LC CHAIN INTERNATIONAL FIN-TEC PTY LTD Privacy Policy

Updated: October 2024 We, LC CHAIN INTERNATIONAL FIN-TEC PTY LTD (hereinafter referred to as "LC Chain" or "we"), value the protection of your privacy and personal information. We are committed to protecting your personal data security in accordance with the Australian Privacy Act 1988, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006, the Electronic Money Regulations 2011, the Payment Services Regulations 2017, and relevant standards and laws of international financial crime control, including the FATF recommendations. This Privacy Policy details how we collect, use, store and disclose your personal information, as well as the rights you have. 1. Information we collect When you use LC Chain's services, we may collect the following personal information: Identity information: such as name, date of birth, ID number, passport number, etc. Contact information: such as email address, telephone number, residential address, etc. Financial information: including bank account information, payment methods, transaction records, etc. Authentication information: Files and data provided through third-party authentication services (such as Onfido). Usage information: including device information, IP address, browser type, access log and cookies information. 2. Information collection methods We collect your personal information through the following ways: Directly provided: information you actively provide when using our services, such as registering an account, conducting transactions, or communicating with us. Automatic collection: Automatically collect device and platform usage data through cookies and similar technologies. Third-party sources: Information obtained from third parties such as identity verification services, credit evaluation agencies, and public databases. 3. Purpose of Information Use We use your personal information for the following legitimate purposes: Service provision: managing accounts, processing payments, identity verification, and customer support. Legal compliance: fulfilling the requirements of anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, including conducting customer identity due diligence (KYC). Risk management and security: Detect and prevent fraud and other financial crimes to ensure transaction security. Marketing and promotion: Send you relevant product or service information with your consent. Improving services: Improve our services and platform functions by analyzing user behavior and platform usage. 4. Information disclosure We may disclose your personal information in the following circumstances: Service providers: Third parties we work with, such as payment processors, identity verification services, and compliance service providers (such as Onfido, Creditsafe, etc.). Legal requirements: In accordance with the Australian Privacy Act, the Anti-Money Laundering and Counter-Terrorism Financing Act, and other applicable laws, we may disclose your information to law enforcement agencies, regulatory agencies, or courts. Business transfer: If there is a business restructuring, merger, or sale, your personal information may be transferred as part of the asset transfer. International Transfer: We may transfer your personal information to countries outside Australia for processing. When transferring data across borders, we will ensure compliance with relevant international data protection laws. 5. Financial Crime Control and Customer Due Diligence (KYC) In accordance with the Anti-Money Laundering and Counter-Terrorism Financing Law and the requirements of Currencycloud, we will conduct due diligence (KYC) on all customers, including the following steps: Authentication: Authenticate individuals and corporate clients through reliable third-party authentication services. Risk assessment: Conduct customer risk assessment based on customer identity, industry, geographical area, and transaction activities. Enhanced Due Diligence (EDD): For high-risk clients or clients involved in complex transactions, we will take additional due diligence measures, including verification of the source of funds. 6. Politically Exposed Persons (PEPs) and Sanctions Screening In accordance with the requirements of Currencycloud and relevant international regulations, we will conduct political sensitive person (PEP) screening and sanctions list screening for all customers. We will check whether the client and its related parties (such as beneficial owners, directors, etc.) appear on international sanctions lists (such as the United Nations, the European Union, and OFAC lists). 7. Data protection and security We are committed to protecting your personal information from unauthorized access, use or disclosure. To this end, we have taken the following measures: Technical measures: including encryption technology, access control, identity verification procedures, etc. Organizational measures: Regularly review security policies and processes to ensure data security management. 8. Data Storage and Retention We will retain your personal information in accordance with legal requirements and business needs, as well as the Australian Privacy Act and AML/CTF regulations. After the information retention period has expired, we will securely destroy or anonymize your personal data. 9. Cross-border data transmission LC Chain may transfer your personal information to countries outside Australia for processing. We will ensure that cross-border data transfers comply with Australian and international data protection laws (such as GDPR) and take appropriate measures, such as standard contract clauses (SCCs) or other legal mechanisms. 10. Your Rights In accordance with applicable laws, you have the following rights to your personal information: Access: You have the right to request access to the personal information we collect about you. Right to correction: You can request to correct inaccurate or outdated information. Right to deletion: In some cases, you can request us to delete your personal information. Right to Limit Processing: You have the right to request that we limit the processing of your personal information. Data portability: You can request that we transfer your personal information to you or another controller. 11. Cookies and Tracking Technologies We use cookies and similar technologies to collect information and improve your experience. You can manage or disable cookies through your browser settings, but disabling cookies may affect your use of certain features of our services. 12. Policy Update We may update this privacy policy from time to time. Any significant changes will be notified to you in advance and the latest version will be posted on our website. We recommend that you periodically review our Privacy Policy. 13. Contact Information If you have any questions or requests regarding this Privacy Policy or your personal information, please contact us using the following methods: Email: cs@lc-fin.com Legal reference: Australian law: Australian Privacy Act 1988 Anti-Money Laundering and Counter-Terrorism Financing Act (AML/CTF Act 2006) International regulations: Electronic Money Regulations 2011 Payment Services Regulations 2017 FATF (Financial Action Task Force) Recommendations