Privacy Policy
Last Updated: February 12, 2025
1. General
- 1.1. We at Leveraged Capital Management (“We”, “Company”, “Leveraged”, “Us” or “Our”), are committed to protect your (“You”, “Your” or “User”) Personal Data (as defined below) and Your privacy.
- 1.2. This privacy policy (the “Policy”) is intended to provide you with all the information regarding the data we may collect while you use our website www.getleveraged.com (the “Website“) and/or any of our services via the website or via other means of communication with us (collectively, the “Services”), as well as to provide you with details of how and when we may collect your data, for which purposes we may process your data and under which conditions we may use and/or transfer your data.
- 1.3. This Policy is part of and should be read in conjunction with Our Terms of Use.
- 1.4. By accessing and using the Website or the Services, You confirm that You have read, understood, and agree to be bound by the terms of this Policy.
- 1.5. In this Policy, any reference to “Personal Data” is to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or in combination with additional information that we are in possession of or which we can have access to.
2. Data collection
- 2.1. We (or others on Our behalf) may collect your Personal Data in the following situations:
- 2.1.1. When You view, access, or use our Website or any of its functions. 2.1.2. When You engage with our Services in any manner.
- 2.1.3. When You interact with Us through any channel, including messages sent via third-party messaging applications or by submitting Personal Data through the Website.
3. Types of Personal Data We collect?
We (or others on Our behalf) may collect the following types of Personal Data about You:
- 3.1. Website or Services usage information. This includes online activity logs and traffic data such as IP address, time and date of access, web and mobile pages visited, language preferences, crash reports, browser type, and information about the device You use. Some of this information may not personally identify You and, therefore, may not constitute Personal Data.
- 3.2. Website or Services activity information. When You use the Website, We may monitor and record Your activity. This includes actions performed on the Website or Services, such as trading activity, the duration of content viewed or used, and interactions with various features or content on the Website. We may also receive trading activity data from the Services to enhance Your experience and optimize functionality.
- 3.3. Registration Information. When You create an account with Us, You may be required to provide information that identifies You, such as Your full name, contact details (i.e. email address, phone number) country of residence, and other details as needed by the Company for registration or account creation. Required fields will be clearly marked, while additional, optional fields may be provided to customize the Services to Your needs and preferences.
- 3.4. User and portfolio Information. When You participate in Our portfolio management services and depending on the different phases you have completed and participated in, We may collect data such as Your full name, contact details (i.e. email address, phone number), phases details, investment amounts, funds received from Us, payment methods, and portfolio behavioral information. This information will be used for purposes such as analysis, strategy development, user evaluation, and fraud prevention.
- 3.5. Communication information. When You contact Us – either via the Website, through Our contact details, or other channels, including the “Contact Us” section – or when you subscribe to Our newsletter or other mailing, messaging or notification updates, You may be required to provide Your contact details, full name, and the subject and content of Your communication.
- 3.6. Know-Your-Customer (“KYC”) information. When You sign up to our platform/s, We may require You to provide additional information, either directly to Us or to third parties acting on Our behalf. This is necessary for compliance with KYC and Anti-Money Laundering regulations, as well as other legal requirements and best practices for licensing and service provision.
- 3.7. Aggregate Information. We create statistical, aggregated, and anonymized data about Our Users and Services for analytical purposes, including business development and improving Our offerings. This aggregated data may be shared with third-party partners. Although derived from personal and user data, aggregated data does not identify individual users or relate to any specific individual’s data. It helps Us better understand Our customer base and refine Our Services.
4. The Legal Basis for The Processing of Personal Data
The legal bases according to which the Company may process Personal Data about You are as follows:
- 4.1. Consent. Your consent may be required, implied or explicit, if the Company will process Personal Data about You for one or more specific purposes (as detailed further below) which you have requested us to provide. For example, for the purpose providing services you have requested or signed up for, to respond to your queries, sending marketing materials that you have signed up for, etc.
- 4.2. Legitimate Interests. If processing is required for the provision of the Services or for other legitimate interests pursued by Us or by a third party (as detailed further below). For instance, to improve Our Services, the data collected during Your use of the Services may be utilized to enhance the Website or the Services, or for the purpose of exercising or defending legal claims.
We will not process Personal Data about You unless there is a legal basis for such processing.
5. Purposes for Use of Your Personal Data
- 5.1. We may use Personal Data about You for the following purposes:
- 5.1.1. To operate and manage the Website and Services.
- 5.1.2. To contact You for operational purposes.
- 5.1.3. To personalize content and offers tailored to You.
- 5.1.4. To respond to Your queries, requests, or complaints.
- 5.1.5. To send You information about the Services, events, or other materials We believe may interest You, subject to Your consent.
- 5.1.6. To analyze and improve the Services, as well as to develop and introduce new ones.
- 5.1.7. To analyze and track usage, assess the usefulness or popularity of content, and gain a better understanding of user activity on the Website. 5.1.8. To monitor and analyze trends, usage patterns, and activities related to the Services.
- 5.1.9. To perform and support various activities essential to offering and maintaining the Services, such as back-office functions, business development, strategic decision-making, financial management, and third-party service integrations.
- 5.1.10. To protect Our interests, rights, and assets, as well as those of third parties, including detecting, investigating, and preventing fraud, unauthorized actions, or illegal activities, and to initiate, exercise, or defend legal claims.
- 5.1.11. To perform Know-Your-Customer (“KYC”) checks.
- 5.1.12. To comply with legal or regulatory obligations..
6. Not Providing Personal Data and Its Implications
- You are not obligated to provide Us with any Personal Data. However, in some cases, failure to do so may limit or prevent Us from providing Our Services, in whole or in part, or granting full access to the Website.
7. Sharing of Personal Data with Third Parties
- 7.1. We will not share Your Personal Data with third parties except as outlined in this Policy.
- 7.2. We may transfer Personal Data according to the below:
- 7.2.1. To entities that control Us, are controlled by Us, or are under common control or ownership with Us (collectively referred to as the “Group“). These entities may use the Personal Data to support the Group’s operational needs;
- 7.2.2. With Your consent or as per Your instructions.
- 7.2.3. In the event of a sale, assignment, or transfer of some or all of Our business or assets to a successor or acquirer; if We are acquired by or merge with a third party; or in cases of bankruptcy, insolvency, or other similar situations where Personal Data may be transferred to a successor or acquirer.
- 7.2.4. If We are subject to an audit or a due diligence process.
- 7.2.5. To protect Our rights, property, and interests or those of third parties. 7.2.6. To comply with legal or regulatory obligations, national authority requests, or court orders;
- 7.3. In addition to the above, We may share Personal Data with third parties that provide Us with services, including but not limited to:
- 7.3.1. Storage and hosting providers, including cloud computing and data security services.
- 7.3.2. IP address management and related services.
- 7.3.3. User experience analysis.
- 7.3.4. Support and customer service providers.
- 7.3.5. Marketing and advertising services.
- 7.3.6. CRM (Customer Relationship Management) data management services. 7.3.7. KYC (Know-Your-Customer) service providers.
- 7.3.8. Third-party services and integrations.
- 7.3.9. Accounting, legal, and compliance services.
- 7.3.10. Research, analytical, technical, and diagnostic services.
- 7.4. We may share aggregated information with Our third-party partners. This information is in a summarized form and does not relate to or identify any specific User.
8. Retention
- We will retain Your Personal Data only for as long as necessary to fulfill the purposes for which it was collected. If required, we may keep Your Personal Data for extended periods to comply with applicable legal obligations.
9. Cookies and Trackers
- please refer to our Cookie policy
10. Security
- We have implemented appropriate technical security measures and relevant security policies to protect the Personal Data under Our control from unauthorized access, misuse, disclosure, alteration, or unlawful destruction.
11. Links to Other Websites
- 11.1. This Website may include links to third-party websites or applications, which may also reference or link back to Our Website. Please note that We do not control these third-party websites or applications, nor their collection and processing of Personal Data. As a result, We are not responsible for their privacy practices, and this Policy does not apply to any actions taken on or via such websites or applications.
- 11.2. If You access third-party websites or applications, We advise You to carefully review their privacy policies and terms of use before using them or sharing any Personal Data.
12. Personal Data Rights
- 12.1. You have the right to request information from Us, including confirmation of whether We are collecting Personal Data about You. You may also request to review such data, rectify it if necessary, or request the erasure of Personal Data that is no longer required by Us. Additionally, You may restrict or withdraw Your consent to certain processing activities involving Your Personal Data.
- 12.2. You are entitled to exercise the following rights concerning Your Personal Data. To do so, You may send a request to [email protected]
We will honor Your right to receive information about how Your Personal Data is processed by Us: - ▪ to rectify any inaccuracy in Your Personal Data;
- ▪ to erase Your Personal Data processed and stored by Us;
- ▪ to restrict the processing thereof or object thereto if applicable under the circumstances;
- ▪ the right to receive the Personal Data about You, which You have provided to the Company, in a structured machine-readable manner; and the right to withdraw Your consent when such is the legal basis of Our processing.
- 12.3. We may reject Your requests if they infringe on the rights and freedoms of others or conflict with legal requirements applicable to Us. Additionally, We may charge a reasonable fee where permitted.
- 12.4. You have the right to lodge a complaint with a supervisory authority established by a Member State of the European Union to protect the fundamental rights and freedoms of individuals concerning the processing of Personal Data.
- 12.5. Please note that We may require Personal Data from You to verify Your identity before allowing You to exercise Your rights.
- 12.6. If the legal basis for processing Your Personal Data is consent, You may withdraw Your consent at any time, free of charge, for the purposes for which it was provided. To do so, please send a notice to the following email address: [email protected]
- 12.7. We may provide You with personalized offers, connecting You to products or services relevant to You. This may include ads, offers, and sponsored content related to Our products and services or those of third parties. Such personalization is based on the processing of Personal Data to align materials with Your preferences, behavior, characteristics, and interests.
- 12.8. You may withdraw Your consent to receive marketing materials via email at any time by sending an email with the subject “unsubscribe” to [email protected] or by clicking the unsubscribe link in any marketing email. To withdraw consent for marketing via push notifications, You can adjust Your mobile device’s settings.
- 12.9. If You withdraw Your consent for the processing of Your Personal Data, We may not be able to provide some or all of the Services You requested or deliver them in their intended form. In such cases, You will have no claim against Us.
- 12.10. At any time, You may contact Us at [email protected] to request information regarding the review We conducted to determine that the processing of Your Personal Data is necessary for the legitimate interests pursued by Us or a third party.
- 12.11. Please note that opting out of marketing communications does not affect Our ability to contact You with non-marketing information about Our services or for other legitimate, non-marketing purposes.
13. Transfer of Personal Data
- 13.1. Personal Data about You may be transferred to a third country (i.e., a jurisdiction outside of Your residence) or to international organizations. In such cases, We will implement appropriate technical and organizational measures to protect Your Personal Data and ensure that enforceable data subject rights and effective legal remedies are available.
- 13.2. If You are a resident of the European Economic Area (EEA), these safeguards and protections will be provided if any of the following conditions are met::
- 13.2.1. The transfer is to a third country or international organization that the EU Commission has determined provides an adequate level of protection for Personal Data, as per Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”);
- 13.2.2. The transfer is based on a legally binding and enforceable instrument between public authorities or bodies, in accordance with Article 46(2)(a) of the GDPR; or
- 13.2.3. The transfer is conducted under standard data protection clauses adopted by the EU Commission, pursuant to Article 46(2)(c) of the GDPR
You may request details about the safeguards the Company has implemented to protect Your Personal Data when transferred to a third country or an international organization by sending an email to: [email protected].
14. Changes to the Policy
- 14.1. We may update this Policy from time to time. When changes are made, We will notify You by publishing the updated Policy on the Website. For significant amendments, We will make reasonable efforts to inform You through appropriate communication channels and by posting a notice on the Website. Unless stated otherwise, all amendments will take effect upon publication of the updated Policy on the Website or its designated page.
15. Contact Us
- 15.1. For any questions regarding this Policy or the protection of Your Personal Data, please contact Us at the following email address: [email protected]