Privacy Policy
Effective date: [EFFECTIVE DATE] · Version: 3
This Privacy Policy explains what personal information Lenium, Inc. ("Lenium", "we") collects when you use www.lenium.capital and the Lenium service, how we use and share it, how long we keep it, and the choices and rights you have. It forms part of our Terms of Service. We do not sell your personal information.
1. Information we collect
| Category | Examples | Where it comes from |
|---|---|---|
| Account identifiers | Name, email address, username, account ID, Google account ID and profile picture if you sign in with Google | You; Google |
| Login credentials | Password (stored only as a one-way hash), session tokens | You; our systems |
| Identity verification | Legal name, date of birth, home address, government ID images and number, selfie or liveness check. [IDENTITY VERIFICATION PROVIDER] holds these; Lenium keeps only the result: whether you are verified, your legal name, country and state, whether you are 18 or older, and [IDENTITY VERIFICATION PROVIDER]'s reference for the check | You, through [IDENTITY VERIFICATION PROVIDER] |
| Identity key | A one-way keyed code made from your ID document's country, type and number and your date of birth. It cannot be turned back into those details; we use it only to tell whether one person holds more than one account | Our systems, from the [IDENTITY VERIFICATION PROVIDER] result |
| Phone number | Your mobile number and when you verified it, if we ask you to verify one by text message | You; [SMS PROVIDER] |
| Tax information | Taxpayer identification number (such as a Social Security number) and details on IRS Form W-9 | You |
| Payment information | Card brand, last four digits, billing ZIP code, transaction IDs, purchase history, discount codes used, and a card fingerprint (an identifier for the card that [PAYMENT PROCESSOR] provides, which we store only as a one-way keyed code). Full card numbers are held only by [PAYMENT PROCESSOR] | You; [PAYMENT PROCESSOR] |
| Trading and program activity | Simulated orders, positions, balances, fees, rule checks, pass or fail results, payout requests and payments, rules version, add-ons | Our systems |
| Payout details | Bank or payout account details needed to pay you, and the name on the receiving account | You; our payout provider |
| Device and usage data | IP address, approximate location derived from IP, browser and device type, pages viewed, timestamps, error logs | Your device; our systems |
| Device and network signals (fraud prevention) | When you sign up, log in, buy, place orders and request payouts: a device identifier (a "fingerprint" from [DEVICE FINGERPRINT PROVIDER], or one made from your browser's settings), your IP address, the country and state it points to, whether the connection appears to come through a VPN, proxy or hosting service, and your browser type. We store the device identifier, IP address and browser type only as one-way keyed codes; the IP address itself is kept separately for 90 days | Your device; [DEVICE FINGERPRINT PROVIDER]; [IP INTELLIGENCE PROVIDER] |
| Risk and enforcement records | Links between accounts that appear to belong to the same person or to trade together, the reasons for them, flags for review, account holds, and a log of every enforcement action and who took it | Our systems |
| Cookies | Sign-in and security cookies, preference cookies [and analytics cookies from [ANALYTICS PROVIDER]] | Your device |
| Legal acceptance records | Which version of each legal page you accepted, when, and the IP address and browser used | Our systems |
| Communications | Emails and messages you send us, survey answers | You |
| Affiliate information | Affiliate code, referral counts, commissions, payout and tax details | You; our systems |
Sensitive information. Government ID numbers, Social Security numbers, precise financial account details, and any biometric information created during a selfie or liveness check are sensitive personal information. We collect them only to verify identity, prevent fraud, pay you, and meet tax and legal duties, and we do not use them for any other purpose. Where a state law requires your consent before biometric information is collected (for example, Illinois, Texas or Washington), [IDENTITY VERIFICATION PROVIDER] will ask for it first; biometric data is kept only as long as verification requires and no longer than the law allows.
2. How we use information
- To create and secure your account and let you sign in, including with Google.
- To run evaluations and funded accounts: pricing trades, applying the Rules, calculating fees, results and payouts.
- To take payments, apply discount codes, process resets and add-ons, and pay affiliate commissions.
- To verify your identity and eligibility, including age and location (from your ID result and your IP address), and to enforce restricted jurisdictions.
- To detect and prevent fraud, multiple accounts, coordinated trading, and other Prohibited Practices under the Terms, including by comparing device, network, payment, phone and identity signals across accounts and linking accounts that appear to belong to the same person. Some checks run automatically and can put an account on hold or a payout under review until a person looks at it. An IP address alone is never treated as proof that two accounts belong to the same person.
- To pay you and meet tax reporting and other legal obligations.
- To send service messages (receipts, rule alerts, pass or fail notices, payout updates, legal notices) and, where allowed, marketing emails you can unsubscribe from.
- To publish aggregate program statistics that never identify you, and individual results only if you opt in.
- To maintain, debug, and improve the Service.
- To comply with law, respond to lawful requests, and protect the rights and safety of Lenium, our users, and others.
3. How we share information
We share personal information only as follows:
- Service providers who process it on our behalf under contracts that limit its use: hosting (Vercel), database (Supabase), payments ([PAYMENT PROCESSOR]), identity verification ([IDENTITY VERIFICATION PROVIDER]), device fingerprinting ([DEVICE FINGERPRINT PROVIDER]), IP address and VPN checks ([IP INTELLIGENCE PROVIDER]), text messages ([SMS PROVIDER]), email delivery ([EMAIL PROVIDER]), payouts ([PAYOUT PROVIDER]), sign-in (Google), [analytics ([ANALYTICS PROVIDER])], and professional advisers such as lawyers and accountants.
