LFE Privacy Statement

Last updated: January 9, 2018 

I.     Scope of this Privacy Statement

This Privacy Statement describes the types of personal information LFE Market Ltd , Inc. (“LFE,” “us,” “we” or “our”) collects through www.LFE.com and any affiliated LFE sites (collectively, the “Site”) and through your use of the services available on the Site (the “Services”), and how we collect, use, and share that information.

By providing your information and using the Site, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement.  The LFE Terms of Use to which you have agreed are to be read in connection with this Privacy Statement, as updated from time to time. If you do not agree with the terms of this Privacy Statement, please do not access, browse, or use the Site or its Services.

II.      What Personal Information do we Collect

A. Information You Give Us

We may collect certain information about you and your use of the Site through the use of tracking technologies or by other passive means.  You will also be asked to submit personal information or request information from us in order to use the Services offered through this Site.  Once you provide us with personal information about you, you are no longer anonymous to us.  This information may include:

• Registration Information: When you sign up to receive the Services, you may be required to provide information such as your name, address, phone number, email address, social security number, as well as residency information and sensitive financial documents, including without limitation bank statements, brokerage statements, asset statements, tax returns, and third party confirmation letters.
• Payment Information: In order to obtain the Services through the Site, you may be required to provide payment information in the form of bank account information, credit and/or debit card information, or a digital wallet compatible with Ethereum and/or Bitcoin and/or Ripple so that we may process the transaction, including without limitation the name of the wallet holder and wallet address.
• User Testimonials: You may choose to provide us with user testimonials. This information may be made public to users of the Site and other third parties.
• Additional Information: Additional information that you provide to us may include your investment information, feedback, messages, emails, and answers to surveys or questionnaires that you may submit, as well as any contact information you provide in order to receive updates from us.

B.  Location Information.

We may collect your physical location information if you use the Site on a location-enabled device (including GPS, cellular, and Wi-Fi networks) or from your browser.

C.  Automated Information Collection

Automated information collection includes “passively collected” information that is, but not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

• Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
• Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses.  We use this information to improve the quality of our Site and Services.
• Location Information. We may receive location data passed to us from location-enabled devices or that you have enabled, from your browser, or from third party services.
• URLs. When you visit or access the Site, we automatically receive the URL of the site from which you came and the site to which you are going when you leave the Site.  Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.
• Cookies. When you visit or access the Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser.  We use cookies to improve the quality of the Site by storing user preferences and tracking user trends.  Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent.  If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies.  Please note that if you disable cookies, you may not be able to use the Services nor certain customized features available through the Site.
• Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies.  We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site.  We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.
• Aggregate Information. We may compile certain personal information and other information collected through the Site on an aggregate basis.  This information may include, without limitation, the number of people who have visited the Site and other user demographics.  Such aggregate information does not identify you individually.

III.     How do We Use Personal Information?

Personal information collected through the Site may be used by us, our affiliates and third parties for purposes of:

• Completing required regulatory verifications for use of the Services through the Site;
• Managing your account and providing the Services through this Site;
• Responding to your questions and feedback;
• Contacting you, whether by email, postal mail, or telephone with information about this Site or our Services;
• For such purposes as you may authorize at the time you submit the information;
• Auditing, research, and analysis to maintain, protect, and improve this Site and our Services;
• Ensuring the technical functions of our network;
• Improving and customizing the content and layout of the Site;
• Tailoring advertisements to you;
• Developing new products and services; or
• Compiling personal information and other information collected through the Site on an aggregate basis.

IV.     How do we Share Personal Information?

 We may sell, rent, trade, or otherwise share personal information collected through the Site in the circumstances described below. Personal information may be transferred and/or accessed in countries outside the European Economic Area (EEA), including the United States.

• In Connection with the Services. Provision of the Services to you may require that we share certain personal information with third parties involved in the provision of Services.  Such third parties may include those that provide identity verification, website hosting, marketing, analytics and fulfillment services.
• Subsidiaries and Affiliates. We may share personal information with our subsidiaries, affiliates and third parties for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
• Consent. We may share personal information in accordance with any consent you provide.
• Required by Law. We may disclose personal information or any information collected through this Site if we are required to do so by law (g., for purposes of completing required verifications for provision of the Services to you) or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
• Certain Transactions. We may disclose or transfer personal information or any information collected through this Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us. 
• Internet Based Advertising. We may participate in Interest-based and behavioral advertising. This means that you may see advertising on the Site tailored to how you engage, browse or shop, or you may see advertising for us on other websites, applications and social media based on your behavior across websites, applications and social media.  We may target ads based on data we have collected, or data provided by third parties alone or in combination with the data we collect ourselves.  If you choose to interact with specific third parties who advertise through the Site, the information you provide to them is subject to the conditions of their specific privacy policies.

