Privacy Policy

Introduction

Lince LTD makes this privacy policy available to you. It applies both to the website https://lince.finance/ and to the Lince mobile app for iOS and Android (the “app”), in order to provide you with detailed information about how we process your personal data and protect your privacy and the information you provide to us. Should any changes be made in the future, we will notify you via the website, the app, or by other means so that you may be aware of the new privacy terms that have been implemented.

In accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), and, with respect to users in the Argentine Republic, Law 25,326 on the Protection of Personal Data, we hereby inform you of the following:

Data Controller

Data Controller: Lince LTD — a company incorporated under the RAK Digital Assets Oasis Company Regulations 2023 (Reg. No. 01010968)

Registered office: Office A, RAK DAO Business Center, RAK BANK ROC Office, Ground Floor, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates

Email: info@lince.finance

Website: https://lince.finance/

If you have any questions, concerns, or suggestions regarding our use of your personal data, you may contact us at info@lince.finance.

We do not hold your funds in custody

Lince operates a non-custodial software interface: your funds remain at all times in a wallet whose private keys are controlled solely by you. Lince never has possession, custody, or control of your funds, and cannot access, transfer, or freeze them. For this very reason, no “account” on Lince contains your money: the app reads your wallet’s balance and transactions to show them to you, but does not hold them on your behalf.

The infrastructure and smart contracts with which Lince interacts have been audited by Halborn, an independent blockchain security firm.

For what purposes do we process your personal data?

At Lince, we generally collect and process your personal information to manage our relationship with you. The main purposes we have identified are as follows:

• Management and procurement of the products and services offered by our company.
• Processing requests for information, suggestions, and complaints you may send us.
• Keeping you informed about events, offers, products, and services that may be of interest to you through various communication channels, provided you have given your consent.
• Managing the employment relationship, in the case of our employees.
• Managing the business relationship with our suppliers.

How do we collect your information?

We collect your personal information through various means, but you will always be informed at the time of collection via privacy notices regarding the data controller, the purpose and legal basis for processing, the recipients of the data, and the retention period for your information, as well as how you can exercise your data protection rights.

In general, the personal data we process is as follows:

• Identification and contact data: first and last names, date of birth, address, national ID number or equivalent document, phone number, and email address.
• Identity verification data: a photo of your identity document and a selfie. Verification includes a facial comparison between both images, which constitutes biometric data. It is processed with your explicit consent and solely to verify your identity and comply with legal anti-money-laundering obligations.
• Financial data: the bank accounts you provide for withdrawals, your balance, the deposits and withdrawals you make, and your wallet address.
• Contracted services and payment and billing information.
• Reviews and feedback you send us from the app.
• If you sign in with your Apple or Google account, the data that account shares with us, such as your name and email address.

In cases involving personnel management and recruitment, we collect academic and professional data in order to fulfill the obligations arising from the employment relationship or, where applicable, to hire you as part of our staff.

The information collected through the posts and communications you publish may contain personal information that is available online and accessible to the public. These social media platforms have their own privacy policies explaining how they use and share your information; therefore, Lince recommends that you review them before using these platforms to confirm that you agree with how your information is collected, processed, and shared.

Through our website, we collect personal information related to your browsing activity through the use of cookies. For a clear and precise understanding of the cookies we use, their purposes, and how you can configure or disable them, please refer to our Terms of Service.

User Responsibility

By providing us with your information through electronic channels, you warrant that you are at least 18 years old and that the information provided to Lince is true, accurate, complete, and up-to-date. To this end, the user confirms that they are responsible for the accuracy of the information provided and that they will keep such information properly updated to reflect their actual situation, and they are liable for any false or inaccurate information they may provide, as well as for any direct or indirect damages that may result.

How long do we retain your information?

At Lince, we retain your information only for as long as necessary to fulfill the purpose for which it was collected, to comply with the legal obligations imposed on us, and to address any potential liabilities that may arise from fulfilling the purpose for which the data was collected.

In any case, and as a general rule, we will retain your personal information as long as a contractual relationship between us exists or until you exercise your right to erasure and/or restriction of processing; in which case, the information will be blocked and will not be used for any purpose other than retention, provided that it is necessary for the exercise or defense of claims or if any liability arises that must be addressed.

You can delete your account at any time from Settings in the app. When you do, we delete your personal data, except the minimum that anti-money-laundering rules require us to keep (your email, name and country); the transactions you made (deposits and withdrawals) are kept without any personal data attached.

To whom do we disclose your data?

Generally speaking, at Lince we do not share your personal information, except for disclosures we are required to make based on legal obligations.

Although this does not constitute a transfer of data, in order to provide the requested service, third-party companies acting as our service providers may access your information to perform the service we have contracted with them. These service providers access your data in accordance with our instructions and may not use it for any other purpose, maintaining the strictest confidentiality.

The providers that process personal data on Lince’s behalf are the following:

• Privy: sign-in and wallet creation and management.
• Bridge and Persona: identity verification and bank transfers.
• Amazon Web Services: servers and email delivery.
• Vercel: website hosting.
• Google Analytics: website usage statistics.
• Meta (Meta Pixel): measuring our advertising campaigns on Facebook and Instagram, on the website only.
• Apple and Google: sign-in, when you choose to sign in with your Apple or Google account. These companies process that data under their own privacy policies.

Likewise, your personal data will be made available to public authorities, judges, and courts to address any potential liabilities arising from the processing.

International Data Transfers

Some of the providers listed in the previous section are based in the United States or process data on servers located outside the European Economic Area (EEA), so using their services involves international data transfers.

These transfers are made with the appropriate safeguards required by the GDPR: where the provider is certified under the EU-U.S. Data Privacy Framework, on the basis of the European Commission’s adequacy decision, and otherwise through the standard contractual clauses approved by the European Commission. You can request more information about these safeguards by writing to info@lince.finance.

What are your rights regarding the processing of your data, and how can you exercise them?

Data protection regulations allow you to exercise your rights of access, rectification, erasure, and data portability, as well as the rights to object to and restrict the processing of your data, and the right not to be subject to decisions based solely on the automated processing of your data, where applicable.

These rights are characterized by the following:

• Exercising these rights is free of charge, except in the case of manifestly unfounded or excessive requests (for example, repetitive requests), in which case Lince may charge a fee proportional to the administrative costs incurred or refuse to act.
• You may exercise your rights directly or through your legal or voluntary representative.
• We must respond to your request within one month; however, depending on the complexity and number of requests, this period may be extended by an additional two months.
• We are required to inform you of the means to exercise these rights, which must be accessible, and we may not deny you the right to exercise them simply because you choose a different method. If the request is submitted electronically, the information will be provided electronically whenever possible, unless you request otherwise.
• If Lince does not process the request, it will inform you, within a maximum of one month, of the reasons for its inaction and of the possibility of filing a complaint with a supervisory authority.

To exercise your rights, Lince provides the following means:

• By submitting a written and signed request addressed to Lince LTD, Office A, RAK DAO Business Centre, RAK BANK ROC Office, Ground Floor, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates. Ref: Exercise of Data Protection Rights.
• From the app, in Settings, you can delete your account and your personal data directly.
• By sending an email to info@lince.finance with “Exercise of Data Protection Rights” in the subject line, stating the right you wish to exercise.

If you write to us by post or email, you must verify your identity by attaching a photocopy or, if applicable, a scanned copy of your national ID card or equivalent document, in order to ensure that we respond only to the data subject or their legal representative; in the latter case, you must provide documentation proving such representation.

Furthermore, and especially if you believe that you have not received a satisfactory response regarding the exercise of your rights, we inform you that you may file a complaint with the data protection authority in your country of residence. In Argentina, this is the Agency for Access to Public Information (AAIP).

How do we protect your information?

At Lince, we are committed to protecting your personal information.

We use reasonably reliable and effective physical, organizational, and technological measures, controls, and procedures designed to preserve the integrity and security of your data and to ensure your privacy.

In addition, all staff with access to personal data have been trained and are aware of their obligations regarding the processing of your personal data.

In the contracts we enter into with our suppliers, we include clauses requiring them to maintain confidentiality regarding the personal data to which they have had access pursuant to the assignment, as well as to implement the necessary technical and organizational security measures to ensure the ongoing confidentiality, integrity, availability, and resilience of the systems and services used to process personal data.

All of these security measures are reviewed periodically to ensure their adequacy and effectiveness.

Third-Party Services

In general, the third-party providers we use will only collect, use, and disclose your information to the extent necessary to enable them to provide the services they offer to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies regarding the information we are required to provide them for purchase-related transactions.

For these providers, we recommend that you read their privacy policies so that you can understand how your personal information will be handled.

In particular, please note that some providers may be located or have facilities in a jurisdiction different from yours or ours. Therefore, if you wish to proceed with a transaction involving the services of a third-party provider, your information may be subject to the laws of the jurisdictions in which the service provider or its facilities are located.

For example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, your personal information used to complete the transaction may be subject to disclosure under U.S. law, including the Patriot Act.

Once you leave our store’s website or are redirected to a third-party site or app, you are no longer governed by this Privacy Policy or our Terms of Service.

Links

When you click on links on our store, you may be redirected away from our site. We are not responsible for the privacy practices of other sites and encourage you to review their privacy statements.

