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We respect and value your privacy as well as the integrity of the information you have provided and/or permitted us to collect. Thus, we endeavor to follow industry standards to ensure the security and confidentiality of your Personal Information when you use Our Services or access Our Platform.
- Personal Information collected by Us
- How We collect Personal Information
- How We use Personal Information
- How We store Personal Information
- How long We retain Personal Information
- Sharing your Personal Information
- Third-Party Collection of Personal Information
- Your Legal Rights
- Rights of the residents of the European Economic Area (EEA)
- How to contact Launchpool
3. Personal Information that we collect
3.1. Information provided by you when registering with Launchpool
When you first sign up to use Our services by opening a Launchpool account, you may be required to provide us your real name, date of birth, nationality, home address, email address, signature, and other information which can be used to distinguish your identity.
Generally, we will not collect nor process "Sensitive Information" such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data that uniquely identify specific persons, or any information concerning health or sexual orientation. Thus, if you use biometric authentication methods to sign into your Launchpool account, you shall be required to provide Us your fingerprint data, facial recognition data, and, more importantly, explicit consent to process your biometric data.
3.2. Information collected by Us for compliance
Purposes In order to comply with domestic and international industry standards, government rules and regulations, particularly Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) rules, and Counter-Terrorist Financing (CTF) regulations, Launchpool is required to collect your Personal Information from identification documents such as your passport, national identification card, driver"s license, tax identification, and visa. Other documents We may use include, but are not limited to, your proof of the address, source of fund declaration, purpose and source of wealth etc.
3.3. Information collected by Us as you use Our Services
3.3.1. Usage Information
When you engage or use Our Services, we will monitor and track your information in relation to your usage of Launchpool Services such as your IP address, phone number, the type of device you use to access Our Platform, device information, operating system and hardware settings, browser type, and network operator. This information shall either be directly obtained by Launchpool or through third-party service providers.
We collect this type of information to ensure that our interface and/or Platform is seamlessly accessible for all users around the world.
3.3.2. Communication Information
You hereby agree that We are entitled to collect and use the Personal Information you have provided on our Platform or generated through your usage of Launchpool Services for the purpose of being able to communicate with you through messages, requests, emails, telephone conversions, voicemails, live chats, file attachments in connection with your transactions on Launchpool, or any other information related to your contact with Launchpool.
3.3.3. Financial Information
4. How we collect Personal Information
4.1. Information automatically collected by Us We will collect and process Personal Information automatically provided by you under the following situations:
4.1.1. when you register an account, log in, or visit the Launchpool Website;
4.1.2. when you voluntarily complete any user survey or provide feedback to us via emails or any other electronic channels;
4.1.3. when you use browser cookies or any other relevant software upon visiting the Launchpool Website; and
4.2. Information collected by the third-party
We shall collect your Personal Information from third parties as required or permitted to the extent of applicable laws. Information from the third-party sources shall include, but will not limited to, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
4.3. Anonymized and Aggregated Data
5. How We use Personal Information
Your Personal Information shall be made available to Launchpool , Our affiliates, and/or within Our group of companies. This will include, but not be limited to, the employees and/or any persons or third parties working for Launchpool who are responsible for using and protecting your Personal Information.
We use and process your Personal Information for the following purposes or in the following ways:
5.1. To provide Our Services
We use Personal information, either collected or delivered, in order to maintain and provide efficient Services (including, but not limited to, processing transactions), to improve the efficiency of day-to-day Services, and to verify your identity. We use IP addresses and unique identifiers stored in your device's cookies to help Us authenticate your identity and activities and provide Launchpool Services.
5.2. To protect users
We use the information collected to protect our Platforms, Users' accounts, and archives. We also use IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.
5.3. To comply with regulations and compliance For Our legitimate interests, We shall use the information in compliance with Our legal obligations, global and local industry standards, government requests, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e. to protect the vital interests of the users or other natural persons, to fulfil the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent.
5.4. For measurement, research and development purposes
We actively measure and analyze your information to understand the way you use and interact with Launchpool Services. This review is continuously conducted by Our operation teams to continuously improve Our Platforms' performance and to resolve issues with user experience. In addition, We use such information to customize, measure, and improve Our Services, Our administration, the content and layout of the Launchpool Website, and to develop new services for you.
5.5. For communication purposes
5.6. To enforce T&Cs
Personal Information is also used to continuously and actively enforce our T&Cs among Our users. Activities in this regard include, but are not limited to, reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, We reserve the right to suspend or terminate any Launchpool Services to any Users found to be engaged in any activities that violate our T&Cs.
5.7. For marketing and advertising
We will share your Personal Information with Our marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising.
5.8. For Rebates
We shall share the Personal Information collected from you, including, but not limited to, your Identification Information and Transaction Information, with your referrer for the purposes of rebates and other benefits.
5.9. For other purposes
6. How we store Personal Information
We shall take great care in implementing and maintaining the security of Launchpool ’s Services as well as that of your Personal Information. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Information and to prevent instances of unauthorized use.
Please note that it is impossible to fully guarantee the security of your Personal Information. While we take reasonable steps to safeguard your Personal Information, we shall not hold any responsibility for the acts committed by those who gain unauthorized access or abuse your information and services. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such as your username and password. You hereby agree that we shall not be liable for any information leakage and other losses not caused by our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.
7. How long We retain Personal Information
We shall be required by applicable laws and regulatory requirements to retain certain information, including Personal Information of users, users' profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between Us and third-parties, account statements, and other records.
Such records shall generally be retained as required by law for the minimum amount of time necessary to accomplish the purpose for which it is collected; and thereafter no longer than is permitted under Launchpool "s information retention policy.
