Effective Date: 01 JUN 2025
1. Introduction
Privacy is paramount at the L1CT Solutions Pvt Ltd and its affiliates (“We”, “Our” “L1CT” or “Company”). We acknowledge the significance of the privacy and are committed to take reasonable precautions and measures to safeguard users’ personal information or sensitive personal information that is shared with L1CT and adhering to applicable laws regarding such data. This Policy provides Our collection, use, disclosure and retention of information that is collected from users.
By using Our website or application, you hereby irrevocably represent that you are major and you have given your consent to allow any of your minor dependents to use this website or application. You further accept the terms of this privacy policy (“Policy”) and Our
If you do not agree to the terms of this Policy, kindly refrain to use Our website or application. The Company reserves a right to amend this Policy and publish the same to Our platform. Your continued use of Our website and application shall mean you accept the amended terms.
This Privacy Policy does not apply to information that you may submit to third-party websites or mobile applications that may link to the Websites or be linked to on the Websites. We are not responsible for the actions or privacy practices of third-party websites and applications; please consult those websites and applications directly to understand their privacy practices.
2. Definitions
For the purpose of this Policy, the below terms shall have the following meaning:
2.1 “Applicable Laws” means any applicable law relating to the processing of personal Data, including the GDPR (the General Data Protection Regulation (EU) 2016/679) and the Information Technology Act, 2000, as amended or substituted.
2.2 “Grievance Officer” or “Data Protection Officer” shall mean the person appointed by the Company to address queries and grievances which a provider of Personal Information (as defined below) or Sensitive Personal Data or Information (as defined below) may raise with the Company
by sending an email at
2.3 “Personal Information” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying such person.
2.4 “Sensitive Personal Data or Information” with reference to a person means such personal information which consists of information relating to:
(i) password;
(ii) financial information such as Bank account or credit card or debit card or other payment instrument details ;
(iii) physical, physiological and mental health condition;
(iv) sexual orientation;
(v) medical records and history;
(vi) biometric information;
(vii) any detail relating to the above-mentioned classes of information as provided to the Company corporate for providing services; and
(viii) any of the information received under the above-mentioned classes of information, by the Company for processing, stored or processed under lawful contract or otherwise Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of this Policy.
Provided that, any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as sensitive personal data or information for the purposes of this Policy.
2.5 “Services” means [add].
3. Personal Data collected
When accessing/using, We gather Data for providing you a seamless and personalised experience of Our Services.
3.1
User-provided information:
Data furnished through web forms, application(s), or communications. This includes information you provide when you sign up or register or login to the website or mobile application of the Company, as well as when you report any issues or problems with the website or application.
3.2 Details we automatically collect concerning the user: In relation each time, you visit Our website or application We automatically gather the following Data:
(i)
User Login Information:
We collect technical logs on your Service usage, including browser type/version, wallet identifier, last wallet access time, the IP address used for wallet creation, and the most recent IP address for wallet access.
(ii)
Device Specifics:
We collect device information (e.g., hardware model, OS version, unique identifiers) for account access, but it’s anonymized and not tied to any individual. Wallet Information If you create an Company wallet through Our Services, you will generate a public and private key pair. Upon logging out of your Wallet, we gather an encrypted file containing keys and transaction history. Enable notifications requires collecting the unencrypted public key from your account settings. We never collect unencrypted private keys from you or decrypt any Wallet file data.
(iii)
Transaction Specifics:
As per Our Conversion Service (as defined, in Our
(iv)
KYC:
Complete name Residential address Contact data (phone number, email address) Date and place of birth, gender, and citizenship Bank account information, as well as a credit card, details of Your "PEP status "source of funds & Proof of funding, and address to prove your identity, carry your passport, national driver's license, or government-issued identification card. Transaction histories and account balances related to your use of specific Services.
(v)
Cookies:
This website may place and access certain cookies on your device (including computer, mobile). The Company uses the cookies to improve your experience of this website.
We process personal data obtained through cookies according to Our privacy policy. If your browser allows it, you may refuse cookies, but this may impact website functionality. Banks or payment processors may provide basic personal data, while advertisers and analytics providers may share anonymized information about how you arrived at Our website
(vi)
Information Obtained from Other Sources:
We also combine information from other sources with information gathered via Our Services.
For Instance:
We utilize third-party services that may be co-branded as affiliate entity but We will make this explicit. Any third-party services may collect information as determined by their privacy policies.
4. PROCESSING OF PERSONAL INFORMATION
4.1 We strive to fulfill your preferences, improve Our Services, manage Our operations, respond to your requests, prevent fraud, and comply with legal and regulatory requirements under Applicable Laws. We may also analyze aggregated personal data to understand user behaviour, as long as it does not identify any individuals.
4.2 We analyze user interactions on Our website using third-party web analytics tools with first-party cookies to improve it. Reports are generated to provide overall website trends without identifying individual users. You have the option to disable these third-party analytics without affecting your interaction with Our website.
4.3 We’ll handle your data lawfully and fairly, using it only for the purposes of rendering Services or any other reason mentioned in this Policy or communicated to the users from time to time. The Company does not sell user’s information, either individually or in the aggregate, for commercial purposes.
5. DISCLOSURE OF PERSONAL DETAILS
5.1 We may share your information with:
(i) Our employees, vendors, agents and professional advisors in relation to the Services;
(ii) Company controlled affiliates and subsidiaries to assist them for provisioning of Services or to prevent or investigate the suspected fraud or illegal activity or any other unauthorised activity;
(iii) service-providers who assist in protecting and securing Our systems and provide services to us which require the processing of personal data, such as to host your information or to process your information for data profiling and user analysis;
(iv) We may share the Personal Information with a third party including an acquirer or successor or prescribed authority under Applicable Law in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all assets, as going concerned or part of bankruptcy, liquidation of the Company or its affiliates.
5.2 We usually do not share other personal Data collected from the Website with other third parties. However, this may happen if:
(i) You request or authorize us to do so;
(ii) We need to comply with applicable law or respond to valid legal process; or
(iii) We need to operate and maintain the security of this website, including to prevent or stop an attack on Our computer systems or networks.
5.3 Cloud providers store personal data for disaster recovery and contract performance. Fraud detection providers run checks on personal data to prevent fraud. Spam and abuse detection providers offer software to prevent unsupported use of the service.
5.4 Unless We are legally obligated to share your data or are not subject to any legal condition related to it, we will require any individual or entity We share your data with to agree to abide by Our privacy policy or a policy that is similar to it. We will make reasonable efforts to ensure that they comply with the policy, but We will not be liable to you if they fail to do so, except if were prohibited by law.
5.5 Some services may record your funding and transaction information on a public blockchain, which is a distributed ledger for recording transactions on a wide network of computer systems. Public blockchains can be subjected to forensic analysis, which may lead to the unintentional disclosure of private financial information when combined with other data, potentially resulting in deanonymization.
5.6 As blockchains, are decentralized or third-party networks beyond Company’s control, We cannot modify or erase Personal Information stored on them.
6. SAFEGUARDING YOUR DATA
We protect Personal Information with physical, technological, and organizational safeguards. information sent over the internet is subject to its routes and means. But We regularly audit Our procedures and security measures to ensure effectiveness. All members of Company are committed to Our Policy. Our website and mobile application has reasonable security measures in place to prevent the loss, misuse, and unauthorized alteration of the information under Our control. Our server uses TLS encryption to protect personal data in transit over the internet.
7. RETENTION OF YOUR DATA
7.1 We retain personal data for different periods depending on why it was collected. Data provided when subscribing to Our services, country location data, data on preferences, and IP address login are stored in Singapore while users remain active. When data is no longer needed, We will remove identifying details or securely destroy records. However, We may need to retain records for a longer span due to regulatory requirements, such as anti-money laundering laws, which mandate retention for 5 years after the business relationship ends.
7.2 We retain records for due diligence and transaction history for legal and regulatory purposes. Personal data is disposed of when no longer needed, and opt-outs are added to Our suppression list.
7.3 After the termination of Services, your information may be kept in the aggregated format as part of Our backup procedures. We will only process your social security number in compliance with federal and state laws and only when necessary for the relevant service or product. We have executed technical and organizational measures to protect the security of your SSN, restrict access to authorized employees, process it only for its stated purpose, share it externally only when legally necessary for the requested service, and dispose of it securely in line with Our retention practices.
8. PRESERVATION OF CONFIDENTIAL INFORMATION
Company stores and secures your Data in the EU, but may transfer it to other company subsidiaries, service providers, and business partners outside the EEA and Singapore. Such transfers will be lawful and comply with GDPR and the Singapore Data Protection Act 2018. Standard contractual clauses may be used for transfers processed in the United States.
9. YOUR RIGHTS
The following outlines your obtainable rights regarding your Personal Information collected or stored or processed by the Company:
9.1 Information Access
If you ask us, We will confirm whether We are processing your Personal Data and, if so, what information We process and, if requested, provide you with a copy of that information within 30 days from the date of your request.
9.2 Amendment
We strive to keep your Data accurate and up-to-date. If We hold incorrect or incomplete information about you, you have the right to have it corrected. We will also notify any third parties with whom We have shared your information of any updates, if possible and lawful. To update your information, please email Us at privacy@ L1CT Solutions Private Limited. We may require supporting documents for legal purposes.
9.3 Erasure
You have the right to request the deletion of your data in certain circumstances, such as if We no longer need it and have no legal obligation to keep it. Any such requests will be subject to agreements you have with us and any applicable laws. If We’ve shared your data, We’ll let others know about your request and may also inform you of whom We shared it with. so that you can contact them directly.
9.4 Processing constraints
You can request to block or suppress the processing of your information in certain situations, such as if you dispute its accuracy or object to its processing. However, We will still store your data. We'll notify you before declining any requested restrictions and inform others of the processing limitation where possible. If you ask, We'll also tell you whom We've shared your data with, if possible and legally.
9.5 Data portability
In some cases, you may have the right to receive your Personal Data (in a machine-readable format), reuse it, or have it transferred to a third party of your choosing.
9.6 Objection
You have the right to request for stoppage of processing of your Personal Data if We are relying on Our own or someone else's legitimate interests to process it (unless We can demonstrate compelling legal grounds), processing it for direct marketing, processing it for research (unless necessary for public interest), or making decisions about you based solely on automated processes or profiling (unless necessary for a contract). If We cannot offer Our Services without such processing, We may need to terminate Our relationship with you. Contact us at
10. AMENDMENT
If there are any changes to this Policy, the revised policy will be posted on the website of the Company, and the same shall be notified to the users. Please visit this page regularly to keep yourself informed of any changes or updates to this Privacy Policy. You are deemed to have accepted the terms of the Policy on your first use of the website following the alterations.
11. GENERAL
11.1 If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
11.2 This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.
11.3 Company shall not be responsible in any manner for the authenticity of any information supplied by the user to Company. If a user provides any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Company has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Company has the right to suspend or terminate the Services at its sole discretion.
12. DISPUTE RESOLUTION FOR ALL USERS
12.1 This Privacy Policy shall be governed by the laws of India. Any and all disputes arising under or in relation to this Privacy Policy shall be subject to the exclusive jurisdiction of courts in Bangalore, India.
12.2 Section 12 survives termination of the Services.
13. INQUIRIES AND GRIEVANCES
For any inquiries regarding this Policy, the collection, use, and disclosure of your data by Company, or if you need access to your data as required by law, please contact us at Our Grievance Officer of the Company. If you have any grievances about how We handle your data, please first contact us at below-mentioned email id or by sending a letter marked to the attention of “Grievance Officer” at below address, and We will make every effort to address your concerns promptly.
Email Id: privacy@l1ct.com
This is without prejudice to your right to file a complaint with the data protection supervisory authority in your country of residence or work if you believe that We have violated data protection laws.