Lescovex Privacy Policy

Lescovex Privacy Policy

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Lescovex Privacy Policy

Title of the document
Document Style:

PolicyFile Name:

Lescovex Privacy Policy

Version:

1.4

Status:

Final

Date:

13/May/2021

History of changes
Version:Date:

Description of the action:

Pages:

1

27/May/2018

Creation of the document

24

1.1

04/Jun/2018

Document update

17

1.2

12/Sep/2018

Document update

17

1.3

04/Jan/2021

Document update

17

1.4

13/May/2021

Document update

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TABLE OF CONTENTS

1.

INTRODUCTION ................................................................................................................. 42.

Important notice ................................................................................................................ 5

3.

WHAT PERSONAL DATA WE COLLECT AND HOW WE DO IT ................................... 6

4.

WHO IS RESPONSIBLE (CONTROLLER) FOR THE PROCESSINGOF YOURPERSONAL DATA ....................................................................................................................... 85.

HOW WE USE YOUR PERSONAL DATA ......................................................................... 96.

HOW WE SHARE AND STORE YOUR INFORMATION ................................................ 117.

HOW WE PROTECT YOUR INFORMATION .................................................................. 138.

HOW LONG WE ARE GOING TO KEEP YOUR PERSONAl DATA FOR ..................... 149.

LEGAL BASIS ...................................................................................................................... 15

10.

YOUR RIGHTS ................................................................................................................16

11.

HOW TO CONTACT US .................................................................................................... 17

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1. INTRODUCTION
The following Privacy Policy describes the way in which LESCOVEX PANAMA, INC.
(hereinafter “Lescovex” or “us”, which refers not only to the company but also to its
shareholders, directors, employees, investors or other related parties), collects,
processes, preserves and uses the Personal Data obtained from you (“User” or“Customer”) either through the website www.lescovex.com (“website” or “platform”)
or through any of the applications by which Lescovex’s Services might be provided.
By “Personal Data” we are referring to any information by which we can identify you
directly or indirectly or by which we can contact you, such as name, address, email,trading information, etc. This privacy policy covers all the personal data that you
voluntarily provide us with and the data we obtain from any of our partners or public
sources. Iinformation by means of which the customer cannot be identified will not
be considered Personal Data.
This privacy policy may change without prior notice in order to adapt it to new
regulations or technological advances, as well as due to any other cause which may
create a need to modify it. These changes will be published directly on the website,
indicating in the header of the privacy policy the date of its last update, being fromthat moment applicable the new version that will repeal the previous one. Whenrequired by law, we will send you the new version so that you can be aware of themodifications introduced.

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2.

Important noticeBusiness Purpose: The Company shall have as its main purpose the operating of a
SWAP platform based on blockchain technology in which different goods may beexchanged, as set forth on the website: www.lescovex.com.
All FIAT-based deposits (such as $, €... understood as: Fiat money, in short, whose
value does not derive from the fact of being a physical good or merchandise, butfrom being issued and backed by a government.) will be carried out by the bank ofeach client so by a third party. In this sense, the responsibility to identify and check
the AML will be made at the origin at the time of making the transfer from the FIAT
customer’s account to Lescovex.
If in this document there is any discrepancy related to the identification of the clients,
the present writing prevails:
Lescovex will identify its clients in specific cases and / or under suspicious behavior,
it is in this sense that Lescovex can identify by claiming information from its clients,
checking with Black lists and performing video identifications if necessary andclaiming all the necessary information.
In that sense and as mentioned, Lescovex is a platform based on SWAP and we will
not store tokens or have third-party deposits, only in the case of fiat currencies.
Countries without service: Republic of Panamá, Venezuela, Cuba, Switzerland.
Regarding the Swap and the Pool’s:
https://uniswap.org/disclaimer/

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3. WHAT PERSONAL DATA WE COLLECT AND HOW WE DO
IT
As we said our platform is based on a SWAP. For the deposits in FIAT the KYC will bedone in origin by the bank when the transfer will be done.
Just in some particular cases we will ask for more information to our customers. To
provide our services we need to obtain some personal information anddocumentation from you, as required by law (i.e. to create an account, make atransaction, add a payment method, etc.). If you do not provide us with that
information and documentation (if we ask you) we will not be able to allow you touse our services. When the infor-mation required is not asked for to comply with any
legal obligation, we will ask you for permission before getting this information (i.e.
when subscribing to get marketing and any other advertising communications). We
collect the following personal data, among others:
A. Information that you provide us with: We collect Personal Data that you
directly provide us with when you create and verify your Lescovex account,carry out a transaction on our platform or use any other of the Services
provided by Lescovex. This data includes:
Personal Identification information: first and last names, date of birth, homeaddress, email, city, nationality, phone number, etc.;
Usage data: username and password, authentication data, security questions,information provided to Lescovex’s support team, etc.;
Formal identification information and documentation: ID or Passport pictures,audio and video recordings, pictures taken during the audio and video
recordings, pictures uploaded by users, etc.;
Financial information: bank account numbers and statements, incomes,
trading information, etc.;
Residence verification: postal delivery, utility bills, etc.;
Employment information: Office location, wages, employment contract, job
title, occupation, etc.
B. Information obtained automatically when you access or use our services:
When you access or use our services, we automatically collect information
related to your device, computer or browser, such as the name and type ofthe browser you use, computer and mobile device, IP address, oper-ating
system, website usage information, etc.

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Information collected through cookies: We use our own cookies on our
website to collect some information about our users in order to ensure theeffectiveness our Website and platform and to manage them.
Cookies are data files that are downloaded automatically and stored on thehard drive of the user’s computer or in the memory of your device whenbrowsing a specific website, which allow the Internet server to remember
certain information about the actions and preferences of a user (such as login,language, display preferences, name and password, etc.) for a certain periodof time, so that the user does not have to enter them again each time he or
she wants to navigate on the website.
We use Cookies to help us recognize you as a customer, manage the accountregistration process, remember the preferences of your site, collectinformation about your use of Lescovex services so as to better customize ourservices and content for you, process your transactions in the exchange, andcollect information about your computer or other access devices so as toensure our compliance with our AML & CFT obligations, as well as to ensurethat your account security has not been compromised by detecting irregularor suspicious account activities.
We only use our own cookies. In particular, we use both session cookies andpersistent cookies. Session cookies expire when you log out. Persistentcookies remain on your computer or mobile device until deleted or until they
expire. Some examples of this information would be: language, username,password, orders on the exchange platform, purchases, sales, IP, etc.
In most browsers, cookies are automatically accepted by virtue of theirdefault settings. However, the user can adjust his or her browser preferencesin order to accept or reject cookies. You can disable the use of our cookies,
but it will interfere with the use and functionalities of our Exchange Services.
You can disable or delete cookies which have already been stored on yourcomputer by accessing the tools provided to that effect by your browser.
Further information can be obtained through the following links:
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookieswebsite-preferences
Internet Explorer:
http://support.microsoft.com/ph/807/es-es
Safari:
http://support.apple.com/kb/HT1677?viewlocale=es_ES
Chrome:https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=en
For further information about cookies and how to disable them, see our
Cookies Policy www.lescovex.com/legal/cookies-privacy.pdf
C. Information collected from other sources or channels: We may also collectinformation obtained through other publicly available sources or channels, so
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Lescovex Privacy Policythat we can check the information you have provided us with and verify its
authenticity and truthfulness. For example: we may collect information about
users from third parties, including, among others, social networks or official
registers, etc.

4.

WHO IS RESPONSIBLE (CONTROLLER) FOR THE

PROCESSINGOF YOUR PERSONAL DATA
The person responsible for the processing of your data (hereinafter “controller”) is
LESCOVEX PANAMA, Inc. which is the owner of the website www.lescovex.com andof the commercial name and trademark Lescovex.
Lescovex Group
Company Name: LESCOVEX PANAMA, INC
Registered Office: 71 Street, San Francisco, N.º 109, Panamá City, Panamá
Register Number: 18699
Business Purpose: The Company shall have as its main purpose the operating of an
Exchange platform based on blockchain technology in which different
cryptocurrencies may be exchanged, as set forth on the website:www.lescovex.com.
Company Name: Blackhole Consulting OÜCompany Registration Number: 16240154
Registered address: Harju maakond, Kesklinna linnaosa, Tornimäe tn 5, 10145, Tallin,
Estonia
Contact
Email: support@lescovex.com
Phone number: +507 6845 6529

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5.