However, even after you deactivate your account, We may retain copies of information about you and any transactions or services which you may have participated in for a period of time that is consistent with applicable laws, the applicable statute of limitations or as we believe is reasonably necessary to comply with applicable laws, regulations, legal procedures, or governmental requests in order to detect or prevent fraud, collect fees owed, resolve disputes, address problems with Our Services, assist with investigations, enforce any of Our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable laws.
A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our Website shall use the following types of cookies:
8.1. Strictly Necessary Cookies
These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. We shall not need to obtain your consent in order to use these cookies.
8.2. Functionality Cookies
These cookies allow the Website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.
8.3. Performance cookies
These cookies collect information about how you use a website, for example, which pages you go to most often, record difficulties you may experience while using the Website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the Website.
8.4. Targeting Cookies or Advertising Cookies
These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies shall be linked to the sites" functionality provided by the other organizations.
You may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of Launchpool Services may not operate properly, and your online experience may be limited.
9. Sharing your Personal Information
We shall not rent, sell, or disclose your Personal Information to any third parties, except to those who require access to the information to perform their tasks and duties and to share with third parties who have a legitimate purpose for accessing it.
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
9.1. We may disclose Personal Information to the third parties in order to administer or process a transaction, or Services you have authorized or requested, or in the context of facilitating the execution of a transaction.
9.2. We shall be required to validate your identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal Information that you provide to Us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter.
9.3. We provide Personal Information that you provide during the account opening process, as required by applicable laws and regulatory requirements, to carry out or aid in certain functions, such as, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination.
9.4. We share your information with financial institutions with which we partner to process payments which you have authorized.
9.5. We may share analyses based on anonymous user information or behavior with Our affiliate companies in order to operate and improve products and services.
9.6. We may disclose or transfer information We collect to a purchaser of our business.
9.7. We may disclose or transfer information we collect upon account closing where you have a deficient balance, or upon excessive instances where you do not have sufficient funds in your account.
9.9. We may disclose Personal Information to third parties that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services.
9.10. We may share your information with law enforcement, and government officials, or other third parties when We are compelled to do so by a subpoena, court order, or similar legal procedure, or when We believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of Our terms and conditions or any other applicable policies.
9.11. We may disclose information to third parties about your account or the transactions you make if you give Us your written permission.
9.12. Other circumstances under which We may disclose your Personal Information include but is not limited to the following:
9.12.1. comply, as necessary, with applicable laws and regulatory requirements;
9.12.2. respond to mandatory legal or governmental requests or demands for information;
9.12.3. meet national security requirements;
9.12.4. enforce Our agreements, policies, procedures and/or T&C"s;
9.12.5. protect ourselves, our affiliates, Our users, Our counterparties or the general public from illegal activities; and
10. Third-Party Collection of Personal Information
11. Your Legal Rights
Under certain circumstances, you have the rights under the data protection laws in relation to your Personal Information. These rights include the followings:
11.1. Right to be informed
You reserve the right to be informed about the collection, use, and process of your Personal Information.
11.2. Right of access
You reserve the right to make a request for a copy of the Personal Information We hold about you and specific information regarding Our processing of this information.
11.3. Right to rectify
You reserve the right to request Us to update, correct, or complete your Personal Information that you believe to be outdated, inaccurate, or incomplete. You shall rectify at any time by signing into your Launchpool account and clicking the Profile.
11.4. Right to erasure
You may request to have your Personal Information deleted from Our record where certain conditions are met.
11.5. Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We shall provide you, or the third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented Us to use.
11.6. Right to restrict processing
You may request Us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
11.6.1. to establish the accuracy of the Personal Information;
11.6.2. when the processing is considered unlawful, but you do not wish to have your Personal Information erased;
11.6.3. where We no longer need to process your Personal Information, but the information must be retained for legal reasons; and
11.6.4. where you have objected to Our processing your Personal Information, but We need to determine whether Our legitimate interest overrides your objection.
11.7. Right to object
You may object to our reliance on our legitimate interests as the basis of Our processing of your Personal Information that impacts your rights. You may also object to Our process of your Personal Information for direct marketing purposes.
11.8. Right to withdraw consent ("Opt-out") You reserve the right to withdraw your consent at any time where We are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of Our processing of your Personal Information prior to withdrawing. If you wish to exercise these rights as aforementioned, please inform and contact Us via our Platform, including Launchpool website.
12. Rights of the residents of the European Economic Area (EEA)
If you are a resident of the European Economic Area, United Kingdom, or Switzerland at the time your Personal Information is collected, you still reserve every legal right as stipulated in Clause 10 as mentioned above. Also, We shall specifically apply legal requirements under the General Data Protection Regulation (GDPR) for collecting, using, or processing your Personal Information.
In the case where some recipients are located outside the EEA, We shall transfer your Personal Information only to such countries as approved by the European Commission as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information.
13.1. Our Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using Our Services.
If you are not over 18 or of the legal age of your country, you shall not provide any Personal Information to Us, or to engage in our Services. We reserve the right to access and verify any Personal Information collected from you. If We are aware that you are under 18 or under the legal age who already shared your Personal Information with Us, we shall then discard such information and terminate your account immediately.
13.2. We cannot guarantee that any losses, misuses, unauthorized accession, or alteration of your Personal Information shall not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials. When registering with Our Services, you are strongly recommended to choose a password with sufficient length and complexity and to not reveal this password to any third parties, or unauthorized persons. Also, you agree that you shall immediately notify Us if you become aware that unauthorized persons access your Launchpool account.
15. How to contact Launchpool