Privacy Policy
lmc. (“we,” “us,” “our,” or the “Company”) operates the website and associated online portals located at https://www.lmc.ltd (the “Site”). We are fully committed to safeguarding the privacy, confidentiality, and security of the personal data of our global clients, investors, and website visitors.
This Privacy Policy outlines how we collect, use, disclose, transfer, and store your personal data. This Policy is designed to comply with major global data protection frameworks, including:
The Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO“);
The EU and UK General Data Protection Regulation (“GDPR“); and
United States state-level privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA“).
Categories of Personal Data We Collect
Depending on your interactions with the Site (e.g., browsing, registering an account, subscribing to insights, or undergoing onboarding), we may collect and process the following categories of personal data:
Identity and Contact Data: Full name, corporate or personal email address, telephone number, job title, company name, and physical mailing address.
Regulatory Compliance and Verification Data: Nationality, date of birth, government-issued identification details (e.g., passport or national ID numbers), and documentation required to verify accredited investor status or fulfill Anti-Money Laundering (AML) and Know Your Customer (KYC) statutory obligations.
Technical and Network Data: Internet Protocol (IP) address, browser type and version, time zone setting, geolocation data, operating system, platform, and other technical identifiers collected via access logs.
Usage and Preference Data: Information regarding how you navigate, interact with, and view content on our Site, including clickstream data, page response times, and your communication/language preferences.
Legal Bases for Processing (Applicable to EEA/UK Residents)
If you reside within the European Economic Area (EEA) or the United Kingdom (UK), we process your personal data only when we have a valid legal basis under the GDPR:
Performance of a Contract: To provide, manage, and maintain our platform, client portals, and the services you request.
Compliance with Legal Obligations: To satisfy statutory regulatory, financial, tax, and AML/KYC reporting requirements globally.
Legitimate Interests: To ensure network security, prevent fraudulent activity, optimize website performance, and enhance our business operations, provided such interests do not override your fundamental privacy rights.
Consent: Where you have granted explicit, affirmative consent (e.g., opting into direct marketing communications or non-essential analytical cookies).
International Data Transfers
lmc. operates globally. Personal data collected by us may be transferred to, stored at, and processed in jurisdictions outside of your country of residence, including our servers and offices in Hong Kong, the United States, and Europe.
For EEA/UK Residents: When transferring personal data out of the EEA/UK to jurisdictions not recognized as providing an adequate level of data protection (such as Hong Kong or the United States), we implement appropriate safeguards, including the European Commission’s Standard Contractual Clauses (SCCs), to ensure your data remains subject to an equivalent standard of protection.
Data Disclosure and Third-Party Sharing
We treat all personal data as strictly confidential. We do not sell, rent, or trade your personal data. We share your data only with the following categories of trusted recipients:
Service Providers and Affiliates: Third-party vendors providing cloud hosting, IT support, technical analytics, and administrative functions, operating under strict data processing addenda (DPAs).
Professional Advisors: Our international legal counsels, auditors, regulatory consultants, and accountants.
Regulatory and Law Enforcement Authorities: Government agencies, courts, or regulators (such as the Hong Kong Securities and Futures Commission (SFC), the US Securities and Exchange Commission (SEC), or European financial supervisory authorities) when we are legally compelled or permitted to do so.
Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including the satisfaction of any legal, accounting, statutory, or regulatory retention periods. When no longer required, data is securely destroyed or permanently anonymized.
Your Global Statutory Rights
Depending on your jurisdiction, you possess specific legal rights regarding your personal data:
Hong Kong Residents (PDPO): You have the right to check whether we hold your data, request access to it, correct any inaccuracies, and opt out of direct marketing.
EEA/UK Residents (GDPR): You have the right to access, correct, or request the erasure (“right to be forgotten”) of your data; restrict or object to certain processing activities; exercise data portability; and lodge a complaint with your local data protection supervisory authority.
US/California Residents (CCPA/CPRA): You have the right to request disclosure of the categories and specific pieces of personal data collected; opt out of the sale or sharing of personal data (we state that we do not sell or share your data for cross-context behavioral advertising); delete collected data; and be free from discrimination for exercising your privacy rights.
To exercise any of these statutory rights, please contact our global data protection team at: Contact: [email protected]
Children’s Privacy
The Site is not directed to, or intended for, individuals under the age of 18 (or the threshold age defined by US/EU local laws). We do not knowingly collect personal data from children. If we discover an inadvertent collection of such data, it will be deleted immediately.