Legion’s Privacy policy

This privacy policy outlines how we manage, use, and disclose your data during your use of our Services, ensuring you understand your privacy rights and the protections offered by law.

By engaging with our Services in any capacity, you're acknowledging and agreeing to the data management practices detailed in this document. Your agreement also extends to how we collect, utilize, and share your information as described herein.

It's important to note that your interaction with our Services is consistently governed by our General Terms of Service ("General Terms"), which this Privacy Policy is a part of. Should there be any terms within this Privacy Policy that are not explicitly defined, their definitions are as provided in our General Terms, including terms related to specific services that are part of the General Terms.

This Privacy Policy is intended to meet our duties under applicable privacy laws, including the General Data Protection Regulation (“GDPR”) and applicable U.S. state privacy laws, such as the California Consumer Protection Act (as amended from time to time) (the “CCPA”).

As a general guide, this Privacy Policy is intended to describe our practices regarding the following:

1. 1. Collecting and Using Your Personal Data
2. 2. Use of Your Personal Data
3. 3. Retention of your Personal Data
4. 4. International Transfer of your Personal Data
5. 5. Disclosure of Your Personal Data
6. 6. Security of Your Personal Data
7. 7. Analytics and Email Marketing
8. 8. Your Rights
9. 9. Children’s Privacy
10. 10. Links to Other Websites
11. 11. Changes to this Privacy Policy
12. 12. Contact Us

Collecting and Using Your Personal Data

Information Collected from You

We collect the following information that may enable us to identify you personally (“Personal Data”) from you when you use our Services:

Information from Third Parties

We may also collect certain Personal Data from third party sources. The following table shows the types of Personal Data we may collect from third parties based on the categories described above, and provide examples of the most common sources of this data:

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on our Services and store certain information. For purposes of this Privacy Policy, “Tracking Technologies” shall include beacons, tags, and scripts to collect and track information and to improve and analyze our Services. The Tracking Technologies we use may include:

• Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.
• Web Beacons. Certain sections of our Services and our emails may contain small electronic files known as Web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit LEGION, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your Web browser. We use both Session and Persistent Cookies for the purposes set out in the table below:

Aggregated Data

When you use our Services, we may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of applicable laws, as this data does not directly or indirectly reveal your identity. However, to the extent that we associate Aggregated Data with your Personal Data in any way such that it can directly or indirectly identify you, we treat such combined and associated as Personal Data that will be subject to the terms of this Privacy Policy.

GDPR Special Categories of Personal Data and Sensitive Personal Data

We do not collect any “Special Categories of Personal Data” about you (e.g., details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data) as described in the GDPR. Some of the Personal Data that we collect may be deemed “sensitive personal information” (“Sensitive Personal Data”) under applicable law, however. We use and disclose this Sensitive Personal Data for our business and compliance functions and for other legally authorized purposes. Please do not submit any Special Categories of Personal Data to us, but if you do, you agree that this Privacy Policy will apply to such Personal Data.

Use of Your Personal Data

LEGION generally uses your Personal Data for the following purposes:

To provide, maintain, and improve our Services, including to monitor the usage of our Services, assist with service requests, remedy security or technical issues, and analyze website and application performance.

To manage your Account: To manage your registration as a User of our Services. The Personal Data you provide can give you access to different functionalities of our Services that are available to you as a User.

For the performance of a contract: The development, compliance and undertaking of the purchase contract for the services or goods you have purchased, or of any other contract with us through the Services.

To maintain legal and regulatory compliance: We are required to collect, use, and store certain of your Personal Data in order to comply with applicable anti-money laundering, sanctions, securities, and other financial laws across jurisdictions.

To contact you and manage your requests: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation, and to support and respond to your inquiries.

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Services users is among the assets transferred.

Automated Decision Making. We may engage in automated decision making, including profiling (e.g., for purposes of determining an Investor’s accreditation status following your completion of an investor questionnaire). LEGION’s processing of your Personal Data will not result in a decision based solely on automated processing that significantly affects you or your legal rights unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth below.

De-identified and Aggregated Information. We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email or tweet inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

Legal Bases Required for Processing Your Personal Data. With respect to each of the purposes for which we use your Personal Data, applicable law may require us to ensure we have a legal basis for that use. The legal bases we rely on depend on the Services you use and how you use them. Our legal bases for collecting and using your Personal Data described above include:

Necessity for the Services. We may need your Personal Data to provide you the Services, including to operate the Services and provide customer support;

To Perform a Contract. We require your Personal Data where it is necessary for the performance of a contract to which you are a party or to protect your vital interests or that of another person;

Our Legitimate Interest Appropriately Weighed Against Your Data Protection Interests. We may collect and use your Personal Data where it satisfies our legitimate interest, but only where such interest is not overridden by your data protection interests, such as for research and development, for marketing the Services and to protect our legal rights and interests;

Legal or Regulatory Obligations. We will require your Personal data where we need to process it to comply with a legal or regulatory obligation, such as applicable anti-money laundering laws; or

Otherwise Explicitly With Your Consent. We may also rely on your consent as a legal basis for using your Personal Data where we have sought it for an explicit purpose. Where we rely on your consent to use your Personal Data, you have the right to change your mind at any time.

Where we need to process your Personal Data to provide the Services, to perform the terms of a contract we have with you, or to satisfy legal or regulatory obligations, and you fail to provide the data as needed and requested, we may be unable to continue providing the Services.

Retention of your Personal Data

LEGION will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

International Transfer of your Personal Data

Your information, including Personal Data, is processed at LEGION’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction. Although LEGION is not headquartered in the United States and does not maintain offices there, these locations may also include the United States, where the data protection laws may differ than those from your jurisdiction, because certain service providers our Services rely on may process data in the United States. We recognize we may have Users that span the globe, but by accessing the Services and providing us with your Personal Data, you are consenting to and authorizing the export of Personal Data to the United States and its storage and use as specified in this Privacy Policy while we are dependent on such service providers to provide our Services. LEGION will take all commercially reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy, including ensuring that any third party service provider we contract with to process your Personal Data has entered into a data processing addendum or other legal document protecting your data privacy rights with LEGION in compliance with this Privacy Policy, and that such third parties maintain such other terms and policies necessary to comply with applicable law with respect to the processing of your Personal Data.

Disclosure of Your Personal Data

We may share your Personal Data in the following situations and may have disclosed within the preceding 12 months:

With Service Providers: We may share your Personal Data with Service Providers to verify your identity or investor accreditation status, monitor and analyze the use of our Services, for payment processing, to contact you.

With Affiliates: We may share your information with our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include our parent LEGION and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with us.

With business partners: We may share your information with our business partners to offer you certain products, services, or promotions you have requested, or products or services We offer jointly.

Advertising Partners: We may share your Personal Data with third-party advertising partners. These third-party advertising partners may set Tracking Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks.

With other users: When you share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on that service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

With your consent: We may disclose your Personal Data for any other purpose with your consent.

Business Transactions: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Disclosures to Protect Us or Others: We may access, preserve, and disclose any information We store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of illegal activity.

Security of Your Personal Data

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We strive to use all commercially reasonable means to protect your Personal Data, including using industry-standard safeguards to protect your Personal Data, requiring confidentiality obligations to be observed by all of our service providers, and limiting information to service providers who require such information to provide the Services. Despite the measures we take to safeguard your Personal Data, you acknowledge that we cannot guarantee its absolute security or that your information on the Services may not be accessed, disclosed, or destroyed by a breach of our safeguards.

By using our Services or providing Personal Data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Analytics and Email Marketing

Analytics

We may use third-party Service providers to monitor and analyze the use of our Services. For example, Google Analytics is a Web analytics service offered by Google that tracks and reports Site traffic. Google uses the data collected to track and monitor the use of our Services. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here. You may also opt out of other analytics providers by following instructions available in their privacy policies or on their websites. To the extent you are unable to identify this information and would like to opt out, please contact us as provided in this Privacy Policy.

Email Marketing

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us. Note that you will continue to receive important transactional emails from us, for example notification of updates to this Privacy Policy.

Your Rights

Site

You can opt out of receiving ads that are personalized as served by our service providers by following our instructions presented on the Services:

The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

The EDAA’s opt-out platform http://www.youronlinLEGIONices.com/

The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests with something like the following features:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices

“Limit Ad Tracking” or “Ask app not to track” on iOS devices

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.

“Do Not Track” Policy

Do Not Track (“DNT”) is a privacy preference that users can set in certain Web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by Web browsers.

Your Legal Rights

LEGION undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

Depending on the law in your jurisdiction, you may have the following rights:

Request access to Your Personal Data. You have the right to receive a copy of the Personal Data we hold about you in a portable and, to the extent technically feasible, readily usable format, and to check that we are lawfully processing it. As applicable, you may also have the right to request that we disclose to you the following information covering the 12 months preceding your request (a) the categories of Personal Data we have collected about you and the categories of sources from which we collected such Personal Data; (b) the business or commercial purpose for collecting Personal Data about you; and (c) the categories of Personal Data about you that we otherwise disclosed, and the categories of third parties to whom we disclosed such Personal Data (if applicable). In some cases, you may be able access, update, or request deletion of your Personal Data directly within your account settings section.

Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information we hold about you corrected.

Request to limit use and disclosure of your Sensitive Personal Data. You may have the right to ask that we limit our use and disclosure of your Sensitive Personal Data to certain purposes permitted by law.

Object to processing of Your Personal Data. You may object where our processing is based on our legitimate interest, or where we are processing your Personal Data for direct marketing purposes.

Right to restrict processing: You can ask us to “block” or suppress the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data.

Request erasure of Your Personal Data. You have the right to ask us to delete or remove Personal Data when there is no good reason for us to continue processing it. In the EU, you also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing as described above.

Request the transfer of Your Personal Data. Subject to applicable law, we will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format.

Request to stop selling your Personal Data or sharing your Personal Data for cross-context behavioral advertising. LEGION does not sell your Personal Data and we have not engaged in such activities in the 12 months preceding the date this Privacy Policy was last updated. If you are in certain jurisdictions, you have the right to ask that we limit the sharing of your Personal Data for cross-context behavioral advertising.

Withdraw Your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising of Your Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us as set forth below. Please note that we may ask you to verify your identity before responding to such requests, such as by asking you questions about your use of the Service. If you make a request, we will try our best to respond to you as soon as possible. Typically, this is within 30 days, but this may occasionally take us longer, particularly if your request requires significant volume or is highly complex.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

LEGION does not and will not discriminate against an individual because the individual exercised any of the rights described above.

Sale of Personal Data

LEGION does not “sell” Personal Data, nor do we have actual knowledge of any “sale” of Personal Data of minors under 16 years of age, as the term “sell” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in this Policy.

California’s Shine the Light Law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, you can contact us by email at

Agora Labs Ltd.

Address: Jayla Place, 2nd Floor, Road Town, Tortola 1110,British Virgin Islands