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Privacy Policy

Privacy Policy

Last updated: June 6, 2023
This Privacy Policy (“this Policy”) governs the access to and use of all parts of the website and mobile application branded as LYOTRADE and referring to the domain https://www.lyotrade.com/en_US/ (hereinafter referred to as the "‘Platform’, ‘LYOTRADE’, ‘us’, ‘we’, ‘our’) and all documents, data, materials or other information made available on the website.
This Policy applies to all users (hereinafter referred to as the ‘User(s)’, ‘you’, your’ or ‘yours’)., and others who access or use our Platform
Please take a moment to read this Privacy Policy, the Cookies Policy along with the Terms and Conditions carefully, and note that by using the Platform, you consent to the collection, storage, processing, and transfer of your personal information as described in this Policy.
  1. 1.
    PURPOSE
Your privacy is very important to us. We are committed to protecting and respecting your personal data. This Privacy Policy describes what types of personal data we collect about you when you choose to use our services, how we will use your personal data, when and with whom we share it and how we will keep it safe. It also details your rights with respect to our processing of your personal information and how you may exercise them. DEFINITIONS
1.1. Data subject” means a person who owns the personal data protected by the Law, or their representative.
1.2. “User(s)” means a Data subject who has attained the age of eighteen (18) with legal capacity and/or any legal entity who successfully creates an account in the Platform and has duly completed the Know Your Client (“KYC”) verification process.
1.3. “Personal data” means any information that relates to an identified or identifiable living individual, including sensitive personal data.
1.4. “Sensitive personal data” means any information concerning sensitive information of a person, that may not be stored except in very specific circumstances. This includes personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, spiritual convictions, socioeconomic condition, biomedical or genetic information, health, sex life, and sexual orientation.
1.5. “Data processor” means any individual or legal entity, public or private, or any other body that may process the Personal data on behalf of the responsible party. As per this Policy, LYOTRADE shall be considered as the Data Processor.
1.6. “Data controller” is the 'person responsible for the database' is the individual or legal entity that administers, manages, or is responsible for the database, whether it is a public or private entity, competent to do so, in accordance with the Law, and it decides on the purpose of the database, which categories of personal data will be processed, and the type of processing. The Money Laundering Reporting Officer (MLRO) of LYOTRADE shall be considered as the Data Controller.
1.7. “PEP” means a Politically Exposed Person refers to a natural person (and includes where relevant, a family member or close associate) who is or has been entrusted with a prominent public function, including but not limited to, a head of state or government, senior government or an important political party official.
1.8. “UBO” means an Ultimate Beneficial Owner is the natural person who ultimately owns or controls the User, or the person on whose behalf a relevant transaction is conducted, and includes the person who exercises ultimate effective control over a body who ultimately has a controlling ownership interest in the User.
1.9. “Authorized Person of the Entity” means any natural person appointed by the entity under a letter of authorization to (a)sign in, (b) open an account and (c) to carry out transactions in our Platform.
1.10. “Consent” means an express, freely given, unequivocal, informed, and specific manifestation from the data subject, granted in writing or in digital form, for a specific purpose, by which the data subject, or their representative, consents to the processing of their Personal data.
  1. 2.
    CONSENT
2.1. By using our Platform, you expressly Consent to the collection, processing, storage, and transfer of your personal information in accordance with this Policy. You acknowledge that you have read and understood the terms of this Policy and voluntarily provide your consent for the aforementioned activities of the Platform. Furthermore, you agree that your continued use of our Platform signifies your ongoing Consent to any updates or modifications made to this Policy, which will be effective upon posting on our Platform. If you do not agree with any aspect of this Policy, please refrain from using our Platform.
2.2. If you do not agree or Consent to the terms outlined in this Policy, you have the right to withdraw your Consent at any time. In such cases, please discontinue accessing or using our services. Please note that the withdrawal of Consent does not affect the legality of any processing that occurred prior to the withdrawal. To withdraw your Consent, please contact us immediately.
  1. 3.
    THE PERSONAL DATA LYOTRADE COLLECTS FROM USERS
3.1. Your Personal data is collected and stored on our Platform with the sole purpose of providing, developing, and improving our products and services. This includes activities such as managing technical infrastructure, ensuring security measures, complying with legal and regulatory requirements, preventing fraudulent activities, and offering customer support. The collection and storage of your Personal data are essential for the effective delivery of our services and enhancing your User experience.
3.2. We are dedicated to exercising due diligence during the onboarding process of Users to our Platform and throughout our business operations. It is our utmost priority to comply with all applicable laws and regulations that mandate us to prevent the facilitation of money laundering and terrorist financing activities. We maintain stringent measures to ensure compliance with these obligations, employing robust systems and processes to detect, prevent, and report any suspicious transactions or activities that may pose a risk of money laundering or terrorist financing. By adhering to these standards, we aim to contribute to the overall integrity of the financial system and maintain a secure and trustworthy environment for our Users.
3.3. We collect Users’ information according to the different tier levels, where each tier corresponds to the amount of KYC verifications undergone by each User in the onboarding process.
3.4. The Personal data we collect from our Users are;
(a) If Retail Users;
  1. 1.
    Name, Surname
  2. 2.
    Date of birth and gender
  3. 3.
    Email Address
  4. 4.
    Residence Address
  5. 5.
    Nationality
  6. 6.
    Country Code
  7. 7.
    Mobile number
  8. 8.
    Profession and employment details
  9. 9.
    Net worth
  10. 10.
    Income
  11. 11.
    National Identity Card
  12. 12.
    Driving License
  13. 13.
    Passport details
  14. 14.
    Proof of Residences
  15. 15.
    Salary Certificate
  16. 16.
    Information about your income and wealth including details about your assets and liabilities (Source of funds), account balances, trading statements, tax and financial statements
  17. 17.
    Sanction & PEP questionnaire
  18. 18.
    Audio or video recordings
  19. 19.
    Wallet Address
  20. 20.
    Transaction details
(b) If Corporate Users;
  1. 1.
    Company name
  2. 2.
    Country of Incorporation
  3. 3.
    Country of Operation
  4. 4.
    Details of the Authorized Person of the Entity
  5. 5.
    UBO Details and Proof of address
  6. 6.
    A copy of Certificate of Incorporation
  7. 7.
    Certificate of Incumbency
  8. 8.
    Shareholder Registry
  9. 9.
    Director Registry
  10. 10.
    General information about nature of business
  11. 11.
    Corporate Expected Trading volume (per week)
  12. 12.
    Source of Funds Verification documents
  13. 13.
    A letter of authorization issued to individual performing on behalf of entity
  14. 14.
    PEP and Sanction Questionnaire
  15. 15.
    Passport copies of all directors & Shareholders
  16. 16.
    Memorandum of Association
  17. 17.
    Article of Association
  18. 18.
    Registered Address
  19. 19.
    Audited financial Statement
  20. 20.
    Audio or video recordings (authorized person/ director/shareholder)
  21. 21.
    Wallet Address
  22. 22.
    Transaction Details
(c) Automated information stored by the Platform are;
  1. 1.
    Browser Information
a. IP Address
b. Login information
c. Browser type and version
d. Time zone setting
e. Operating System
f. Transaction history
g. Pages accessed and links clicked
h. Public blockchain data
  1. 2.
    Log information
a. Device- specific information
b. Location
c. System activity
d. Uniform Resource Locators [URL]
e. Data collected via Cookies [you can find out more about our cookies on our “Cookies Policy” available on our Platform]
(d) We also keep records of your trading behavior, including a record of:
  1. 1.
    Trade history
  2. 2.
    Virtual Assets you trade on our Platform
  3. 3.
    Data related to the trades and investments you have made, including the amount invested
  4. 4.
    Visa/Debit card details (as if applicable)
  1. 4.
    PROCESSING AND HANDLING OF PERSONAL DATA
4.1. To communicate with Users: We engage in communication with our Users through various channels to effectively operate our business. Primarily, we utilize social media platforms and emails as means of communication. These channels serve the purpose of sharing important information about our products and services, as well as notifying Users about any reward programs or referral programs that may be available. Our aim is to keep our Users informed and engaged, ensuring they are up-to-date with the latest developments and opportunities within our offerings.
4.2. To comply with legal and AML compliance: In instances where internal AML compliance requirements dictate, during the onboarding process of Users to our Platform, if we identify a User's profile as significant concerns relates to financial crimes and/or associated with credible adverse media, we may deem it necessary to obtain additional information. Such information may include employment details, proof of funds, proof of residence, or, in circumstances where the adverse media pertains to the User's criminal history, we may request a police clearance letter. These measures are implemented to ensure enhanced due diligence and mitigate potential risks related to money laundering or other financial related crimes. By conducting these additional checks, we aim to maintain the integrity and security of our Platform and provide a safe environment for our Users.
4.3. To detect and prevent fraud risks: We maintain a steadfast commitment to adhering to anti-money laundering and combating terrorist financing (AML/CFT) laws, as well as stringent anti-fraud prevention measures. As part of our ongoing transaction monitoring on our Platform, we diligently identify and investigate any instances of fraudulent or suspicious transactional activities to proactively prevent and mitigate fraudulent acts. In such cases, it may be necessary for us to request additional supporting documents or evidence from our Users to facilitate our investigation process and reach a conclusive resolution. These measures are implemented to safeguard the integrity of our operations, protect our Users, and uphold the highest standards of security and compliance.
4.4. To provide, troubleshoot, and improve our services: We acknowledge that Users may encounter challenges related to KYC, transaction related quarries, or technical issues while using our Platform. To address and resolve these concerns efficiently, we have implemented a systematic approach. We prioritize effective communication with our Users and have introduced a ticketing system that enables real-time resolution of their issues. This system allows users to submit their concerns or queries, ensuring that their issues are promptly addressed by our dedicated support team. We are committed to providing a seamless user experience and strive to assist users in overcoming any obstacles they may encounter while utilizing our services.
4.5. To enforce our terms in our User agreement (“Terms and Conditions”): User agreement is an essential primary document that stipulates the terms and conditions applicable to our Platform and sets out the rules (within applicable law) of how our services or products may be used, including but not limited to things like copyright conditions, age limits, and the governing law of the agreement. Our primary objective is to safeguard the interests of both our business and our Users throughout their engagement with our Platform. To ensure clear communication of these interests, we enforce our terms and conditions through the User Agreement.
4.6. To provide customer services: We ensure to build a strong relationship with our Users to understand their issues while using our Platform and to assist them by listening and clarifying questions if they do not understand any of our Platform’s operations. To achieve this, we prioritize effective communication with our Users. We actively listen to their feedback and questions, taking the time to clarify any uncertainties they may have regarding the operations of our Platform. We have established a dedicated customer support team that utilizes a ticketing system. This system enables Users to submit their complaints, allowing us to promptly address and resolve any disputes or issues they may encounter. Our customer support team is committed to handling these matters in a professional and amicable manner, ensuring that our Users receive the assistance they require
4.7. To ensure quality control: We emphasize quality control programs to ensure the delivery of proper, consistent products and services and a seamless user experience on our Platform. In the event that any of our Users encounter issues, we are committed to providing prompt and effective responses. For this purpose, we engage in regular communication with our Users, and we obtain valuable insights that enable us to identify areas for improvement and enhance the quality of our offerings.
4.8. To ensure network and information security: Network security and information security encompass all the steps taken to protect the integrity of a computer network and the data within it. We strictly ensure that the Personal data of the Users are safe from cyber-attacks and that the network is usable and trustworthy. We have employed multiple security solutions to protect the Users’ Personal data and our Platform from malware and cyber-attacks. In order to ensure the highest level of security, we may require our Users to provide us with access to certain cookies. These cookies play a vital role in enhancing the security of our Platform and enabling us to deliver a seamless User experience.
4.9. To enhance and personalize User experience: We believe in providing our targeted audience and Users with a virtual asset centralized exchange platform that caters to their specific needs and preferences. We aim to anticipate and fulfill their requirements even before they make specific requests. This personalized approach aims to streamline the User experience, saving their time and effort while enhancing their overall satisfaction with our technology. We strongly believe that by actively seeking and valuing our User feedback, we can continually enhance the User experience, provide tailored services, and maintain high levels of User satisfaction on our platform.
4.10. To facilitate virtual asset transactions: We provide services of Crypto- Crypto, Crypto – Fiat, Fiat to Crypto transactions on our Platform. In order to facilitate such virtual asset transactions, we may communicate with Users. To ensure smooth and efficient processing of these transactions, we may engage in communication with our Users. This communication allows us to facilitate and assist our Users throughout the transaction process, ensuring a seamless experience.
4.11. To engage in marketing activities: Marketing allows us to identify and target highly highly-specific with personalized and high-converting marketing messages. Through strategic marketing activities, we aim to foster continuous growth and attract qualified traffic that demonstrates genuine interest in our business. We engage with digital marketing via social media platforms. By employing digital marketing strategies, we aim to drive awareness, generate leads, and cultivate a strong brand presence that attracts Users who are genuinely interested in what we have to offer.
4.12. Purposes for which we seek User’s Consent: We acknowledge that the Users have the legal right to grant and/or withdraw their Consent to the disclosure of their Personal data. We may communicate with the User via User Terms and Conditions to obtain their consent. In the event of withdrawal of the Consent, the User is requested to contact us via our support team and exercise their legal right of withdrawal. Simultaneously, we obtain Sensitive personal data, only with the Users’ explicit consent in certain exceptional circumstances where such processing is required only for the purpose for which the consent was given by the User. For instance, during the KYC verification process, if we encounter adverse media which reflects that the User is engaged or suspected with predicate offenses as theft, terrorism activities, money laundering, and/or murder which may reasonably assumed that the User is under such criminal convictions or alleged commission of any offence, we may specifically communicate with the User and obtain further information such as a police clearance certificate.
  1. 5.
    DISCLOSURE OF PERSONAL INFORMATION
We may share your Personal data with our direct and indirect affiliates as well as selected third parties located outside the Republic of Costa Rica, such as business suppliers, distributors, and subcontractors. This disclosure is necessary to facilitate the delivery of our services or when there is a legal basis to do so. However, it is important to note that these third parties are only authorized to collect, use, and disclose your information in accordance with our instructions and for the purpose of providing the necessary services.
We strive to ensure that any third parties with whom we share your Personal data adhere to appropriate safeguards and security measures to protect your information. Furthermore, we only collaborate with trusted partners who have demonstrated their commitment to data privacy and security. By sharing your Personal data with these parties, we aim to ensure the efficient provision of our services and maintain compliance with applicable legal obligations.
We further ensure that we comply with the applicable data protection legal norms, and we shall only share information in the following circumstances:
5.1. With applicable regulatory bodies of the Republic of Costa Rica. In the event of suspicious activities or transactions, such as instances of fraud, tax, money laundering, or terrorist financing activities, we are obliged to share the User’s personal information with the applicable regulatory bodies if necessary and with due consideration for privacy and data protection. This action is taken if deemed necessary to fulfill our legal obligations and contribute to the prevention and detection of unlawful activities.
5.2. As a general part of conducting our business and to offer comprehensive services, we may share your Personal data with our affiliates and business partners. By sharing your Personal data and partnering with trusted affiliates and business partners, we aim to enhance the overall quality and scope of the services we offer. These entities may assist us in various aspects of our operations, such as customer support, marketing, technology infrastructure, and service delivery as applicable. When sharing your Personal data with our affiliates and business partners, we do so in compliance with applicable data protection laws and regulations. We take measures to ensure that they handle your Personal data responsibly and in accordance with our instructions and policies.
5.3. With third party KYC/AML service providers of our Platform to identity verification services in User onboarding process. Our Platform intends to uphold and implement the strictest standards of compliance, security and transparency in its operation, starting with detailed onboarding verification process, therefore we acquire the User’s Personal data via third party KYC/AML service providers to provide streamlined verification process for individuals and companies with global coverage, configurable verification rules, detailed and case management tools along with PEP database screening, sanction crime screening, legality of assets verification and due diligence services.
5.4. With third party Know Your Transaction (KYT) service providers and other external service providers who provide the custody of funds on the Platform. During the process of ongoing transaction monitoring, we ensure that the transaction monitoring system traces the nature of the virtual asset wallet to which each of our Users is sending to or receiving from. By collaborating with trusted third-party KYT service providers and external service providers, we aim to enhance the effectiveness of our transaction monitoring efforts and ensure the integrity of our Platform. The information shared with these parties is done so with strict adherence to applicable privacy and data protection regulations.
5.5. With service providers under contracts to operate the business. - When engaging with outsourced service providers located outside of the Republic of Costa Rica, we ensure that we transfer only the minimum amount of data necessary for the specific services being provided. We maintain a strict selection process and only collaborate with outsourced service providers who can provide an adequate level of personal data protection. We share your Personal data with the followings;
5.5.1. Cloud storage
5.5.2. Payment process
5.5.3. Network Infrastructure
5.5.4. Security
5.5.5. Customer Support
5.5.6. Marketing
5.5.7. Data analytics
5.6. We may share your Personal data with financial institutions with whom we have partnered to process payments that you have authorized. This includes collaborations with recognized entities such as Visa and debit cards issued by banking authorities. These collaborations enable us to offer a variety of payment options and enhance the convenience and accessibility of our services.
  1. 6.