In connection with the foregoing activities, third parties, often called “ad servers” or “ad networks,” may place and access cookies, web beacons, or other tracking technology on your device to collect information about your use of the Site and your use of third-party sites. The information about your use of the Site may be combined with information about your use of third-party websites to provide targeted advertisements and content that may be of interest to you (this is known as “behavioral advertising”).  The information they collect from the Site may identify you personally, or they may associate it with personal information collected in other ways or received from other third parties.  We do not control these third parties or their use of cookies, web beacons, or other tracking technology.

By using the Site you agree to usage tracking and targeted, behavioral advertising.  If you do not wish to have cookies track your usage for these purposes please see the Section II.C of this Privacy Statement to refuse all or some browser cookies or do not use the Site.

V.     Aggregate Information

We may compile personal information and other information collected through the Site on an aggregate basis.  This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual preferences.  Such aggregate information does not identify you individually.  We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

VI.     Your Choices

A.  Information You Provide

You can always choose whether or not to provide information on the Site.  However, if you choose not to disclose certain information, you may not be able to receive the Services or access certain portions of the Site.

B.  Communications From Us

If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at support@londonfootballexchange.com

C.  Do Not Track

Our Site does not honor “do not track” signals or other mechanisms.  However, as described in more detail in Section II.C of this Privacy Statement, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.

VII.     Information Storage and Security

We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site.  These security measures include the following:

• All stored personal information is encrypted using IEncryption library, using 256-bit AES algorithms.
• Uploaded user documents used for investor status verification are encrypted for storage using 256-bit AES algorithms.
• Multi-tier server architecture is used to safeguard user data. The Web layer is located in a DMZ and a Web Application Firewall is used to isolate server infrastructure from internet-based attacks.
• We employ Secure Socket Layer (SSL) technology to secure and encrypt communications between the Site and web browsers.

However, no method of transmitting or storing data is completely secure.  As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site.  If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

VIII.    Minors

Children are not eligible to use the Site, and we ask that minors (children under the age of majority in the country in which they reside) not submit any personal information to us.

IX.    External Links

The Site may contain links to websites that we do not control.  When you click on one of these links, you will no longer be transacting business through the Site.  Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Site.  If you visit a website that is linked to the Site, you should consult that website's privacy policy before providing any personal information.  Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of your personal information.

X.    Data Protection Directive

The Site is currently hosted in the United Kingdom but that may change without notice to you. You have the right to obtain certain information about the processing of your personal data through a Subject Access Request (as defined in the Data Protection Act 1998). In circumstances where the processing of your personal data is not in compliance with applicable national data protection laws, you may also request rectification, erasure or blocking of your personal data. We shall not retain or process personal data for longer than is necessary. However, if the data is retained, we shall continue to retain personal data in accordance with any statutory or professional retention periods applicable in their respective countries and / or industry.

We shall only transfer the personal data to a third party by using secure methods. For the purposes of this clause, transfers of personal data shall mean any sharing of personal data by us with a third party, and shall include, but is not limited to, the following:

(a)  storing personal data on servers outside the EEA.

(b)  subcontracting the processing of personal data to data processors located outside the EEA.

(c)  granting third parties located outside the EEA access rights to the personal data.

XI.     Updates to this Privacy Statement

We may change or update the Site or any of our policies and procedures without prior notice.  We will post a notice on this Site to advise you of any significant changes to this Privacy Statement and indicate via the “Last Updated” legend at the top of this Privacy Statement when it was most recently updated.  Your continued use of the Site signifies your continued assent to the terms of this Privacy Statement, as updated or amended at that time.

XII.     Governing Law and Jurisdiction

You irrevocably agree that the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with this Agreement or its subject matter or formation, except that if you are a consumer and you are a resident of Northern Ireland, you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.

XIII.     Questions Regarding this Privacy Statement

If you have any questions or comments regarding this Privacy Statement, please send us an email at support@londonfootballexchange.com.