing and Disclosing Your Personal Data
Your data may be accessible to persons or companies contracted or employed by LYPTOEX, including financial institutions, lawyers, IT providers, marketing agencies, on a need-to-know basis.
We may share your data with government or law enforcement authorities when required by valid legal process or to prevent harm or illegal activity.
We may share personal data with affiliates, subsidiaries, business partners, subcontractors and third parties during transactions, restructuring, mergers or sales.
Other cases include:
- Service providers working on our behalf;
- Legal requests by authorities;
- Protection of rights or safety;
- With your consent or direction.
For US residents, sharing may occur under the US Patriot Act and FATCA regulations.
Aggregate or anonymized data may also be shared.
Data Storage and Security
We implement technical and organizational measures to protect your data against unauthorized access, loss, or damage. Access is limited to those with a business need and confidentiality duties.
However, no online system is totally secure; you accept inherent risks. We have breach notification procedures where required by law.
Transferring Your Information Outside UK/EEA
Your data is primarily stored and processed in the UK and EEA but may be transferred internationally with appropriate safeguards and protections.
Third Party Links
Our Website may include links to third party websites and services. We do not control those and recommend reading their privacy notices.
Your Rights
Depending on jurisdiction, you may have rights including:
- Access your personal data;
- Correction of inaccurate data;
- Erasure of data (with legal limitations);
- Object to legitimate interest processing;
- Restrict processing;
- Data portability;
- Withdraw consent.
We may request identity verification and may charge a fee if requests are excessive. We will comply within statutory timeframes.
To exercise rights or for questions, contact privacy@lyptoex.net.
Contact Us
If you have questions or concerns about this Privacy Policy or your data, please contact:
LYPTOEX Limited
Level 3 207 Regent Street
W1B 3HH, London
United Kingdom
Email: privacy@lyptoex.net
If not satisfied with our response, you may contact your local data protection authority. For UK residents, the Information Commissioner: https://ico.org.uk
We encourage you to contact us first for your concerns.