- Fraud prevention. To run the checks above we send each provider only what it needs to return a result: your ID and selfie to [IDENTITY VERIFICATION PROVIDER], a device signal to [DEVICE FINGERPRINT PROVIDER], your IP address to [IP INTELLIGENCE PROVIDER], and your phone number to [SMS PROVIDER]. These providers may also use that information to detect and prevent fraud as their own terms and privacy policies allow.
- The exchange whose prices we use. We do not share your personal information with the exchange. We only read the exchange's public market data.
- Affiliates. An affiliate whose code you use sees that a purchase was made with their code and its amount. They do not see your name, email, or trading.
- Legal and safety. When required by law, subpoena, or court order, or when we believe in good faith that disclosure is needed to prevent fraud, protect someone's safety, or enforce our Terms, including reporting suspected market manipulation or insider trading to the exchange whose prices we use or to authorities.
- Business transfers. In a merger, acquisition, financing, or sale of assets, subject to this Policy.
- With your consent, such as when you opt in to a public leaderboard.
We do not sell personal information, and we do not share it for cross-context behavioural advertising. We have not done so in the past 12 months.
4. Cookies and similar technologies
We use cookies that are strictly necessary for sign-in, security, and checkout, and preference cookies to remember settings such as dark mode. When you sign in with Google, we set a security cookie for up to 15 minutes that carries a device signal for fraud prevention. [We use [ANALYTICS PROVIDER] to understand how the site is used; you can decline these cookies in the cookie banner.] We do not use advertising cookies. We honour the Global Privacy Control signal as an opt-out of any sale or sharing. Most browsers let you block or delete cookies, but the Service will not work without the necessary ones.
5. How long we keep information
| Information | How long |
|---|---|
| Account and trading records | While your account is open, then 3 years |
| Purchase, payout, commission and tax records | 7 years after the transaction, for tax and accounting duties |
| Identity verification data | As long as needed to verify you and meet legal duties, and no longer than 5 years after your account closes; biometric data only as long as verification requires. ID images, ID numbers, selfies and your full date of birth are held by [IDENTITY VERIFICATION PROVIDER], not by Lenium |
| Identity key, and the identity, phone number and card codes of closed or banned accounts | As long as needed to stop one person from holding more than one account or returning after a ban |
| Raw IP addresses used for fraud checks | 90 days |
| Device and network signals (as one-way keyed codes) | 3 years |
| Verified phone number | While your account is open, then 3 years |
| Account links, risk flags and the enforcement log | While your account is open, then 7 years, to prevent repeat fraud and resolve disputes |
| Legal acceptance records | While your account is open, then 7 years |
| Device and security logs | 12 months, or longer if needed for an investigation |
| Support communications | 3 years after the last message |
We may keep information longer if the law requires it or to resolve a dispute, and then delete or de-identify it.
6. Security
We protect information with encryption in transit, hashed passwords, access controls, row-level security on our database, and by keeping secret keys only in secured environment settings. We store IP addresses (after 90 days), device identifiers, card fingerprints and the identity key only as one-way keyed codes, and our application does not write them to its logs. No system is perfectly secure. If a breach affects your personal information, we will notify you and regulators as the law requires.
7. Your rights and choices
7.1 Depending on where you live, you may have the right to: know what personal information we hold about you and get a copy in a portable format; correct inaccurate information; delete your information; opt out of sale, sharing, targeted advertising, and profiling with legal effects (we do none of these); limit use of sensitive personal information (we use it only for the purposes the law permits); and not be treated differently for using these rights.
7.2 These rights apply to residents of California and other states with comprehensive privacy laws, and we extend them to all users where practical.
7.3 To make a request, email privacy@lenium.capital from your account email, or from another address with enough detail for us to verify you. We will verify your identity, and may ask an authorised agent for proof of authority. We will respond within 45 days, and may extend by another 45 days where the law allows. If we decline, you may appeal by replying to our decision; if we deny the appeal, you may contact your state attorney general.
7.4 Some information cannot be deleted while it is needed, for example payout and tax records we must keep by law, or data needed to resolve an open investigation or dispute.
7.5 You can unsubscribe from marketing emails at any time using the link in each email. Service and legal messages will still be sent while you have an account.
8. Google sign-in
If you sign in with Google, we receive only your name, email address, profile picture, and Google account ID. We use them only to create and secure your Lenium account. Our use of information received from Google APIs follows the Google API Services User Data Policy, including its Limited Use requirements. We do not access your Gmail, Drive, contacts, or any other Google data.
9. Children
The Service is only for people 18 and older. We do not knowingly collect information from anyone under 18. If we learn we have, we will delete it and close the account. Contact privacy@lenium.capital if you believe a minor has an account.
10. Where information is processed
Lenium operates in the United States, and information is stored and processed in the United States by us and our service providers.
11. Changes to this Policy
We will post any change here with a new version number and effective date. If a change is material, we will tell you by email or in the dashboard before it takes effect.
12. Contact
Lenium, Inc. · 251 Little Falls Drive, Wilmington, DE 19808 · Privacy requests: privacy@lenium.capital