HOW WE USE YOUR PERSONAL DATAA.

To verify a customer’s identity: As required by the enforceable law, wecollect and use your personal information to identify you in accordance with
the Law No. 23 dated 27 April 2015 “Adopting measures for the Prevention of
Money Laundering, Terrorism financing and Financing of Proliferation of
Weapons of Mass Destruction and other provisions” and our Manual for thePrevention of Money Laundering and Countering the Financing of Terrorism(AML and CFT policy), as well as all the European regulation related to thePrevention of Money Laundering and Countering the Financing of Terrorism.
The procedure to do so is set out in our AML and CFT policy, which is based
mainly on the Law No. 23 dated 27 April 2015 from Superintendency of Banksof Panama .
We may also share your information with financial institutions, especially theSUPERINTENDENCIA DE BANCOS DE PANAMÁ (SBP), or any othergovernment or judicial authorities, when we are required to do so and when
we have any suspi-cions about the activity you are carrying out on ourplatform.

B.

To provide our services and to process transactions: When it will will

be necessary. We will use your personal data to provide you with Lescovex’s
Services and to carry out all the transactions you do on the SWAP platform.
To comply with the AMLA and the AML and CFT policy, we will perform
behavioural analysis regarding our customers’ activities, to be sure that
nobody is using our platform to carry out any illegal activity. We will informthe Reporting Office of the SUPERINTENDENCIA DE BANCOS DE PANAMÁ
(SBP) if we have any suspicions or find any indication that any of ourcustomers are performing unlawful activities.

C.

To enhance the customers’ website experience: We use yourinformation to analyse, process, manage, improve and personalize ourservices and to respond to the demands of our users, so that they can enjoy
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our services in a safe and adequate way in consonance with their needs andexpectations.

D.

To ensure network and information security: The use of your personal

data is also of service to identify, prevent and report potentially suspicious,
fraudulent or illegal activities stemming from your account and to facilitate
the creation and secure management of your account, amongst other things.

E.

To contact users: We will use your email address to keep in touch withyou, so that we can send you administrative notifications, such as thoseregarding the activity of your account, transactions made and their processing(i.e.: asking for confirmation and so on), maintenance notifications, anychange to our terms and conditions, privacy, cookies or AML and CFT policy,
answers to enquiries, processing of payments, etc.

F.

Marketing Purposes: We may also use your email address to send you

company news, promo-tions, updates and any other information related tosimilar products or services provided by Lescovex.
For this purpose, we use a commercial automation platform whereby wecollectively send all the marketing or updates emails to our customers, being
necessary to that end that your email be transferred to that platform for thatspecific purpose. This platform is the website www.mailchimp.com, ownedby the company whose legal name is The Rocket Science Group LLC and thecommercial name MailChimp (the “Processor”). This company fully complies
with the European Data Protection Regulation, which has come into force on
the 25th of May 2018.
You can find further information about how MailChimp processes all the data
we provide them with in order to use their services by clicking the following
links:
Terms and conditions:https://mailchimp.com/legal/terms/
Privacy Policy: https://mailchimp.com/legal/privacy/
If you do not want to receive this type of communications, you can opt out of
our marketing communications at any time by going to “email configuration”
in you personal account and opting out of it or by sending an email tosupport@lescovex.com.
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Lescovex Privacy PolicyG.

To facilitate corporate acquisitions, mergers or transactions: We mayprocess any information regarding your account and use of our Services asnecessary in the context of corporate acquisi-tions, mergers or othercorporate transactions. You have the option of closing your account if you do
not wish to have your personal information processed for such purposes.

6.

HOW WE SHARE AND STORE YOUR INFORMATION

Lescovex may disclose your personal data to third parties, legal and regulatory
authorities, as well as transfer your personal data:

A.

Disclosure to third parties: We may share some of your personal datawith thirdparty service providers who may be of help to our business
operations. Lescovex’s third party service providers are contractually boundto protect and use such information only for the purposes for which it wasdisclosed, except as otherwise required or permitted by law. We ensure thatsuch third parties will be bound by terms no less protective than thosedescribed in this Privacy Policy, or those we are subject to under applicabledata protection laws.
Some or all of your personal data may also be shared upon or during thenegotiation of any merger, financing, acquisition or dissolution transaction orproceeding related to the sale, transfer, divestment or disclosure of all or partof our business or assets. If another company acquires our company, ourbusiness, Lescovex project or our assets, that company will own the Personal
Data we collect and will assume the rights and obligations with regards toyour Personal Data as described in this Privacy Policy.

B.

Disclosure to legal and regulatory authorities: We may also share your

Personal Data with financial authorities, such as the SUPERINTENDENCIA DE
BANCOS DE PANAMÁ (SBP), governmentofficials, data protection authorities
or any other authorities when:•

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Compelled by subpoena, court order or any other legal
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•We have any suspicions of you carrying out any unlawful
activity through our platform;•

Acting to prevent physical harm or financial loss;•

Acting to investigate any violations of our Privacy Policy.

International transfers of Personal Data: We store and process your

Personal Information in data centres around the world, wherever Lescovex
facilities or service providers are located. As such, we may transfer your
Personal Data outside of the Economic European Area (EEA). Such transfers
are undertaken in accordance with our legal and regulatory obligations.

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7.

HOW WE PROTECT YOUR INFORMATION

Lescovex has implemented the technical and organizational security measuresnecessary to ensure the security of your personal data and to protect it from loss,
theft, unauthorised access, alteration, misuse or destruction, taking into account thestate of technology, the nature of the stored data and the risks to which it is exposed,
whether due to human action or in relation to the physical, technical or naturalenvironment. These security measures include, but are not limited to:•

Restricting the access to your personal data only to Lescovex
personnel who need that information in relation to the tasks they
perform;•

Password and encrypted protected directories and databases, and, if
the information has to be trasferred in any way, it will also be done in
an encrypted format;•

Secure Sockets Layered (SSL) technology to ensure that yourinformation is fully encrypted and sent across the Internet securely;•

PCI Scanning to actively protect our server from hackers and othervulnerabilities.

However, we cannot guarantee that loss, misuse, unauthorised acquisition oralteration of your data will not occur. Please recognise that you play a vital role inprotecting your own personal information. When registering with our Services, it isimportant to choose a password of sufficient length and complexity, to not reveal
this password to any third parties, and to immediately notify us if you become awareof any unauthor-ised access to or use of your account.
Furthermore, we cannot ensure or warrant the security or confidentiality of
information you transmit to us or receive from us through the Internet or wirelessconnection, including email, phone or SMS, since we have no way of protecting that
information once it leaves and until it reaches us. If you have reason to believe thatyour data is no longer secure, please contact us through support@lescovex.com.
The security measures set out above will be reviewed regularly in light of new andrelevant legal and technical developments.

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8.

HOW LONG WE ARE GOING TO KEEP YOUR PERSONAl

DATA FOR
We retain Personal Information for as long as necessary to fulfil the purposes
described in this Privacy Policy, subject to our own legal and regulatory obligations.
In accordance with our record-keeping obligations, we will retain Account and other
Personal Information for at least ten years after an Account has been closed or atransaction has been made.
When the information is collected for marketing purposes, we will keep thisinformation for two years after the date of your consent, unless you have asked us toerase it by executing your rights set forth in Section 9 of this Privacy Policy.

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9.

LEGAL BASISA.

We mainly collect and process your personal data in compliance witha legal dutyto which Lescovex is subject. This is the case of the data collected
to verify your identity or to provide you with our services and to process thetransactions, or to contact users. The regulation and law enforceable in thissense is the Law No. 23 dated 27 April 2015 “Adopting measures for thePrevention of Money Laundering, Terrorism financing and Financing of
Proliferation of Weapons of Mass Destruction and other provisions”.

B.

We also collect and use your personal data to carry out our obligations

arisingfrom the contract entered with you when you become a member of
our Website and when we, therefore, have to provide you with our services.

C.

We may use you personal data to satisfy our legitimate interests toprotect ourproperty, rights or the safety of Lescovex, our customers or others.
This will be the case of when we are using your personal data to enhance yourwebsite experience or to facilitate corporate acquisitions, mergers ortransactions.

D.

We will solely need your express consent to send you information

related to newservices, promo-tions, updates and commercial notifications
through the MailChimp platform, as the rest of information collected andprocessed is, as we said, necessary to comply with legal obligations, toperform the obligations arising from the contract entered with you and tosatisfy our legitimate interests.
If you have accepted to receive marketing and updates communications andwant to stop receiving them, you can opt out of them at any time by going to“email configuration” in your personal account and opting out or by sending
an email to support@lescovex.com.

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10.

YOUR RIGHTS

You, the data subject, will have the rights lain down below, which can be exercisedat any time by contacting us through support@lescovex.com, after which we willconsider your request under the applicable laws:
Right to access: You have the right at any time to know what personal
data we have about you, what it is used for and the conditions and purpose ofus using it. We may charge a USD 15 fee per copy of the personal data
undergoing processing and always for more than one copy.

1.

Right to Rectification: You have also the right to request the correction
or erasure of your personal data when it is inaccurate or to complete it when
it is incomplete.

2.

Right to erasure (right to be forgotten): You have the right to request
erasure of your personal information that:3.

is no longer necessary in relation to the purposes for which it
was collected orotherwise processed;A.

was collected in relation to processing that you previously
consented, but forwhich you later withdrew such consent; orB.

was collected in relation to processing activities to which you
object, and there areno overriding legitimate grounds for our
processing.

C.

If we have made your personal information public and are obliged to erase thepersonal information, we will, taking into account available technology andthe cost of implementation, take reasonable steps, including tech-nicalmeasures, to inform other parties that are processing your personal
information that you have requested the erasure of any links to, or copy or
replication of your personal information. The above is subject to limita-tions
by relevant data protection laws.
We will not erase your personal data when we have to keep it to comply withthe enforceable law and regu-lations, such as the obligation to keep thetrading information during 10 years after it took place or after the terminationof a business relationship.
Right to data portability: If we process your personal information basedon a contract with you or based on your consent, or the processing is carriedout by automated means, you may request to receive your personal information in a structured, commonly used and machinereadable format, and tohave us transfer your personal information directly to another “controller”,
when technically feasible, unless exercise of this right adversely affects therights and freedoms of others. A “controller” is a natural or legal person, public

4.

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authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of your personal
information.
Right to restriction of processing: You have the right to obtain from us
restriction of processing where one of the following applies:

5.

•

The accuracy of the personal data is contested by you, for a period
enabling us to verify the accuracy of the personal data;•

The processing is unlawful and you oppose the erasure of the personal
data and request the restriction of its use instead;•

We no longer need the personal data for the purposes of theprocessing, but it is required by you for the establishment, exercise or
defence of legal claims;•

The data subject has objected to processing, pending the verificationof whether Lescovex’s legitimate grounds override your rights.

Right to object to processing: When the processing of your personal
information is based on consent, contract or legitimate interests, you may
restrict or object, at any time, to the processing of your personal information
as permitted by applicable law. We can continue to process your personal
information if it is necessary for the defence of legal claims, or for any otherexceptions permitted by applicable law.

6.

Right to withdraw consent: You have the right, at any time, towithdraw your consent to the processing of your personal informationcollected on the basis of your consent. Your withdrawal will not affect thelawfulness of Lescovex’s processing based on consent before yourwithdrawal.

7.

11.

HOW TO CONTACT US

If you have any questions or concerns regarding our Privacy Policy, or if you have any
complaint, you should first contact us through support@lescovex.com.
You can also complain about the processing of your personal data to the relevant
data protection authority. You can complain in the EU member state where you live
or work, or in the place where the alleged breach of data protection law has takenplace.

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