Privacy Policy

This Privacy Policy governs your use of the website, content and features offered by LCX Exchange USA Inc., 1007 N Orange St, 4th Floor, Ste 1382, Wilmington, DE 19801, United States (“LCX US”, “we”, “us”, “our” or the “Company”), including when you provide any information to us in relation to your use of this website.

At present this website has a single purpose: to allow you to join a waitlist so that we can tell you when LCX Exchange USA becomes available in your state. No account is created, no identity verification takes place, and no product or service is offered or sold through this website.

This Policy explains what information we collect, how we use it, and the choices and rights available to you. It is drafted to meet the requirements of applicable United States federal and state privacy laws, including the California Online Privacy Protection Act, the California Consumer Privacy Act as amended, and comparable state privacy laws.

LCX US operates independently from LCX.com. Information you provide to LCX.com is governed by that platform’s own privacy policy and not by this Policy.

This website is not intended for minors (persons under 18 years of age) and we do not knowingly collect personal information relating to minors. If you believe a minor has submitted information to us, please contact us and we will delete it.

We do not sell your personal information, and we will not rent or sell it to third parties for cross-context behavioral advertising.

Company responsible for your information

LCX Exchange USA Inc., as defined above, is the company responsible for the personal information collected through this website.

Changes to this Privacy Policy

We may revise this Policy over time, for example as new features are added or as legal requirements develop. If we make changes we will update the “Last Updated” date above and, where a change is material, we will provide notice on this website or by email before it takes effect. If you disagree with the terms of this Policy, please do not submit information through this website.

Third-party websites

Some pages may include links to third-party websites. Those sites are governed by their own privacy statements, and we are not responsible for their operations or information practices, including any cookies they set. Please review their privacy statements before providing them with any information.

2.1 What these technologies are

When you access this website we, and companies we work with, may place small data files on your computer or device, or read files already there. These may be cookies, pixel tags and clear GIFs, tracking scripts and software development kits, or local storage provided by your browser (collectively “Cookies”). We use them to make the website work, to remember your preferences, to understand how the site is used, to measure how our marketing performs, and to help prevent abuse and automated sign-ups.

2.2 Categories of Cookies we use

• Strictly necessary. Required for the website to function and to keep it secure, including protecting the waitlist form against automated submissions. These cannot be switched off through our preference tool.
• Functional. Remember choices you make, such as language or whether you have already dismissed a notice.
• Analytics and performance. Help us understand how many people visit, which pages they view and where they arrive from, in aggregate.
• Advertising and targeting. Help us measure the performance of our marketing and, where used, show our advertising to relevant audiences on other platforms.

2.3 The Cookies currently in use

Some tools we use, such as Yoast SEO, operate on the server side and do not place cookies or similar identifiers on your device.

2.4 Third-party collection across other websites

Some of the providers listed above are third parties that set their own Cookies through our website. Where advertising or analytics providers are used, those third parties may collect information about your online activities over time and across different websites and services, including after you leave our website. We do not control those Cookies and cannot access the data they generate. Each provider is responsible for its own handling of that information under its own privacy policy, and links are given in the table above. This disclosure is provided in accordance with California law.

2.5 Your choices — how to turn Cookies off

• Browser settings. Most browsers accept Cookies by default and allow you to block or delete them. Blocking strictly necessary Cookies may stop parts of the website working.
• Global Privacy Control and universal opt-out signals. Some browsers and extensions transmit a Global Privacy Control (“GPC”) signal. We treat a recognised Global Privacy Control signal as a valid request to opt out, and we disable non-essential analytics Cookies for that browser or device. Because the signal is stored per browser and per device, you may need to apply it again on each browser and device you use.
• Do Not Track. Some browsers transmit a “Do Not Track” signal. There is no common industry standard for how these signals should be handled. We do not currently respond to Do Not Track signals, and instead honour Global Privacy Control as described above. This disclosure is provided in accordance with California law.
• Industry opt-out tools. You can opt out of interest-based advertising from participating companies through the Digital Advertising Alliance at optout.aboutads.info and the Network Advertising Initiative at optout.networkadvertising.org. These tools rely on Cookies and will need to be reapplied if you clear them.
• Provider-specific controls. Where a provider offers its own opt-out, the link is given in the table in section 2.3.

2.6 Consent

United States privacy laws generally operate on an opt-out basis rather than requiring your prior consent to Cookies, and we do not ask for consent before setting them. Where we display a Cookie notice, it is provided for transparency and to give you access to the controls described above. Opting out will not prevent you from joining the waitlist.

Information we collect from you

• Your email address, when you join the waitlist.
• Your state of residence, which tells us whether and when our services will be available to you.
• Anything you choose to include if you contact us directly.

Information collected automatically

• Your IP address, which also indicates an approximate location.
• Device, browser and operating-system information.
• Pages viewed, referring website and basic interaction data, collected through Cookies.

Information we do not collect

Through this website we do not ask for or collect your name, postal address, telephone number, date of birth, Social Security number, government-issued identification, financial account or payment details, or biometric information. We do not carry out identity verification here, and we do not collect transaction information because no transactions take place on this website.

Because no sensitive personal information is collected, we do not use or disclose sensitive personal information for any purpose.

