Privacy Policy

Lendo Capital ("Lendo Capital", "Company", "we", "our", or "us") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, and protect your information when you visit our website at www.lendocapital.com (the "Site") or otherwise interact with us in connection with our sales and trading‑related services.

By using our Site or our services, you agree to the terms of this Privacy Policy.

1. Information We Collect

We may collect the following types of information:

• Personal Identification Information, such as your name, contact details, employer, job title, and any information you provide when you contact us or request information.
• Client and Account Information, such as account identifiers, trading mandates, onboarding documentation, and information about the nature and purpose of your relationship with us.
• Regulatory and KYC Information, including identification documents, beneficial ownership information, sanctions‑screening data, and information about source of funds or wealth, as required by AML/KYC and other financial regulations.
• Trading and Transaction Information, such as orders, trades, positions, confirmations, allocations, communications related to trading activity, and related market data.
• Interaction and Communication Data, including communications with our sales and trading teams (such as emails, chat messages, meeting notes, and where permitted by law, recorded calls).
• Usage Data, collected automatically when you access the Site or any digital tools (for example, IP address, device identifiers, browser type, operating system, pages viewed, timestamps, and referring URLs), often via cookies and similar technologies.

We may also collect information from third‑party sources, such as market data providers, counterparties, intermediaries, and public registers, where permitted by law.

2. How We Use Your Information

We may use your information to:

• Provide, operate, and administer our sales and trading‑related services, including onboarding, account management, and trade execution;
• Process, confirm, and settle transactions, and provide trade confirmations, statements, and related reporting;
• Communicate with you about markets, trades, investment ideas, and opportunities, in accordance with applicable marketing and conduct rules;
• Perform pre‑trade and post‑trade checks, risk management, and surveillance to detect abuse, market manipulation, or other prohibited conduct;
• Comply with legal and regulatory obligations, including securities and market abuse regulations, AML/KYC requirements, sanctions rules, transaction reporting, and record‑keeping requirements;
• Conduct research and analytics using aggregated or anonymized data to improve our execution quality, pricing, and client service;
• Protect the security and integrity of our systems, prevent fraud, and manage operational and credit risk;
• Enforce our Terms of Use and other agreements, and exercise or defend legal claims.

3. Cookies and Tracking Technologies

We use cookies and similar technologies on our Site and any online tools to:

• Support secure login and session management;
• Remember your preferences;
• Analyze Site performance, traffic, and usage patterns;
• Support analytics and diagnostics to enhance our services.

You can manage cookies via your browser settings, but disabling certain cookies may affect the functionality of the Site or digital tools.

4. Information Sharing

We do not sell or rent your personal information. We may share information with:

• Affiliates and Group Companies involved in providing sales and trading, research, risk management, or operational support;
• Service Providers, such as technology vendors, hosting and cloud providers, communication and compliance tools, professional advisers, and KYC/AML vendors;
• Counterparties and Market Infrastructure, such as brokers, dealers, exchanges, trading venues, central counterparties, and custodians, as necessary for executing and settling transactions;
• Regulators, Exchanges, and Public Authorities, where required to comply with laws and regulations (including transaction reporting, trade surveillance, tax reporting, and AML/KYC obligations) or to respond to lawful requests;
• Business Transfers, in connection with a merger, reorganization, or sale of all or part of our business.

We take steps to ensure that any third parties with whom we share personal information protect it and use it only as permitted by law and our agreements.

5. Data Retention

We retain personal information and trading‑related records for as long as necessary to:

• Maintain client relationships and provide services;
• Comply with legal and regulatory obligations, including retention periods for trading records, communications, and AML/KYC data;
• Establish, exercise, or defend legal claims.

These retention periods may extend for several years after a client relationship ends, in line with regulatory requirements. When information is no longer required, we will securely delete, anonymize, or aggregate it, subject to any legal or regulatory obligations.

6. Data Security

We implement administrative, technical, and physical safeguards designed to protect your information from unauthorized access, loss, misuse, or alteration, including:

• Access controls and authentication;
• Encryption and secure communication channels where appropriate;
• Segregation of environments and least‑privilege access;
• Monitoring and incident response processes.

Despite our efforts, no system can be fully secure. You are responsible for safeguarding any credentials or devices associated with your use of our Site or services.

7. Your Rights

Depending on your location and applicable law, you may have the right to:

• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Request deletion or restriction of processing in certain circumstances;
• Object to certain types of processing, including certain marketing activities;
• Receive a copy of your information in a portable format;
• Lodge a complaint with a supervisory authority.

We may be required to retain certain data despite such requests, particularly where necessary to comply with regulatory obligations or to protect our legitimate interests.

8. International Data Transfers

Lendo Capital may operate and provide services globally. Your information may be transferred to and processed in countries that may not provide the same level of data protection as your home jurisdiction.

Where required by law, we implement safeguards for such transfers, such as standard contractual clauses or other mechanisms recognized under applicable data protection laws.

9. Links to Other Websites

Our Site may contain links to third‑party websites or resources. We are not responsible for the content, security, or privacy practices of those third parties. We encourage you to review their privacy policies when you visit their sites.

10. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services, technologies, or legal and regulatory requirements. Any updates will be posted on this page with a new "Last Updated" date. We encourage you to review this Policy periodically.

11. Additional Disclosures for Sales & Trading Activities

Because Lendo Capital is involved in sales and trading‑related activities, the following additional disclosures apply:

• Recorded Communications: Where permitted or required by law, we may record telephone calls, electronic communications, and other interactions related to trading activity for regulatory, evidentiary, and quality‑assurance purposes.
• Trade Surveillance and Monitoring: We may monitor orders, trades, and related communications to detect potential market abuse, insider trading, or other misconduct, and may share relevant information with regulators or trading venues as required.
• Best Execution and Analytics: We may use trading and market data (in aggregated or anonymized form where appropriate) to monitor execution quality and improve pricing, liquidity access, and execution strategies.
• Regulatory Reporting: We may report transaction details, client identifiers, and related information to regulators, trade repositories, or other infrastructure providers as required under applicable securities and market regulations.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, or if you wish to exercise your rights, please contact us at: