Privacy Policy

ABOUT THIS PRIVACY POLICY

This Privacy Policy describes how we will treat your personal information in relation to the services provided by LANIN PAY SA de CV ("LANIN PAY"), and is an integral part of the Terms and Conditions of use of the platform (sites and apps). Therefore, your voluntary, specific, informed and unequivocal consent to the terms of this Privacy Statement, which applies to all personal data processing services and operations (carried out by LANIN PAY, its subsidiaries, controllers and/or associates) , is an essential requirement to be able to operate on or through the platform.

We have written and organized this Privacy Statement in a simple and accessible way precisely so that you can understand how we use your personal data. Below we share some of the most important terms that we use here and you should know:

• - PERSONAL DATA: Any information related to an identified or identifiable natural person (for example, name and surname, facial image, address, email, identity, location data, IP address, cookie data, telephone, etc.).

• - HOLDER: You. The natural person to whom the personal data in question refer.

• - CONSENT: The free, informed and unequivocal statement with which you accept the treatment of your personal data for a specific purpose.

• - TREATMENT: Any operation carried out with personal data. For ex. collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, modification, communication, transfer, dissemination or extraction.

RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA

LANIN PAY is a company incorporated in the Republic of El Salvador as a provider of Bitcoin services and intermediation in the purchase, sale and custody of crypto assets, and will be responsible for the treatment that is carried out on your personal data.

Your privacy is very important to us and we intend that the trust you place in LANIN PAY translates into security to operate in our entire ecosystem. For this reason, it is very important that you bear in mind that, by registering on our platform, you will be providing certain personal information that LANIN PAY will process and share with all the companies that participate in the provision of our services and make its operation possible.

You must previously accept these conditions to complete your registration and use the platform. If you do not agree, or have any doubts about its scope, please do not continue with the registration; We invite you to write to us at DPO@LEMON.ME so that we can improve.

WHAT TYPES OF PERSONAL DATA WE PROCESS 

We collect personal information to provide you with our services and to continually improve them. The main source of information is going to be you, when registering and then using the platform, but we also collect data from other reliable sources.

Therefore, if you provide us with false or inaccurate information, we will not be able to provide you with our services. Please note that LANIN PAY may suspend or disable any user who violates this Privacy Statement in any way.

DATA THAT YOU PROVIDE US WITH THE REGISTRATION:

• - IDENTIFICATION AND CONTACT DATA: name and surname, sex, postal, telephone and electronic address, residence address, nationality and date of birth, language, identity document.

• - SOCIOECONOMIC DATA: work activity, professional or occupation, tax data and tax data.

• - BIOMETRIC DATA: facial pattern.

DATA THAT YOU PROVIDE US WITH THE USE OF THE PLATFORM:

• - CONTRACTING DATA: contracted products and services, owner status, information on investments made and their evolution.

• - BASIC FINANCIAL DATA: current and historical balances of your products and services, and movements of your accounts, including the type of operation, the parts, the amount and the concept.

• - DATA OF THE COMMUNICATIONS MAINTAINED WITH YOU: obtained from the chats, emails, calls or equivalent means that have you as an interested party.

• - NAVIGATION DATA ON OUR PLATFORM: time and date of access, browsing history and content clicks, device ID, IP address and if you have accepted the use of cookies.

• - LOCATION DATA: location of the businesses where you make purchases with your card and the geolocation data of your mobile device, when you have authorized it in the configuration.

DATA OBTAINED FROM THE ANALYSIS OF THE DATA:

• - DATA OBTAINED FROM THE EXECUTION OF STATISTICAL MODELS: we apply various statistical models on the data of our clients to fight against fraud, deduce consumption habits or preferences, comply with our regulatory obligations and manage our products and services.

• - RISK ASSESSMENT DATA: to provide you with some of our products, we will previously deduce your ability to pay, applying statistical models that are calculated on your data.

DATA OBTAINED FROM PUBLIC ACCESS OR EXTERNAL SOURCES:

• - DATA OBTAINED FROM CREDIT INFORMATION SYSTEMS: result of consulting the most recognized systems on the market, which provide information on debts, asset solvency and credit (debtor, creditor and debt).

• - DATA OBTAINED FROM PUBLIC AGENCIES: result of consulting public access systems, which provide information on debts.

• - DATA RELATING TO INTERNATIONAL SANCTIONS: data of people who are included in laws, regulations, guidelines, resolutions, programs or restrictive measures regarding international economic-financial sanctions imposed by the United Nations, the European Union, the United Kingdom and the United States, among others. .

• - DEMOGRAPHIC DATA: statistical data associated with geographical areas, age groups and/or sectors of activity, which we will link to your personal information.

• - DATA ON PUBLIC OFFICES AND/OR CORPORATE LINKS: result of consulting the most recognized information systems in the market, which we will use to complement the information on your activity.

• - DATA FROM SOCIAL NETWORKS: from the platforms that you link and/or authorize to consult.

WHAT WE TREAT YOUR PERSONAL DATA FOR

We will only treat the necessary personal data according to the conditions and purposes set forth herein. The collection of all this information allows us to identify you, validate your information, facilitate contact with other users, manage our services, provide you with support, offer you a better experience, increase the security of our platform and comply with current regulations, among other issues, but it will only be appropriate if it has a sufficient legal basis.

POSSIBLE LEGAL BASIS FOR PROCESSING:

• - PRIOR CONSENT. If we have your prior consent, from registration we will use your personal data to develop a commercial profile that allows us to offer you, in particular, our services and promotions. In addition, we will employ technical means that use biometrics to verify your identity.

• - CONTRACT EXECUTION. We will use your personal data to formalize and/or maintain the existing contractual relations with you, including the processing of your requests or mandates, the procedures prior to contracting and the establishment of measures aimed at ensuring compliance with the obligations you have with us.

• - COMPLIANCE WITH LEGAL OBLIGATION. We will use your personal data if it is necessary to comply with an enforceable legal obligation. Keep in mind that, in addition to the regulation of the sector and the activity, rules related to: Prevention of Money Laundering and Financing of Terrorism, information regimes in general, tax collection regimes and requirements of administrative and/or judicial authorities apply here. , among other.

• - LEGITIMATE INTEREST. We will use your personal data if it is necessary to satisfy the legitimate interests pursued by LANIN PAY or by a third party, provided that your interests, rights and/or fundamental freedoms do not prevail.

POSSIBLE PURPOSES OF PROCESSING:

• - Verify your identity

• - Demonstrate your consent

• - Carry out credit analysis

• - Identify and prevent possible fraud

• - Identify and prevent possible threats to the security of the platform

• - Make advertising and/or promotional contacts

• - Comply with PLAFT regulations

• - Comply with judicial or administrative requirements

• - Personalize and improve services

• - Analyze their behavior

In any case, keep in mind that in the event of adopting decisions based solely and exclusively on automated processing (that is, without the participation of a person) that could produce legal effects on you, or that could significantly affect you (for example, with the denial of a product), we will inform you about it and we will facilitate the right to obtain human intervention, to express your point of view and to contest the decision.

WHAT ARE THEY AND WHAT WE DO WITH COOKIES

Cookies are small text files that the sites and apps you use send to your device (through the browser) in order to identify it. They allow you to remember certain information about your visit and make subsequent visits easier. They serve eg. to remember your language, your time zone and the products you have consulted, among other things. In fact, on occasion, cookies may also be used so that you do not have to enter your password as often during a session.

For us, these technologies are very important. They allow us to recognize you as a user, learn about your habits and behaviors and even improve our services.

And although the lemon.me site is accessible without the need for cookies to be activated, you should bear in mind that their deactivation could limit the use of certain services or prevent their proper functioning as certain functions cannot be executed.

We invite you to read our "Cookies Policies" (found at the bottom of the site), where you can understand what cookies are, why we implement them and how you can manage them.

WITH WHOM WE SHARE YOUR PERSONAL DATA

LANIN PAY does not market or market your personal data in any way. Therefore, we detail below the companies and entities with which we could share your data to offer you our services correctly:

• - LANIN PAY. They are the companies that are part of the corporate group, that operate under the same policies, whether they are controlled, controlling and/or affiliated with LANIN PAY.

• - SUPPLIERS. They are third parties that we contract to act on behalf of LANIN PAY and provide their services following our instructions in accordance with this Privacy Statement.

• - COMMERCIAL ALLIES. They are third parties with whom we have a relationship to offer you services and promotions. In these cases, LANIN PAY ensures that these companies comply with the applicable personal data protection regulations by imposing specific contractual clauses.

• - LINKED USERS. They are registered users on the platform, and the sole purpose of exchanging information is the transaction they intend to carry out (both parties will know the other, at the time of carrying out the operation, the full name and account data).

• - COMPETENT AUTHORITIES. Before formal requests in the exercise of its functions, we could share information for example. with tax authorities, control agencies, national or local justice, etc.

In addition, we reserve the possibility of disclosing your information to other users, entities and/or authorities when there are sufficient reasons to consider that your activity was suspicious and/or there is a reasonable suspicion that other people could be harmed.

For any other case, before sharing your personal information, we will ask for your prior and express consent, unless there is a sufficient rule or order that allows otherwise.

HOW WE MAKE INTERNATIONAL TRANSFER OF PERSONAL DATA

The services we provide, by their nature, require servers and services in the cloud, so it may happen that some of the personal data we collect is stored or processed in countries other than the original.

In cases where the receiving country does not have an adequate level of personal data protection in accordance with current law, we will implement additional technical and/or organizational security measures to guarantee the protection of your personal data, and we will require the provider of services, if applicable, that also implements them (or complements them with others).

Such guarantees may consist of resorting to binding corporate regulations, standard clauses adopted by a supervisory authority, or contractual clauses authorized by a supervisory authority. They must ensure compliance with the regulations on personal data and the availability by the interested parties of enforceable rights and effective legal actions.

WHAT ARE YOUR RIGHTS AS A DATA HOLDER

At LANIN PAY, your privacy is one of our greatest concerns. We will try to be as transparent as possible in the processing of your personal data and therefore, from the moment you entrust us with your information, you will have the following rights:

• - ACCESS. You will have the right to request access to your personal data, as well as to know any information related to the conditions of your treatment.

• - RECTIFICATION. You will have the right to request the rectification of your personal data, when they turn out to be inaccurate, incomplete or not updated.

• - CANCELLATION. You will have the right to request the deletion of your personal data, so that they are not processed by LANIN PAY, unless it could cause damage to the legitimate rights or interests of LANIN PAY or third parties, or when there is a legal obligation to keep them.

• - OPPOSITION. You will have the right to oppose the processing of your data, or for a specific purpose, when you have not given consent and/or its processing is not legitimate or justified according to current regulations.

To exercise any of these rights, and even to exercise any other that you consider linked to them, you can write to DPO@LEMON.ME and we will immediately process your request and inform you of the results within the period provided by current law.

ABOUT OPERATIONS CARRIED OUT IN BLOCKCHAIN

​​Blockchain technology works as a shared and immutable ledger that facilitates the process of registering transactions and tracking assets (tangible and intangible). Virtually anything of value can be tracked and traded on a blockchain network, reducing risk and costs for everyone involved.

By its nature, this technology generates an ever-growing list of data records, called blocks. Included in each block is a cryptographic hash of the previous block, a timestamp, and other data related to the transaction. Its immutability is one of the most outstanding characteristics: It is not possible to add, delete or modify the information stored in a block without a change in the value of the hash used as a link in the next block. No participant may change or falsify a transaction once recorded in the shared ledger. If a transaction log includes an error, a new transaction must be added to reverse the error, but both transactions will be visible.

If you still have questions about it, we invite you to our WIKI, where we will publish guides and resources to learn more about cryptocurrencies and smart contracts.

The best-known success story regarding blockchain is Bitcoin. The first cryptocurrency based on blockchain technology makes use of its characteristics to offer a business model without intermediation, that is, without any type of central regulatory entity. Sure, Bitcoin isn't the only cryptocurrency out there; there are many more, each with their own features, some implemented on top of existing blockchains and others built from scratch. Blockchain technology is one of the main elements of our platform in relation to transactions with crypto assets, tokens and other digital representations of value.

As regards this Privacy Statement, you must bear in mind that, due to its nature, it will not be possible for you to modify or correct any transaction you carry out on the blockchain, on or through the LANIN PAY platform, nor will it be possible for you to delete any of the personal data that the block chain requires you to provide for that transaction.

In general, when you carry out an operation with crypto assets, the following personal information will be written on your respective blockchain:

• - Origin wallet address.

• - Destination wallet address.

• - Amount of the operation.

• - Time and date of the operation.

For what we explained above, once the operation is confirmed, all this information will no longer be in our possession and we will not be able to help you exercise your rights over it. Each block is chronologically linked with its predecessor and its subsequent one, in an inseparable way. Once the data has been recorded in a block, it is practically impossible to alter and/or delete it.

This particularity of the blockchain could affect your ability to exercise some of your rights as the owner of your data, such as the right to delete or rectify. Although there are some smart contracts that could block certain personal information from third parties, the truth is that the data will still be there and cannot be deleted.

In short, if you want to ensure that your rights are not affected in any way, do not transact on the blockchain, as certain privileges will not be fully available or fully exercised. Blockchains, in general, are publicly available and any personal data published on them will be public knowledge.

HOW LONG WE STORE YOUR PERSONAL DATA

LANIN PAY will keep your personal data as long as they are necessary to achieve the purposes for which they were collected, to comply with regulatory or legal requirements, or during the prescription period of possible legal or contractual responsibilities, or could cause damages to rights or legitimate interests of LANIN PAY or third parties. Keep in mind that there are regulations that require us to keep certain information for a special period of time, which could be 2, 5 and up to 10 years.

To determine the appropriate retention period for each category of personal data, we consider the amount, nature, and sensitivity of the data, as well as the potential risk (arising from unauthorized use and/or unlawful disclosure), the purposes of the treatment and if it is possible to fulfill said purposes by other means in accordance with the current law.

In short, from registration and for as long as the account is active, all personal data linked to your account will continue to be stored. At the end of the legal period that affects the type of specific data (or when the purposes for which they were collected have been achieved), we will proceed to their elimination or anonymization so that no person can be individualized.

HOW WE TAKE CARE OF YOUR PERSONAL INFORMATION

As part of the provision of our services, we apply strict technological and procedural controls to guarantee the security and protection of all the personal data that we collect and store.

We have adopted practices such as user authentication, strict access control, encryption of data and transaction content, prevention and detection of intrusion and unauthorized access, prevention of information leakage, periodic testing and scanning to detect vulnerabilities, protection against malicious software, traceability mechanisms, access controls and segmentation of computer networks, maintenance of backup copies of personal data and information, among others.

In any case, and beyond the tools that we implement at LANIN PAY, it is very important that you use the platform safely, identifying and avoiding situations that may threaten the security of your personal data and our products and services.

If you detect or suspect that the security of your account may have been compromised, it is essential that you immediately contact LANIN PAY through any of the channels provided. Please note that when you transact and/or enter your data on third-party sites or services, the responsibility for protecting and storing your personal data in those places rests with the providers of those services.

HOW WE COLLECT INFORMATION FROM MINORS

Some of the services provided by LANIN PAY can be used by minors under 18 years of age. In all cases, we will request the consent of one of the responsible parents and/or guardians. At the time of registration, the platform itself will warn the minor of this requirement and will ask them to provide said authorization prior to any interaction with the platform. We will never ask the minor for more information than is necessary to provide our services in accordance with this Privacy Statement.

Once consent is granted, the minor's account will behave similarly to any other account. The minor may operate with other users, platforms and businesses on or through the LANIN PAY platform.

Any of the parents and/or responsible guardians may revoke the consent provided at any time as well as exercise, on behalf of the minor, all the rights provided for in the personal data regulations and this Privacy Statement.

HOW TO TALK WITH OUR PROTECTION DELEGATE OF PERSONAL DATA

To exercise any of the rights mentioned in this Privacy Statement, and even to exercise any other that you consider linked to them, you can write to DPO@LEMON.ME, and we will immediately process your request and inform you of the results within the period provided by current law. There we will also receive your comments, questions and suggestions related to this Privacy Statement.

For the purposes of this Privacy Statement, LANIN PAY appointed Christian Hernán Miller as Personal Data Protection Officer, who may be contacted by email at DPO@LEMON.ME.

HOW WE NOTIFY OF POLICY CHANGES

As we always seek to improve our services, this Privacy Statement may be updated. Therefore, we recommend that you periodically visit this page to be aware of changes. However, if we make material changes that require your consent, we will post the update and notify you by email so you can be aware. If you do not agree with this Privacy Statement, you must discontinue use of the platform.

APPLICABLE LAW AND JURISDICTION

This Privacy Statement shall be governed by the laws of El Salvador. Any dispute related to the interpretation, validity or compliance with this Privacy Statement will be resolved before the Ordinary National Courts with seats in the City of San Salvador. The parties (the user and LANIN PAY) expressly waive any other jurisdiction and/or jurisdiction that may correspond to them.