We use the information described above for the following purposes:

• To notify you when LCX Exchange USA becomes available in your state, and to send launch updates you have signed up to receive.
• To understand, in aggregate, the level of interest and which states it comes from, so that we can plan and prioritize our state-by-state rollout.
• To operate, secure and improve this website, and to prevent abuse, fraud and automated sign-ups.
• To comply with applicable law and to enforce our terms.

We will not use your information for a materially different purpose without telling you first.

If you join the waitlist, we will send you information about the launch of LCX Exchange USA and related updates. Every marketing email includes an unsubscribe link, and we will stop sending marketing messages promptly once you use it. You may also contact us at any time to change your preferences.

We do not sell your personal information. We disclose it only as follows:

• Service providers acting on our behalf and under contract, namely our email platform (HubSpot), website hosting and analytics providers. Our contracts require them to use the information only for the services they perform for us and not for their own benefit.
• Legal, regulatory and safety disclosures, where required by applicable law, subpoena, court order or other lawful request, or where necessary to protect our rights, our users or the security of our systems.
• Professional advisers such as our lawyers and auditors, who are bound by duties of confidentiality.
• A successor in the event of a merger, acquisition, financing or sale of assets, on condition that this Policy continues to apply to the information transferred.
• Aggregated, de-identified information that cannot be linked to you, for example the proportion of waitlist interest by state, which we may share publicly or with partners.

We require all third parties to respect the security of personal information and to handle it in accordance with applicable law.

We are committed to handling your information to a high standard of information security. We use safeguards including encryption in transit, encryption at rest, network protections, and access controls that limit access to those personnel who require it and who are subject to confidentiality obligations.

Information collected through this website is stored and processed on servers located in the European Union. It may also be accessed by our personnel and by the service providers listed in this Policy, some of whom are located in the United States and other countries, for the limited purposes described here. By submitting your information you understand that it will be transferred to, stored and processed in these locations, which may have data-protection rules different from those of your home state. This website is directed to residents of the United States and is not intended for persons located in the European Economic Area, the United Kingdom or Switzerland.

No method of transmission or storage is completely secure and we cannot guarantee absolute security. If a security incident affects your personal information, we will notify you and the relevant authorities where required by applicable state or federal law.

We retain your email address and state of residence for as long as necessary to fulfil the purpose for which they were collected, namely notifying you about the launch of LCX Exchange USA, and thereafter only for as long as required to meet any legal or recordkeeping obligations.

In practice, we retain waitlist information until you unsubscribe or ask us to delete it, and in any event for no longer than 24 months from the date you join if LCX Exchange USA has not launched in that period.

Aggregated figures that cannot identify you may be retained for longer.

Please note that different and longer retention periods will apply to account and transaction records once LCX Exchange USA services become available, as described in the privacy policy that will apply at that time.

We ask only for the information we actually need. For the waitlist this is an email address and a state of residence, and nothing further. Where information is no longer necessary to identify you, we anonymize or aggregate it so that it can no longer be associated with you, in which case we may retain and use it for statistical purposes without further notice.

Depending on where you live, you may have the following rights in relation to your personal information:

• To know what personal information we have collected about you, the sources, the purposes, and the categories of recipients.
• To obtain a copy of that information in a portable form.
• To correct inaccurate personal information.
• To delete your personal information. Because the only information we hold through this website is your email address and your state, there is nothing further to remove.
• To opt out of marketing and, where applicable, of targeted advertising or any “sale” or “sharing” of personal information.
• To appeal a decision we make about a request.
• Not to be treated differently for exercising any of these rights.

Residents of California, Virginia and other states with comprehensive privacy laws have these rights under those laws. We honor requests from residents of any state through the contact details below, whether or not a particular state law currently applies to us.

How to make a request

Email us using the details in section 11. We will respond to your request within 45 days. If we need more time, we may extend this period by a further 45 days and will notify you of the reason for the delay within the initial 45-day period. We will reply from, or ask you to confirm, the email address held in our records, so that we do not act on another person’s behalf, and we may decline a request where we cannot verify who you are. You may appoint an authorized agent to make a request for you, in which case we will ask for your written, signed authorisation and will also verify your identity directly.

For any question or request relating to this Policy or your personal information, including to exercise any of the rights above, please contact us:

Full name of legal entity: LCX Exchange USA Inc.

Registered office: 1007 N Orange St, 4th Floor, Ste 1382, Wilmington, DE 19801, United States

Email address: legal@lcx.com

If you are not satisfied with the way we address your request or handle your information, you may appeal by replying to us with “Appeal” in the subject line, and you may also contact the attorney general of your state. We ask that you contact us first so that we have the opportunity to resolve the matter.

This Policy will be reviewed and updated regularly to ensure it remains accurate and compliant. We are committed to transparency and accountability in how we handle personal information.

Should any provision of this Policy be invalid or unenforceable, the remainder shall remain valid and in force. The invalid or unenforceable provision shall be amended only as far as necessary to make it valid and enforceable while preserving its original intent as closely as possible.

This Policy is governed by the laws of the State of Delaware and applicable United States federal law, without regard to conflict-of-laws principles, and subject to any mandatory consumer protection provisions of the state in which you reside.