    PROTECTION AND STORAGE OF PERSONAL DATA
6.1. LYOTRADE maintains physical, technical, administrative, and procedural safeguards in connection with the collection, storage, and disclosure of a User’s Personal data. We use firewall barriers, encryption techniques, and authentication procedures to maintain the security of User’s online sessions.
6.2. To enhance the security of your account and protect it from unauthorized access, we have implemented a two-factor authentication system using One-Time Passwords (OTPs). This system is designed to provide an additional layer of verification when you sign in to your account from different devices. When you attempt to sign in to your account on a new device, our OTP system will generate a unique and time-limited code that will be sent to your registered contact information, such as your mobile phone number or email address. You will then be required to enter this code during the login process as part of the two-factor authentication. We aim to ensure that only authorized individuals with access to your registered contact information can successfully sign in to your account from different devices. This additional layer of security helps to protect your account and safeguard your personal data from potential unauthorized access.
6.3. In the event of unauthorized access or any suspicious activity related to your LYOTRADE account, we strongly urge you to notify our customer support team immediately. Your account security is of the utmost importance to us, and prompt reporting of any unauthorized access helps us take immediate action to protect your account and investigate the incident.
6.4. The Data controller shall be responsible for processing and storing the Personal data of the Users. The Data Controller may conduct a KYC screening provided by an external AML/KYC service provider, during the onboarding process in the Platform. In the event that we require additional information from our Users, such as supporting documents or verification materials, we ensure that these documents are securely stored by the Data Controller. These documents are kept on file in a readily retrievable format to facilitate efficient access and retrieval when necessary.
6.5. As a Data controller, we shall ensure that for the purposes of protecting the Personal data from any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. To fulfill this commitment, we require our Data Processor to provide sufficient guarantees in terms of the technical and organizational security measures governing the processing of your data. Our Data Processor shall be responsible for handling and processing your Personal data on our behalf. We have implemented measures to ensure that our Data Processor maintains a high level of security and adheres to strict data protection requirements. Please be aware that these security measures include, but are not limited to, encryption, access controls, firewalls, regular security assessments, and staff training on data protection best practices.
  1. 7.
    DATA RETENTION
7.1. As per the applicable laws of the Republic of Costa Rica, we are required to retain the original or a true copy of all KYC/KYT related documents, data, or any other relevant documents and information provided by our Users for a period of more than ten (10) years after the conclusion of the purpose for which the data was initially collected. Please be aware that, if applicable, even after the expiration of this retention period, we may retain your Personal data only after completing an anonymization process.
7.2. In addition to the retention period mentioned in 8.1, information or data collected through technical means, such as cookies, web page counters, and other analytics tools, is retained for a period of up to one year from the expiration of the Cookie policy. These technical means allow us to collect and analyze data to improve the functionality and performance of our Platform, enhance User experience, and provide personalized content and services. However, it is important to note that this data is collected and stored in an aggregated and anonymized format, ensuring that it cannot be linked back to any individual User.
  1. 8.
    DISCLAIMER
8.1. We prioritize the protection of your Personal data and take appropriate measures to ensure its confidentiality and security within our network domain. However, it is important to note that we cannot guarantee the confidentiality and security of your Personal data transmitted via email, phone, SMS, or other wireless communication until it reaches our network domain.
8.2. During the transmission of data via these communication channels, there may be inherent risks associated with interception, corruption, loss, destruction, late delivery, incompleteness, or the presence of viruses or other harmful material. Therefore, we advise our Users to exercise caution and take necessary precautions when transmitting personal data through such channels. Also, it is the responsibility of the User to check their emails and any attachments for the presence of viruses or other harmful material. We shall not be held liable for any damages caused by viruses, malware, or otherwise harmful material transmitted through email or other wireless communication.
  1. 9.
    YOUR RIGHTS UNDER COSTA RICAN LAW
9.1. We ensure the applicability of the data protection framework of Costa Rica. Specifically, the legislation of the “Law on the Protection of the Individual in Relation to the Processing of Personal Data” where Data Subjects are granted various rights regarding the processing of their Personal data. These rights include:
9.1.1. Right to access: Data Subjects have the right to request access to their Personal data held by the Data controller. The Data Subject has the right, within five (5) working days after submitting a request and free of charge. This right includes the possibility to receive an accurate report of the Personal data being processed and the possibility of receiving extensive information, in writing (whether digitally or physically), concerning all the data being processed, as long as this does not affect third party rights.
9.1.2. Right of rectification: This right enables you to exercise this right if your Personal data processed by us is incomplete, incorrect, misleading or excessive or not relevant to the purpose for which the Document is held, you may request us in writing to amend such information. Regarding the right of rectification raised by citizens or owners of the Personal data, the person in charge of that data shall have a period of five (5) business days to make the requested correction. In the event that it has not been corrected or it is not appropriate to correct it, we may respond to the interested party in those terms within the same period.
9.1.3. Right to erasure
This right enables you to request, at any time, the deletion of your Personal data. Upon your request, we shall delete or remove your Personal data where there is no good reason for us to continue to process it. Please, as the Data controller we may refuse such requests if the data should be maintained in order to comply with other laws; the data is needed for security reasons or for the prevention or investigation of any crime; the data is maintained for adequate provision of a public service; the data is unrestricted Personal data, obtained from sources of general public access; and the Personal data was anonymized.
  1. 10.
    GENERAL DATA PROTECTIONS REGULATIONS OF EU
10.1. We fully recognize and adhere to the principles and requirements outlined in the General Data Protection Regulation (GDPR) as well as the specific data protection regulations applicable in Costa Rica. We understand that the GDPR is a regulation enacted by the European Union (EU) and is primarily applicable to EU member states. However, the GDPR may also apply to organizations outside the EU if they process Personal data of individuals within the EU in certain circumstances.
10.2. General Rights Applicable to EU Users, including the Right to Access, Rectification, and Erasure of Personal Data as outlined in Clause 10 of this Policy EU Users shall be entitled to exercise their rights as provided under the applicable data protection laws, including but not limited to the GDPR. These rights include:
10.2.1. Right to information: Data Subjects may have the right to be informed about the processing of their Personal data, including the purpose of processing, the categories of data being processed, and the identity of the Data controller.
10.2.2. Request to Restrict Processing: This enables you to object in writing to the processing of your Personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the Users, exercise or defense of legal claims. We shall comply with your request and we shall notify you in writing within three (3) days after receiving such notice of request of restriction.
10.2.3. Request to Object Processing: You have the right to object to the 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. You also have the right to object where we are processing your Personal data for direct marketing purposes.
10.2.4. Right to data portability: The Data Subject has the right to receive his/her Personal data in a structured, commonly used, and machine-readable format from the Data controller. Also, Data Subject shall have the right to transmit this data to another controller without any obstacles from the original controller, provided that the processing is based on consent or a contract, and the processing is done through automated means. When exercising the right to data portability, the data subject can request that their Personal data be directly transmitted from one controller to another, if technically feasible.
10.2.5. Right not to be subject to automated decision-making: The Data Subject has the right not to be subject to a decision that is solely based on automated processing, including profiling, if it has legal effects on them or significantly affects them in a similar manner. However, this right does not apply in situations where the decision is necessary for entering into or performing a contract between the Data Subject and the Data controller, authorized by applicable laws that safeguard the Data Subject's rights and interests, or based on the explicit consent of the Data Subject.
  1. 11.
    PRIVACY TERMS IN USING VIRTUAL ASSETS AND BLOCKCHAIN
The virtual assets are recorded on a public blockchain. The blockchain is a public ledger, which means a chain of blocks where each block contains the recording of any data transmission. Any information entered onto the blockchain cannot be deleted, or modified. Blockchains are decentralized or third-party networks which are not controlled or operated by any third-party service provider or affiliates or business partners of LYOTRADE, and any data that is published on a blockchain is considered public, and therefore it is considered to be outside the scope of this Policy. We have no access to or authority to erase, modify, or alter any Personal data from such networks. By using our Platform and services, you acknowledge and accept these risks associated with storing information on a public blockchain, and you agree that we shall not be liable for any damages or losses arising from any such breaches or the public nature of the blockchain.
  1. 12.
    MODIFICATIONS
We retain the right, at our discretion, to modify, amend, or replace this Policy at any time. Any updates or changes to the Policy will be prominently displayed at the top of the Privacy Policy page on the Platform. We will periodically review and revise this Policy as necessary to ensure compliance with applicable statutory and legal requirements. The determination of what constitutes a material change will be made solely by us. We will inform our Users of all material amendments to this Policy by publishing the updated version of this Policy on our Platform. When an updated version of the Policy is released, your continued access to the Platform means that you agree to the updated content and agree to abide by the updated Policy.
  1. 13.
    CONTACT INFORMATION
In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns to [email protected].