Cookie Policy

At Lince, we use cookies or other files with similar functionality (hereinafter, "cookies") to offer you better service and provide you with a better browsing experience.

Lince is responsible for cookies and for processing the data obtained through them—whether first-party or third-party—and determines the purpose, content, and use of the information collected.

The purpose of this policy is to provide you with clear and detailed information about what a cookie is, its purpose, the types of cookies we use, and how to configure or, if necessary, disable them.

A cookie is a small text file that is stored in your browser when you visit our website and that records information about your browsing activity to make the user experience more efficient.

Some cookies are essential for websites to function properly, such as technical cookies or cookies used to personalize the user interface, while others—such as analytics cookies or behavioral advertising cookies—require us to inform you and obtain your consent for their use.

Below, and so that you can give your fully informed consent, we detail information about what each type of cookie consists of and its purpose.

Technical cookies are those that allow the user to navigate a website, platform, or application and use the various options or services available on it, including managing and operating the website and enabling its functions and services, such as, for example, identifying the session, accessing restricted-access areas, remembering the items that make up an order, completing the purchase process for an order, managing payment, etc. The website cannot function properly without these cookies, so they are considered necessary.

Preference or personalization cookies allow the website to remember information that modifies the site’s behavior or appearance, so that the user accesses the service with certain features that may differentiate their experience from that of other users, such as, for example, language, the number of results shown when the user performs a search, or the region in which the user is located. If the user themselves chooses these features, for example by selecting the language flag, it is considered an expressly requested service, provided that the cookies are used exclusively for the selected personalization purpose.

Analytics or measurement cookies are those that allow us to understand how visitors interact with web pages and thus perform statistical analyses of how users utilize the services provided. The information collected is used to measure the activity of the websites or the application in order to introduce improvements to the products and services offered by the controller.

Marketing or behavioral advertising cookies store information about user behavior obtained through the continuous monitoring of their browsing habits, which allows for the development of a specific profile to display advertising that is relevant and appealing to that particular user and, therefore, more valuable to third parties.

If you access the site from the European Economic Area, we ask for your consent to analytics and marketing cookies via the notice that appears when you visit, and they are not activated until you accept.

Which analytics tool do we use?

We use Google Analytics to obtain website usage statistics, such as the pages visited, how you arrived at the site, and your device and browser type. Google may process this data on servers located outside the EEA, with the safeguards described in the international transfers section.

We also use Meta Pixel, a marketing cookie from Meta, to measure the effectiveness of our ads on Facebook and Instagram: it records visits and actions on the website, such as requesting access, and lets Meta show our ads to people with similar interests. Meta may process this data outside the EEA, with the safeguards described in the international transfers section. If you access the site from the EEA, it is only activated if you accept cookies in the notice.

If you decline analytics and marketing cookies, Google Analytics and Meta Pixel do not collect data about your browsing. If you accept and later change your mind, you can delete the cookies from your browser, and we will ask for your consent again.

If you disable cookies, you will still be able to access the website, but your browsing experience may not be optimal, and some of the services offered may not function properly.

If, in the future, Lince uses types of cookies other than those described in this Cookie Policy to provide new services, or if it becomes necessary to adapt the policy to new legal requirements, we will notify you.

You can allow, block, or delete cookies stored on your device through your web browser's settings menu, and can configure it to block cookies or notify you when a server wants to save them. The following links provide information on how to configure and/or disable cookies in each of the main browsers on the market so that you can decide whether or not to accept the use of cookies.

• Microsoft Internet Explorer: Tools menu > Internet Options > Privacy > Settings.
• Firefox: Tools menu > Options > Privacy > Cookies.
• Chrome: Options menu > Advanced Options > Privacy.
• Safari: Preferences/Privacy menu.
• Safari for iOS (iPhone and iPad): Settings option > Safari
• Chrome for Android: Settings > Site Settings > Cookies

Security

To protect your personal information, we take reasonable precautions and follow industry best practices to ensure that it is not lost, misused, accessed inappropriately, disclosed, altered, or destroyed.

Age of Consent

Lince’s services are intended exclusively for people aged 18 or over. By using the website or the app, you represent that you are at least 18 years old. We do not knowingly collect data from minors and, if we find that we have received it, we will delete it.

Changes to This Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their publication on the website or in the app. If we make substantial changes to this policy, we will notify you here that it has been updated so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our store is acquired by or merges with another company, your information may be transferred to the new owners so that we can continue to provide you with products and services.

Questions and Contact Information

If you wish to: access, correct, modify, or delete any personal information we have about you; file a complaint; or simply request more information, please contact our Privacy Compliance Officer at info@lince.finance or by mail at Lince LTD. [Office A, RAK DAO Business Centre, RAK BANK ROC Office, Ground Floor, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates]