Last Updated: 11 July 2019
This Policy applies to information we collect from you or any such users of our Sites such as but not limited from www.LDJdigital.com, our online services, our apps users, our Products users, recipients of our emails or our notifications, or when you otherwise interact with us (the “Services”). This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
By using our Services, you are accepting and consenting to the practices described in this Policy. If you do not agree to this Policy, please do not use the Services and move away from any and all of our Services.
For the purposes of the Data Protection Act 2004 and the EU General Data Protection Regulation (the “Act”), the data controller is Frinwo S.L., Company ID: B93520922.
The information we collect
There are three basic categories of information we collect:
- Personal Information you provide to us
- Automatically-collected data
- Information we get from third parties
Information we collect from you:
This is information about you that you give us by filling in forms on our site www.LDJdigital.com or any such other websites that may be owned by LDJ digital, it´s parent company or its subsidiaries (our sites), when you use our products or services from our site or our APPs, or by corresponding with us through our app, by phone, e-mail, through social media or otherwise. It includes information you provide when you register to use our site or our app, subscribe to our Services, search for a product, use any of our services in our site or our APPs, participate in discussion boards or other social media functions on our site or our social media channels, enter a competition, promotion or survey and when you report a problem with our site, our service or APPs.
The information you give us may include your name, address, e-mail addresses, date of birth, your CRYPTO wallet addresses, bank account details, phone numbers, financial and credit or debit card information, personal description or photograph and KYC & AML (know your customer & anti money laundry) as well as any compliance documentation.
Information we collect about you:
With regard to each of your visits to our site we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, your login information, browser type and version, device type and version, time zone setting, blockchain identifiers, browser plug-in types and versions and operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or things you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service.
- Name and Surname
Enter the name you want to use on LDJ Digital. When you receive an email or interact with other user(s) of our Services or 3rd party financial providers, your name will show up with it.
To help keep your account safe, choose a strong password that’s at least 6 characters.
Have a mix of letters, capital letters, lower case letters and numbers.
Avoid personal info or common words that are easy to guess, like your street or pet’s name.
Don’t use a password you’ve used for other accounts or websites. Likewise, don’t use this password anywhere else.
- Username – email address
Enter an email address that you’ll use to sign in to your LDJ Digital Account, like email@example.com. This email address can be used for a few reasons, including to:
Help you get back in if you can’t sign in, like if you forget your password
Get notifications from any of our Services
- Change this info later
After you create an LDJ Digital Account, you can change some of this info and control who sees it, except for the username once created will not be changeable.
To assure you can use certain LDJ Digital Services we need to check you are not a USA citizen. Also, to comply with the new European guidelines we need to check if you are a European territory User or not, in which case the new European data protection law requires such users´ data from European users to be stored on server(s) within a country of the European Union.
When you create an LDJ Digital Account, you provide us with personal information that includes your name, country and a password and other information. Even if you aren’t signed in to a LDJ Digital Account, you might choose to provide us with information — like an email address to receive updates about our Services.
- Your apps & devices
We collect information about the apps, browsers, and devices you use to access our Services, which helps us provide features like automatic product updates and dimming your screen if your battery runs low.
The information we collect includes unique identifiers, device type and settings, operating system, and application version number. We also collect information about the interaction of your apps and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.
We collect this information when an LDJ Digital service on your device contacts our servers or our apps — for example, when you install our app from the Play Store.
You can visit your LDJ Digital Account to find and manage activity information that’s saved in your account, however limiting certain information will not limit LDJ Digital access to any such information we deem necessary to provide any and all of our current and future Services as well as any such information we collect for KYC (know your customer), AML (anti money laundry) and Compliance purposes.
- Your location information
We collect information about your location when you use our services, which helps us offer features like nearby devices or Wi-Fi hotspots locations and it helps us to comply with the new European regulations by checking if you are a European territory User or not, in which case the new European data protection law requires us to store such European users´ data to be stored on server(s) within a country of the European Union.
. Your location can be determined with varying degrees of accuracy by:
Country of SIM, connected Mobile service provider (home or roaming).
Sensors data from your device, i.e. pressure data to calculate estimated altitude.
Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices.
The types of location data we collect depends in part on your device and account settings. For example, you can turn your Android device’s location on or off using the device’s settings which is independent of our app(s).
- Your privacy controls
You have choices regarding the information we collect and how it’s used. You can login to your LDJ Digital Private Area and manage, review and update your information.
Personal Information you provide to us
When you interact with our Site or mobile app, we collect Personal Information that you choose to share with us. For example, when you set up an account with us, we need to collect a few important details about you, such as your name, a unique username you would like to go by, a phone number, your email address, and your date of birth. We may also collect other information such as a copy of your government-issued identification and a selfie image for verification purposes. Please ensure that you only send us an image of yourself. Do not include any images of others. When you contact customer support or communicate with us in any other way, we’ll collect whatever information you volunteer, in addition to your name and email address.
When you visit our Site, app or use our Services, we collect information about which of the Services you’ve used and how you’ve used them. Examples , but not limited to, of this information include:
- Usage information on our Site or mobile app (e.g., pages you visit on the Site, webpage from which you linked to our Site);
- Time and date of your activities;
- Location from which you browsed the Site or app;
- Device ID;
- Your IP address;
- The kind of browser or app and the type of computer or mobile device you use;
- Name of your internet service provider or SIM provider or country code or roaming country code of the mobile operator SIM in your device; and
- Operating system version.
Information we get from third parties
These 3rd party information that we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on our site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly available sources to verify your identity or fiscal residence. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law.
EXCLUSION OF RIGHT OF USE
How we use your information
- Personal Information
To provide the Services: LDJ Digital may use your Personal Information to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Manage individual information and accounts;
- Respond to questions, comments, and other requests;
- Verify an individual’s identity by comparing your selfie image against your government-issued identification;
- Process payment for products or Services purchased;
- Process applications and transactions;
- Provide access to certain areas, functionalities, and features of our Services; and
- Allow you to register for events.
For internal business purposes: LDJ Digital may use Personal Information for its internal business purposes, including to:
- Measure interest in LDJ Digital’s Services;
- Develop new products and Services or improve existing products and Services;
- Ensure internal quality control;
- Communicate about individual accounts and activities on LDJ Digital’s Services and systems, and in LDJ Digital’s discretion, changes to any LDJ Digital Policy;
- Comply with regulatory requirements;
- Prevent potentially prohibited or illegal activities;
- Protect the safety of any person, to address fraud, security or technical issues, or to protect the Company’s rights or property;
- Comply with applicable laws, rules and regulations or court orders; and
- For any other purpose for which you have given express permission or consent to LDJ Digital.
For marketing purposes: LDJ Digital may analyze and use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. LDJ Digital may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time you provide Personal Information; and
- Otherwise with your consent.
- Non-personal Information
Uses made of the Information
We shall process all information we collect from you in accordance with this Policy and applicable UK and EU laws and regulations, as may be amended from time to time, and the data controller, we may directly or through our service providers or agents process your information for any one or more of the following purposes, but not limited to:
Information you give to us. We will use this information:
- arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and Services we offer that are similar to those that you have already used, purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail, notifications, SMS, MMS, social media as WhatsApp or others or any such other means) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you or a Service you use in inquired for. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form or if not available or not found than simply email us at contact@LDJdigital.com );
- to notify you about changes, updates or down times to any of our Service;
- to ensure that content from our sites o apps is presented in the most effective manner for you and for your computer or mobile device.
Information we collect about you, we will use this information:
- to administer our sites, apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our sites and apps to ensure that content is presented in the most effective manner for you and for your computer and mobile or wireless devices;
- to allow you to participate in interactive features of our Services, when you choose to do so;
- as part of our efforts to keep our sites and apps safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our sites or apps about goods or services that may interest you or them.
- For identification purposes, including but not limited to for KYC and login, and compliance purposes, including but not limited to for AML and address identification.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
How we share information
We may share Personal Information about you in the following ways:
- To verify your identity. For example, we may share information about you with credit reporting agencies to verify your Social Security number.
- With vendors and service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities; (v) fraud prevention; (vi) analytics services; and (vii) in connection with the provision of the Services. These service providers have contracted with us to only use the Personal Information for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
- Business partners.We may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also share Personal Information with business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.
- With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
- comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
- investigate, remedy, or enforce potential Terms of Service violations;
- protect the rights, property, and safety of us, our users, or others; or
- detect and resolve any fraud or security concerns.
- With third parties as part of a merger or acquisition. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of LDJ Digital or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.
Cookies & analytics technologies
In operating the Services, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services, including helping us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
We may also use analytics tools such as Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.
Clear Gifs (Web Beacons)
We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.
How long we keep your information
We will retain your information for as long as you use our Services or as necessary thereafter to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws, such as but not limited to the European GDPR privacy regulations.
Where we store your information
All information you provide to us is stored on our secure servers. Any payment transactions will be stored encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, app or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or app; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Any information from European residents will be stored on servers in a country of the European Union.
Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them LDJ Digital does not endorse, approve or make any representations about Third-Party websites or domains. We encourage you to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and you visit them at your own risk.
Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties.
We take commercially-reasonable measures to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Site or Services, please keep in mind these risks and know that you do so at your own risk.
- Communications Preferences
- Sharing Preferences
We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.
Other Rights and Important Information
- Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services are directed to children under the age of 16. If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at contact@LDJdigital.com . If we learn that we have collected any personal information from children under 16, we will use commercially-reasonable efforts to delete such information.
- Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise that right at any time by contacting us at contact@LDJdigital.com . Our sites or apps may, from time to time, contain links to and from the websites or in-app links of our partner networks, advertisers and affiliates. If you follow a link to any of these websites or in-app links, please note that these websites or in-app links have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites on in-app links.
Disclosure of information
By using any of our Service, websites or apps You agree irrevocably that we have the right to share your personal information with: • any member of our staff or related entity within our group, parent or holding company or subsidiaries. – selected third parties including: – businesses, financial service providers, banks, credit or debit card providers, suppliers and sub-contractors for the performance of any contract we enter into with you or with third parties:
– analytics and search engine providers that assist us in the improvement and optimisation of our sites or apps;
– credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We will disclose your personal information to third parties:
– KYC/AML/Compliance agencies or third party contracted companies for such purpose of assessing your identity, living or fiscal address, anti-money laundry checks and checks for source of funds of money and crypto or other such services where this is a condition of us entering into a contract with you or such third party. We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If LDJ Digital sells part or all of its assets, acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of LDJ Digital or any of its officers, shareholders, customers, or others. This includes exchanging information with other companies and organisations for the purposes of financial compliance, customers fiscal address compliance verifications to comply with applicable laws, fraud protection and credit risk reduction.