FairX Privacy Policy

May 25, 2021

1. Purpose and Scope. This Privacy Policy describes how and why LMX Labs, LLC, operating as FairX (referred to herein as “LMX”, “Fair Exchange”, “FairX”, “we”, or “us”), collects and processes personal information in connection with your access and use of Fairx.com including any content, information, systems, services, functionality, or software accessed through or on FairX.com (“Website”).

This Privacy Policy applies only to the information collected as part of the Website. It does not apply to access to the FairX electronic trading platform, whether provided through the Internet or by other means. Access to our electronic trading platforms is limited to participants who have entered into agreements with us for such access, and is governed by the terms of those agreements.

Your use of the Website is subject to the Terms of Use/Site Disclaimer, available at here, including any applicable limitations on damages and the resolution of disputes.

2. Changes to Privacy Policy.This Privacy Policy is current as of the effective date set forth above. We reserve the right to change this Privacy Policy from time to time. Changes and modifications to this Privacy Policy will be effective immediately upon posting of the changes and modifications on the Website, except where prohibited by law. Accordingly, you should periodically visit this page to review the current Privacy Policy. If we change this Privacy Policy, we will notify you of the changes by updating the effective date at the top of this policy and, if required by applicable laws, by other means, such as email or notice. If at any time you choose not to accept the terms of this Privacy Policy, you should not use the Website

3. Collection of Information. We collect personal information from you when you use the Website. The type of information that we collect from you depends on your particular interaction with the Website. We collect information from you directly (such as your registration information), automatically (via technologies such as cookies), and from other sources, including commercially-available sources, such as public databases (where permitted by law).

  1. We require you to register with the Website to access certain features. When we do, we may collect the following information from you during the registration process:
    • Identifying information, such as your name, date of birth, age, address, country of residence, phone number, email address, account password, or other identifying details;
    • Commercial information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
    • Protected characteristics, such as your military status;
    • Education information, such as the information included in your curriculum vitae;
    • Professional information, such as your job title, company, or investor type;
    • Audio, electronic, visual, or similar information, such as photographs or voice recordings; and
    • Your preferences, such as how often you wish to receive marketing or other communications.
  2. We and our third-party service providers use cookies, web beacons, and other tracking technologies to collect information about you automatically as you use our Website. Examples of this type of information include, but are not limited to:
    • Identifiers, such as your IP (Internet Protocol) address, your browser type, your operating system, or domain name; and
    • Internet or other electronic network activity information, such as the dates and times of your use of the Website, the route by which you choose to access them, and your use of any hyperlinks or downloadable content available on the Website.

    For additional information about our use of these technologies, please see our Cookie Policy.

  3. We also collect information about you from third party sources, including suppliers that help us prevent money laundering and fraud; marketing agencies; identity verification services; and analytics providers. The categories of personal information we collect from these sources may include:
    • Identifiers, such as your name or date of birth;
    • Commercial information;
    • Audio, electronic, visual, or similar information, such as photographs or voice recordings;
    • Financial information;
    • Protected characteristics;
    • Professional Information, such as your employer name;
    • Education information; and
    • Internet or other electronic network activity information.

    Please note that we may be required by law to collect and use certain personal information about you. And we may need to collect and use personal information to enter into or fulfill a contract with you. Failure to provide this information may prevent or delay the fulfillment of our obligations in these circumstances. Where you provide personal information to us for purposes of providing Services (“Customer’s Personal Information”), we act as a Service Provider with respect to such Customer’s Personal Information. We will process Customer’s Personal Information consistent with FairX’s Privacy Policy and unless Customer provides prior written approval, we will not collect, retain, use, disclose, or sell Customer’s Personal Information for any purpose other than performing the Services, enabling us to meet its legal and regulatory requirements, marketing our products and services, or product improvement and development.

4. Use of Your Information. We primarily use your personal information to provide our services to you and to respond to your inquiries. We also may use your personal information as follows:

  • To communicate with you, including to respond to your comments or requests for information, to request feedback on our products and services, and to notify you about changes to your subscriptions or to the services and products you use;
  • To help us understand our customers, to tailor and enhance our product and service offerings, anticipate and resolve problems with any products or services supplied to you, create products or services that may meet your needs;
  • To provide access to restricted pages or contents of the Website;
  • To comply with legal and/or regulatory requirements and cooperate with regulators and law enforcement bodies;
  • To facilitate your activity and to identify you when you log into your account on our Website;
  • To send you marketing communications and advertising in line with your communications preferences and where permitted by applicable law about products and services that we believe would be of interest to you, including products and services offered by third parties;
  • To evaluate the success of our advertising campaigns, to improve our products and services, to assess patterns of use, and to plan and evaluate our marketing and business development programs; and
  • To protect our rights, your rights, and the rights of others, and to meet our own high standards of business practice.

5. Disclosures and Onward Transfers. We share your personal information for our business purposes with Third Party Service Providers, to enable us to more efficiently provide the products and services you have requested from us, we may share your personal information with selected entities that act on our behalf as our agents, suppliers, or providers, or these entities may collect your personal information on our behalf. These service providers may provide services such as marketing support, technical assistance, data hosting, payment processing and customer service support. We also engage third-party analytics providers to help us understand how users engage with the Website. These analytics providers may use cookies and similar technologies to collect information about your use of the Website as well as information about your use of other websites over time.

6. Legal Compliance and the Protection of Our Rights. We will share information with regulators, government authorities, and third parties where we believe it is necessary to comply with a court order, subpoena, or regulatory request. We may disclose information when we believe in good faith that such disclosures will help protect our rights or enforce our Terms of Use; support our detection of, prevention of, or response to fraud or intellectual property infringement; help protect your safety or security; or protect the safety and security of the Website, our services, or any individual.

7. Purchases and Mergers. As we continue to develop our business, we might acquire or buy other businesses or assets. In such transactions, customer information generally is one of the transferred business assets. Also, we may transfer any information we have about you as an asset to third parties in connection with the consideration, negotiation, or completion of a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of FairX, or as part of a corporate reorganization or stock sale or other change in corporate control, for the purposes of such third parties carrying on our business in relation to the continued provision of our services to you as described in this Privacy Policy.

8. Additional Sharing of Information. From time to time we share your information with our attorneys, banks, auditors, brokers and other professional service providers and advisors in connection with the purposes described above. The following categories of your personal information may be shared with these parties:

  • Identifiers;
  • Commercial information;
  • Internet or other electronic network activity information;
  • Financial information;
  • Professional information;
  • Education information; and
  • Inferences drawn from any of the above information categories.

9. Your Choices. If you wish to stop receiving marketing information concerning our services or products, or if you wish to withdraw any consent that you have provided, please contact us by email at privacy@fairx.com to notify us of your wishes.

10. Your Rights in relation to Your Personal Information. Subject to local law, you may have certain rights regarding your personal information. These may include, depending on the circumstances, the following rights to: access your personal information; rectify the personal information we hold about you; erase your personal information; restrict our use of your personal information; object to our use of your personal information; receive your personal information in a usable electronic format and transmit it to a third party (also known as the right of data portability); receive additional information regarding the sources from which we collect information, the purposes for which we collect and share personal information, the information of yours we hold, and the categories of parties with whom we share your information; lodge a complaint with your local data protection authority; and withdraw any consent you have given to uses of your personal information. If you would like to discuss or exercise the rights you may have, feel free to contact us via email at privacy@fairx.com.

If you are a registered user of the Website, you may access your personal account information online and make changes by logging into your account.

You may exercise your rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate as permitted by applicable law.

11. Security and Data Integrity. We use technical, administrative, and physical security safeguards and other reasonable security measures to protect the information that we collect or receive against loss and unauthorized access, use modification, or disclosure. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. Moreover, we are not responsible for the security of information that you transmit to us over networks that we do not control, including internet and wireless networks.

12. Children’s Data. The Website and our services are not intended for use by minors (persons under the age of 18). If you are a minor, do not use the Website. If parents believe their minor children have accessed the Website and provided their personal information, please contact us and we will delete the information.

13. Complaints/Comments. We take your privacy concerns seriously. If you have any questions about this Policy or if you believe that we have not complied with this Privacy Policy with respect to your personal information, please contact us at privacy@fairx.com.