Introduction
Upstream Ventures International Limited, trading as Lendingblock, ("Lendingblock" or “we”, “us” or “our”) is committed to processing data in accordance with Data Protection Legislation including but not limited to the General Data Protection Regulation. This Privacy Statement explains how we process, share and store your personal information, our legal basis for doing so, and your rights in relation to the information we hold on you.
Please read this Privacy Statement carefully. This Privacy Statement is subject to change as we are continually reviewing our Data Protection policies and procedures to ensure they meet the highest standards. Please revisit this page from time to time to review any changes that may have been made. This policy is effective from 1st September 2021.
If you are providing us with another person’s personal information you must ensure they have also read this Privacy Policy. By giving us information about another person you are confirming that they have given you consent to provide the information to us.
Lendingblock are the Data Controller in respect of personal information gathered from you when you:
- apply to trade on our platform;
- use our products or services;
- visit to our website https://lendingblock.com (the “Website”);
- contact us;
- make a request/complaint;
- download documents from us;
- subscribe for alerts or newsletters; and,
- attend one of our events, or an event hosted at our premises.
In the event of any conflict between this Privacy Statement and the terms of a contract you have with us, the relevant provision of that contract shall prevail. Nothing in this Privacy Statement shall apply to the extent that it is incompatible with applicable data protection laws.
Applying to trade on our platform, or using our products or services
When you register with Lendingblock either as an individual or as a business, apply to trade on our platform or use our products and services and provide personal information, we will use this to process and administer your platform account and relationship with Lendingblock. This includes, but is not limited to:
- Carrying out checks in order to verify your identity, documents submitted, and information provided,
- Setting up, administering and maintaining client records,
- Administering and monitoring transactions,
- Providing information on our products and services,
- Providing marketing communications,
- Enforcing contractual terms,
- Performing ongoing client, due diligence, and transaction reviews,
- Complying with legal obligations,
- Preventing and investigating potentially prohibited/illegal activities,
- Ensuring compliance with platform rules,
- Providing support or administrative information to you and other platform users,
- Resolving disputes, complaints or troubleshooting,
- Ensuring quality and services standards,
- Evaluating usage of the platform, products or services offered by Lendingblock.
This may include sharing your personal information with:
- Identity Verification Service Providers
We use Identity Verification Service Providers to verify identity and carry out a search for sanctions and politically exposed persons in accordance with our legal obligations.
- Third party providers providing transaction monitoring services
We use a ‘Know Your Transaction’ provider to monitor transactions on the platform and ensure compliance with our legal obligations.
- Third party cloud data storage providers
We use Cloud Data Storage to store and backup data.
- Client Relationship Management (CRM) software providers
We use CRM providers to provide client management and business development services.
We ensure that all third-party providers that process and store data on our behalf do so under contracts which state data protection requirements equivalence, such as the EU-US shield.
We process this information for the performance of a contract with you, to comply with legal obligations and for our legitimate interests (to keep our records updated and review our product offering).
Visitors to our websites
When someone visits lendingblock.com we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
We process this information for our legitimate interests (to monitor use of the website and improve the service provided).
If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Contact us
Email
We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with the Lendingblock information security policy. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Make a request or complaint
When we receive a request or complaint from a person, we make up a file containing the details of the request or complaint. This normally contains the identity of the requestor or complainant and any other individuals involved in the request or complaint.
We will only use the personal information we collect to process the request or complaint and to check on the level of service we provide. We may compile and publish statistics showing information like the number of requests or complaints we receive, but not in a form which identifies anyone.
We usually have to disclose the requestor or complainant’s identity to whoever the request or complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. If a requestor or complainant doesn’t want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a request or complaint on an anonymous basis.
We will keep personal information contained in request or complaint files in line with our retention policy. This means that information relating to a request or complaint will be retained for six years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Similarly, where enquiries are submitted to us, we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.
We process this information for the performance of a contract with you, and for our legitimate interests (to improve our products and services).
Categories of Personal Information
The categories of personal information we may collect and process include, but are not limited to: Name, Address, Date of Birth, Nationality, Contact Details, Financial Information, Identity Documents, Tax Information, Wallet Addresses, Employment Information, Regulatory Status.
Retention Period
We will only retain your personal information for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
We will only retain your personal information for as long as necessary to fulfil the purposes we collect it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Individual/Business information obtained for the application of a trading account on the platform or using any Lendingblock products/services will be retained for the duration of your relationship with Lendingblock and for a period of 6 years after ceasing to be a Lendingblock client.
We may anonymize your information (so that is can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
International Data Transfers
When we share data, it may be transferred to, and processed in, countries other than the country you live. For example, the United States, where some of our data processors and their data servers are located. These countries may have laws different to what you’re used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data. For example, by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
Links to other websites
This Privacy Statement does not cover the links within our Website linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Your rights
Under certain data protection laws and regulations you have rights as an individual which you can exercise in relation to the information we hold about you. You can read more about these rights here: https://ico.org.uk/your-data-matters/
Under the General Data Protection Regulation you have the following rights:
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Right to be informed – be informed on your data rights, how we collect, use, share, and store your personal data,
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Right to access – access to your personal data which we have processed,
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Right to rectification – request we correct any mistakes in your information which we hold,
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Right to be forgotten/Right to erasure – request the erasure of personal data we hold concerning you in certain situations,
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Right to data portability – request the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations,
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Right to object – object at any time to processing of personal data concerning you for direct marketing, processed on the basis of legitimate interests only, or processed for scientific/historical research and statistics.
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Right to restrict processing - otherwise restrict our processing of your personal data in certain circumstances,
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Rights on automated decision making (including profiling) – Automated decision making may only be carried out where the decision is:
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necessary for the entry into or performance of a contract;
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or authorized by Union or Member state law applicable to Lendingblock; or
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based on Your explicit consent. (You may notify us at any time if you wish to withdraw your consent).
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You have the right to object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
If you wish to invoke your data rights, please contact our Data Protection Officer at the below email addresses:
Complaints or queries
Lendingblock tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring any issues to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
If you would like to make a complaint of have a query you’d like to raise, please send details to one of the below addresses: