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Privacy Policy


Updated: July 1, 2019

SCOPE


This Privacy Policy explains what information is collected by Legend OTC Inc. (“we”, “us”, “Legend”, why we collect it, and how we treat your information. By visiting, accessing, or using Legend, you have indicated that you are at least eighteen (18) years old, have the legal capacity to consent to this Privacy Policy, and to agree to be bound by the policies and practices of this Privacy Policy in their entirety.

Legend reserves the right to change any of its policies and practices at any time.

DIGITAL CURRENCY


As used herein, “Digital Currency” means a digital asset (also called a “cryptocurrency,” “virtual currency”), such as, but not limited, bitcoin or ether, which is based on a cryptographic protocol(s) of an electronic system that may be (i) centralized or decentralized, (ii) proprietary or open-source, and (iii) used as a medium of exchange and/or store of value.

INFORMATION WE COLLECT


Section 326 of the USA PATRIOT ACT requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This federal requirement applies to all Legend counterparties. This information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities. Legend voluntarily complies with the USA PATRIOT ACT. When you complete an application we ask you for your name, address, date of birth, and other identifying information. For more details, please see below Section 4.

VERIFICATION INFORMATION


Legend collects information that you provide during a completed, incomplete, or abandoned application. This may include the information set forth below.

Individual Counterparties

Legend attempts to collect, verify, and authenticate the following information from individual counterparties:

Institutional Counterparties

Legend attempt to collect, verify, and authenticate the following information from institutional counterparties:

DEVICE INFORMATION


Information that is automatically collected about your device (such as, but not limited to, hardware, operating system, browser, etc.).

LOCATION INFORMATION


Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us.

LOG INFORMATION


Information that is generated by your use of Legend that is automatically collected and stored in our server logs. This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to Legend pages that you visit.

TRADING INFORMATION


Information that is generated by your trading activity including, but not limited to trading activity and wallet addresses.

CORRESPONDENCES


Information that you provide to us in correspondence, including opening an application, and with respect to ongoing customer support.

COOKIES


When you access Legend, Legend may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit Legend. Cookies are small bits of information that are automatically stored on the web browser of your device that can be retrieved by us. The type of information we collect includes, but is not limited to, uniquely identifying visitor information and information related to your usage preferences. Legend use these technologies to help us recognize you as a user, collect information about your use of Legend to better customize our services and content for you, and collect information about your computer or other access devices to (i) ensure compliance with our BSA/AML Program and (ii) ensure that your account security has not been compromised by detecting irregular or suspicious account activities. By using Legend, you acknowledge and agree that we may collect and/or transmit any data collected to our third-party service providers, such as analytics providers, which may also make use of such technologies described above.

Please note that if you block or delete cookies you will not be able to use some or all of Legend. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use Legend.

HOW WE USE INFORMATION WE COLLECT


The information collected and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve Legend.

We may share information with trusted and contracted third-party service providers (including those that may be located outside of the United States or your country), who help us operate our platform and systems, and detect fraud and security threats throughout the normal course of our business. Such third-party service providers are subject to confidentiality obligations. In addition, we may be compelled to share information with law enforcement, government officials, and regulators.

For example, we may use your information to:

We do not sell customer information to third parties for the purposes of marketing.

Be aware that bitcoin, ether, and other Digital Currencies are not anonymous. Anyone can see the balance and transaction history of any Digital Currency address (public key). We, and any others who can match your Digital Currency address (public key) to other information about you, may be able to identify you from a blockchain transaction. This is because information published on a blockchain can be correlated with information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such information about you. You acknowledge and agree to allow us to perform such practices.

HOW WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES


We may share your personal information with:

DIRECT MARKETING


Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from you.

SUBMISSIONS


Legend cannot agree to obligations of confidentiality or nondisclosure with regard to any unsolicited information you submit to us, regardless of the method or medium chosen. By submitting unsolicited information or materials to Legend, you or anyone acting on your behalf, agree that any such information or materials will not be considered confidential or proprietary.

Transmission of information via regular email is inherently insecure – so please DO NOT do so. Contact us if you need to submit sensitive personal information and we can arrange for a method of secure transmission. The definition of sensitive personal information varies from jurisdiction to jurisdiction. For your own protection, assume all of your information to be sensitive and act accordingly.

CHANGES


Legend reserves the right to change this Privacy Policy from time to time to meet our changing needs.