L&M Group Holding Company Inc. and its wholly-owned subsidiaries (collectively, "L&M Group," "Company," "us," "our," or "we") have created this Privacy Notice and Privacy Policy to demonstrate our Company's commitment to the privacy of a) users of the L&M Group website (hereinafter, "users"); b) L&M Group's customers and potential customers; c) L&M Group's participants, members, users, and related entities and representatives; and d) any other persons whose personal information L&M Group collects in the course of its business activities. This Privacy Notice and Privacy Policy describe the personal data we collect, how L&M Group uses your personal data, with whom we may share this data, and how you can contact L&M Group, access your personal data, and exercise your rights regarding L&M Group's use of your personal data. Your personal data is collected for specified, explicit, and legitimate purposes and is not further processed in a manner incompatible with those purposes, in accordance with this Privacy Notice and Privacy Policy, and applicable data protection laws to which L&M Group is subject. By using or visiting our website, registering with L&M Group, and to the extent required or permitted by applicable law, you confirm your consent and agreement to L&M Group's collection and processing of information about you in accordance with this Privacy Notice and Privacy Policy.
When We Collect Data
We may receive your personal data when you use or visit our website, attend L&M Group-sponsored events, sign up for L&M Group newsletters or educational programs, visit L&M Group facilities, apply for a job with L&M Group, become a controlling person or ultimate beneficial owner of one of L&M Group's companies and are required by law to provide information about you for regulatory purposes, or apply to become an L&M Group client. We may also receive your personal data from third parties, including third-party partners, apps, advertising networks, government agencies, regulators, and other companies and organizations engaged in market research. Your personal data may also be collected for authentication and security purposes in accordance with applicable law.
Depending on the specific products, services, business relationships, or websites (and as required by applicable law), L&M Group may collect the following categories of personal data about you, either directly or from third parties, in accordance with applicable law.
Identification Data:Includes first name, last name, username, social media username, photo, employment information, career or professional experience, education, passport or government-issued identification or similar identifiers.
Contact Data:Includes address, email address, mailing address, business contact information, and telephone number.
Transaction Data:Includes bank account information, financial assets, as well as transaction, position, and other information about the services L&M Group provides to you as a client.
Technical Data:Includes IP address, your login credentials, browser type and version, cookies, log files, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access L&M Group websites and online services.
Profile Data:Includes your username, password, preferences, or responses to reviews.
Usage Data:Includes statistical data, analytics, trends, and information about the use of our systems, products, and services, such as activity logs and other aggregated quantitative data.
Marketing and Communications Data:Including your preferences in receiving marketing materials from L&M Group and your communication preferences.
L&M Group may also collect, use, and share aggregated data, such as statistical or demographic data, which may be used and processed after your relationship with us ends. Aggregated data derived from your personal data is not considered personal data because this data is anonymized and does not directly or indirectly reveal your identity.
In some cases, L&M Group may collect and process sensitive personal data. L&M Group will collect sensitive personal data only in accordance with applicable law, including, where necessary, with the individual's consent.
Identifiable data: Includes criminal records for the evaluation of individuals with access to L&M Group facilities/systems and/or control persons, as well as race/racial origin data to facilitate background checks.
Unless otherwise provided in this Privacy Notice and Privacy Policy, the following discloses our
data processing and dissemination practices.
L&M Group values your privacy and
processes your personal data as a data controller in accordance with applicable data protection laws. Processing means any operation or set of operations which is performed on
personal data or sets of personal data, whether or not by automated means, such as
collection, recording, organization, structuring, storage, adaptation or alteration,
retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure, or destruction.
L&M Group
will collect and process your personal data only where there is a lawful basis to do so. Legal bases may include:
Consent:L&M Group will use or process personal data if the data subject has given consent to the processing of their personal data for one or more specific purposes. L&M Group may use or process your personal data for direct marketing if you expressly agree to receive direct marketing communications via email. You may withdraw your consent at any time. If you no longer wish to receive marketing communications and would like to withdraw your consent, please see the "Choice/Opt-Out" section below.
Contractual Obligation:L&M Group may use or process personal data if the processing is necessary for the performance of a contract.
Statutory Obligation:We will use or process personal data as necessary to comply with a legal or regulatory obligation to which we or our affiliates are subject. This includes using or processing personal data to: (a) defend against claims and satisfy any governmental reporting obligations and requests, (b) monitor compliance; and (3) detect, investigate, and prevent fraud and other criminal threats or activities.
Legitimate Interests:We will process your personal data for any other legitimate interests not described above. These include analyzing the use of our website or services, tailoring website and news content, customizing preferences on our website or in email newsletters, improving our websites, offering and managing programs and events, assessing which products and services may be of interest to individuals, fulfilling our obligations to our customers and others, and managing relationships with customers and suppliers.
We use your personal data only for the purposes expressly described in this Privacy Notice and Privacy Policy. If we use or disclose your personal data for any purpose that is additional or different from the purpose originally stated at the time of collection, the new use is fair, lawful, and transparent and complies with the legal basis and notice requirements set forth above and those set forth above.
To the extent provided for by applicable law, each purpose for processing personal data is justified by a legal basis for processing. L&M Group processes your personal data for certain purposes, which may include some or all of the following:
Using the L&M Group website may involve the collection of personal information by L&M Group. There are also instances when users may be asked to provide personal information on the L&M Group website. For example, online surveys may sometimes be conducted to better understand the needs and profiles of L&M Group website users. In our online surveys, users may provide demographic and profile information, such as postal code, age, and income level. Additionally, personal information is requested if you voluntarily register to receive additional information about L&M Group or subscribe to L&M Group products and services. Voluntary registration forms on the L&M Group website may request personal information from the user, such as name, postal address, and/or email address. Registered users of L&M Group websites may have certain opt-out options, which are described in the "Choice/Opt-Out" section below.
L&M Group provides access to personal data only on a need-to-know basis, and such access
will be limited to the personal data necessary to perform the business function for which such access is granted. Permission to access personal data for
personal purposes is not granted.
L&M Group does not sell, rent, lease, transfer, disclose, distribute,
provide, transfer, or otherwise communicate, orally, in writing, electronically, or
by other means, personal data to third parties for monetary or other valuable consideration.
From time to time, your personal data may be processed on our behalf or shared with affiliates of L&M
Group and other unaffiliated parties (collectively, "third parties"). Third parties processing your data may include lawyers, auditors, agents, suppliers, vendors,
service providers, contractors providing services to L&M Group, business partners,
governmental and judicial authorities and regulators, and any other persons and
entities to whom L&M Group is required to disclose such information in accordance with applicable law. When transferring data from the EEA to third parties outside the EEA, L&M
Group uses appropriate safeguards, as defined in the GDPR and approved by the European
Commission, to ensure an adequate level of protection.
A list of third-party providers
who may process your personal data can be found in the "Service Providers" section below.
L&M Group may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, brands, affiliates, subsidiaries, or other assets. To the extent permitted by applicable law, we may transfer information to a potential buyer or transferee of the business as part of the due diligence process. We require any such third party to maintain the confidentiality of your information and protect it with appropriate technical and organizational security measures.
Where necessary, L&M Group has implemented appropriate cross-border transfer mechanisms to ensure adequate protection when transferring certain personal data. To the extent permitted by applicable law, by using our websites and providing us with information about yourself, you consent to the international transfer of information about you to our subsidiaries, controlled companies, affiliates, suppliers, business partners, and selected service providers. L&M Group may also disclose your information to international regulatory and government authorities in accordance with the requirements of applicable law.
L&M Group is responsible for the processing of personal data it receives in accordance with applicable law and may subsequently transfer it to third parties acting as agents on our behalf. L&M Group has contracts with these third parties that limit their access, use, and disclosure of personal data. The liability of L&M Group and third parties is governed by contractual agreements and/or other applicable law.
In certain situations, L&M Group
may be required to disclose personal data in response to lawful requests by public
authorities, such as to meet national security requirements, a subpoena, a request from a governmental, regulatory, or law enforcement agency, or any other authority
of competent jurisdiction, or in connection with any emergency.
L&M Group takes reasonable precautions to protect and secure the personal data
held by L&M Group. We store all information securely and in a safe location on our
computer systems and databases (which may be hosted by a third party on our behalf). L&M Group employs security measures to help protect against the loss, misuse, and alteration of data under our control. These security measures utilize technologies that comply with applicable industry standards. L&M Group periodically tests the security of its information systems and monitors the effectiveness of its information security controls, systems, and procedures. L&M Group takes reasonable steps to review third-party processors of personal data to ensure that these third-party processors implement effective data protection measures in accordance with applicable law.
While we take appropriate measures to protect against unauthorized disclosure of data, we cannot guarantee that the personal data we collect will never be disclosed in a manner inconsistent with this Privacy Notice and Privacy Policy.
L&M Group will retain your personal data for as long as your account, membership, customer
relationship, or any other business relationship with L&M Group is active, as applicable, or for a reasonable period necessary to provide you with products or services, or for a longer period to comply with applicable laws and regulations. L&M Group may retain your data
after your relationship with us has ended. Your personal data may be aggregated for statistical use in accordance with applicable law. Aggregated data derived from your personal data is not considered personal data because this data is anonymous and does not directly or indirectly reveal your identity.
Personal data may be retained for the period necessary to fulfill the purposes outlined in this Privacy Notice and Privacy Policy, as well as for any other period necessary for legal, regulatory, or judicial purposes, as may be required by applicable law or internal policies. If you wish to delete your account or request that we no longer use your personal data to provide you with products or services, please contact us using the contact information provided below.
L&M Group websites may log IP addresses and browser types for administrative purposes, including logging IP addresses associated with each posting or use of an L&M Group website. These logs may be reviewed to improve the user experience and the quality of materials and content available on the L&M Group website. Additionally, such information may be used for information security purposes in connection with performance monitoring, investigations, questions, claims, or complaints regarding the use of the L&M Group website.
When you use an L&M Group website, L&M Group and third-party service providers may use cookies. Cookies place small files/code on your device or browser that serve several purposes, such as remembering your preferences (such as language) and improving your experience using L&M Group websites. Specifically, we may use this technology for the following purposes:
You can set your browser to notify you when you receive cookies, giving you the opportunity to decide whether to accept them. You can continue to browse L&M Group websites even if you choose not to accept cookies; however, some features of L&M Group websites may be limited. This Privacy Notice and Privacy Policy govern the use of cookies by L&M Group websites and do not cover the use of cookies by service providers for L&M Group websites. [See also the "Choice of Service Providers" section below.]
L&M Group websites are not intended for use by children under 16 years of age. We do not
intend any of our products or services for use by children.
L&M Group may collect limited
data from individuals under 16 years of age with verified parental consent for the limited
purpose of processing beneficiary information associated with customer,
member, or member accounts. Parents may access, edit, or delete this data by contacting us using the information provided in the "Accessing Your Personal Data" section of this Privacy Notice and Privacy Policy.
L&M Group websites may contain links to other external websites, including third-party websites with which L&M Group partners to serve non-targeted advertising. L&M Group's inclusion of a link should not be construed as an endorsement of the content of such websites or as an indication of the value of any statements, recommendations, or other information contained therein. Users of L&M Group websites should be aware that L&M Group has no control over and is not responsible for the content or privacy practices of any linked website or any link on a linked website. L&M Group urges its users to be aware when they leave the L&M Group website and to carefully read the privacy statements of each linked website that collects personal data. This Privacy Notice and Privacy Policy apply only to data collected by the L&M Group website.
If you choose to update or delete personal data previously provided to L&M Group, to the extent permitted by law, L&M Group will correct, update, or delete the personal
data stored by L&M Group. You can do so by contacting us by email at
compliance@lmgroup.io or using the contact information provided below. L&M Group will respond to your request(s) within the timeframes required by law.
In accordance with local law(s), you may have certain rights regarding the personal data we have collected about you.
Verifiable requests made pursuant to the privacy laws of your jurisdiction can be
sent by mail to compliance@lmgroup.io. To protect your privacy, L&M
Group takes reasonable steps to verify your identity before granting access to your personal
data or responding to your requests.
L&M Group websites provide registered users with the opportunity to opt-out of receiving communications from us at the time user data is requested. If you consent, L&M
Group may (1) share data with organizations with which L&M Group has a direct or indirect business relationship; (2) use the data for its own internal purposes; or (3)
contact you for market research.
If you prefer not to receive traditional
mail or other offline promotional materials from L&M Group or from organizations with which L&M Group
has a direct or indirect business relationship, please send an email to compliance@L&M
Groupmarkets.com. Please provide your full name and mailing address. To unsubscribe
by mail, please send an email to one of the addresses below.
To remove yourself
from any L&M Group mailing list, click the "Update Preferences" button or
"Unsubscribe" located at the bottom of any L&M Group marketing email. To
unsubscribe by mail, please write to one of the mailing addresses listed
below.
Alternatively, to remove yourself from L&M Group mailing lists, you can
send an email to compliance@lmgroup.io.
If you have other questions about opting out of receiving communications from L&M Group, please
email compliance@lmgroup.io.
Also, please review the
data subject rights section below for jurisdiction-specific rights applicable to you.
To the extent provided by the GDPR, as of May 25, 2018, if you are a data subject in the
European Union, you have the right to access your personal data; receive information about the processing of your personal data; request correction or erasure of your personal data, or restriction of its
processing; or exercise your right to data portability. You also have the right
to withdraw any consent you have provided to the processing of your personal data,
including any consent for any direct marketing purposes, with effect for the future. These rights are known
as "Data Subject Rights."
If you would like to exercise your Data Subject Rights or
to learn more about the details of the processing of your personal data, please contact us by
email at compliance@lmgroup.io. L&M Group will respond to your request(s) as soon as possible
within the statutory deadline. To protect your privacy, L&M Group takes reasonable steps to verify your identity before granting access to your personal data or responding to your requests.
If you are not satisfied with L&M Group's response or believe that we are not processing your personal data in accordance with applicable law, please contact L&M Group's Data Protection Officer using the contact information provided below. You may also contact or lodge a complaint with the competent supervisory authority, or pursue other legal remedies in accordance with applicable law.
L&M Group is committed to protecting the privacy of L&M Group customers in the United Kingdom ("United Kingdom") and their personal data in accordance with the current version of EU law, the General Data Protection Regulation ((EU) 2016/679) ("UK GDPR") and the Data Protection Act 2018 ("DPA"). L&M Group is committed to complying with all requirements of the UK GDPR and the DPA, as well as the provisions of this Privacy Notice and the L&M Group Privacy Policy. In the event of any discrepancy between the requirements of this Privacy Notice and L&M Group's Privacy Policy and the requirements of the UK GDPR and/or the DPA, L&M Group will comply with any additional obligations or higher standards of protection imposed by these laws for UK residents and their data.
L&M Group is committed to protecting the privacy of L&M Group's California customers and their personal information in accordance with the California Consumer Privacy Act of 2018 ("CCPA")
and California Civil Code Section 1798.83, the California Consumer Privacy Act ("STL"). L&M Group will comply with all requirements of the CCPA and STL, as well as the terms of this Privacy Notice
and Privacy Policy. In the event of a conflict between the requirements of L&M Group's current policies and the requirements of the CCPA and/or STL, L&M Group will comply with any additional
obligations or higher standards of protection imposed by these laws for California residents
and their data.
L&M Group members and clients who are California residents
may request certain information regarding our disclosure of personal data and
information to third parties for direct marketing purposes. To make such a request, please
contact our Data Protection Officer with "Request for California Privacy Information" in the subject line
and body of your message. We will comply with your request within thirty (30) days, or as otherwise required by law. L&M Group will not discriminate against you for exercising your rights under the CCPA.
L&M Group is committed to protecting the privacy of L&M Group customers in Singapore and their personal data in accordance with the Personal Data Protection Act of Singapore ("PDPA"). L&M Group is committed to complying with all requirements of the PDPA, as well as the provisions of this Privacy Notice and the L&M Group Privacy Policy. In the event of any conflict between the requirements of this Privacy Notice and the L&M Group Privacy Policy and the PDPA, L&M Group will comply with any additional obligations or higher standards of protection provided by the PDPA for Singapore residents and their data.
L&M Group is committed to protecting the privacy of L&M Group's Hong Kong customers and their personal data in accordance with the Hong Kong Personal Data Ordinance ("PDPO") and other relevant privacy laws. L&M Group will comply with all requirements of the PDPO, as well as the provisions of this Notice and the L&M Group Privacy Policy. In the event of any discrepancy between the policy requirements between this Privacy Notice and the L&M Group Privacy Policy and the PDPO, L&M Group will comply with any additional obligations or higher standards of protection provided by the PDPO for Hong Kong residents and their data.
L&M Group is committed to protecting the privacy of L&M Group customers in Japan and their
personal information in accordance with the Japanese Personal Information Protection Act ("APPI") and other relevant privacy laws. L&M Group will comply with all requirements of the APPI, as well as the terms of this Privacy Notice and the L&M Group Privacy Policy. In the event of any discrepancy between the policy requirements in this Privacy Notice and the L&M Group Privacy Policy and the requirements of the APPI, L&M Group will comply with any additional obligations or higher standards of protection established by the APPI for Japanese residents and their data.
Personal data of L&M Group clients in Japan may be transferred to the Company's affiliates.
To request disclosure (access), correction, supplementation, termination of use, deletion, or destruction of your
personal data, please send a request to compliance@lmgroup.io. Please note that L&M Group may charge you a reasonable fee for processing data access requests.
If you
have any comments or complaints regarding a possible violation of the APPI, please email L&M Group at compliance@lmgroup.io or contact the Personal Information Consulting Department of the
Japan Securities Dealers Association (phone: 03-6665-6784, website:
http://www.jsda.or.jp)
Information on how personal
information is protected depending on the jurisdiction in which L&M Group is located can be found on the Personal Information Protection Commission
's website (https://www.ppc.go.jp/).
L&M Group reserves the right to disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference (intentionally or unintentionally) with our rights or property, other users of the L&M Group website, or anyone else that could be harmed by such activities. We may also disclose personal information without prior notice in response to a subpoena or request from a governmental, regulatory, law enforcement agency, or any other authority of competent jurisdiction, when we believe in good faith that such disclosure is necessary, or in response to any emergency.
We may share your information with third-party service providers who perform functions on our behalf. We do not authorize these third parties to use your information for purposes other than those for which it was provided, and we do not authorize these third parties to disclose or distribute your information to unauthorized persons. All of our service providers undergo a comprehensive due diligence process to ensure they provide an adequate level of security to protect your information from unauthorized access or processing.
L&M Group reserves the right to update or change this Privacy Notice and Privacy Policy, or any part thereof, without prior notice. L&M Group encourages you to periodically review this Privacy Notice and Privacy Policy for changes. You may contact us at any time to request a copy of this Privacy Notice and Privacy Policy.