Privacy Policy
Last updated: November 1, 2024
1) Who We Are
a) The controller of your personal data is Levl GmbH, c/o F Trust AG, Zug 6300, or email to customersupport@levl.ch. References in this privacy notice (the Notice) to "Levl", "we" or "us" are references to Levl GmbH.
b) We have appointed the following EU representative: Mr. Steven Yee, Levl GmbH, c/o F Trust AG, Zug 6300
c) We have appointed the following Data Protection Officer: Mr. Steven Yee, Levl GmbH, c/o F Trust AG, Zug 6300
2) Personal Data We Process
a) Personal data we process about you includes:
i) your name and contact details (for example name, address, phone number or email address), information about the company you work for, your position or title and your relationship to a person, and other basic information;
ii) identification and background information provided by you or collected as part of our on-boarding process;
iii) financial information, for example payment-related information;
iv) information provided to us by or on behalf of our customers or generated by us in the course of providing services to customers;
v) Information provided to us by or on behalf of third party vendors in the course of conducting risk assessments and compliance checks;
vi) information provided to us for the purposes of attending meetings, seminars and events;
vii) information in relation to materials and communications we send to you electronically, for example your use of marketing e-mails;
viii) any other information relating to you which you may provide to us.
b) We collect this information when you interact with us, for example when you communicate with our staff, sign up to receive information by e-mail, or participate at a meeting, seminar or other event. We also collect or generate personal data in the course of performing compliance checks, in the course of providing our services, and we may collect personal data from other sources for example to keep your information up to date using publicly available sources.
3) How we use your personal data
a) We use your personal data:
i) to communicate with you;
ii) to provide and improve our services to you and our customers, including personal data of others provided to us or collected by us on behalf of our clients, for example processing identification and background information as part of our on-boarding, finance, administration and marketing processes;
iii) to administer our relationship with you and with our customers;
iv) to provide and improve our websites, including monitoring and evaluating its use (see "Use of our websites and e-mails" below for additional information);
v) to promote our services, including by sending alerts, updates, event invitations etc.;
vi) to comply with our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims.
4) Use of our websites and e-mails
a) Our website uses Google Analytics, a service provided by Google, Inc. that tracks and reports on the manner in which our websites are used. Google Analytics does this by placing small text files called "cookies" on your computer or other device. Cookies collect information about the number of visitors to the websites, the pages visited and the time spent on the websites. This information is aggregated and not personally identifiable.
b) You may refuse the use of cookies by selecting the appropriate settings on your browser. Note however that this may affect your experience of our websites.
c) To find out more about cookies, including how to manage, reject and delete cookies, visit www.allaboutcookies.org.
5) On what basis we use your personal information
We process personal data on the following grounds: to perform a contract, such as engaging with an individual to provide legal or other services; for the establishment, exercise or defence of legal claims or proceedings; to comply with legal and regulatory obligations; and for legitimate interests. Please see "How we process your personal data" above for additional details.
6) Who we share your personal data with
a) We will share your personal data with trusted third parties including:
i) IT service/cloud providers;
ii) Compliance vendors who support us during the onboarding process (KYC-process) as well as to conduct ongoing screening procedures of transactions for compliance reasons;
iii) Partner payment facilitators abroad who help us to terminate payments.
b) For the purposes set out in this Policy and where necessary, we may share personal data with courts, regulatory authorities, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
7) Countries we transfer your personal data to
Your personal data received by us is generally only stored in the territory of Switzerland.
We may transfer your personal data to recipients abroad, including in countries that do not provide the same level of protection as Swiss or EU law. Before we do so we will implement appropriate measures to protect your personal data, for example by requiring the recipient to agree to data processing agreements (if you would like to receive a copy of these agreements, please contact us at the address indicated above. These agreements are usually based on the EU standard clauses, which you may review here). We may also transfer personal data with your explicit consent and in certain other situations as permitted by applicable law.
8) How we retain your personal data
We retain your personal data for as long as it is necessary for the purposes for which the data is collected, and as long as we have a legitimate interest in keeping personal data, for example to enforce or defend claims or for archiving purposes and IT security. We also retain your personal data as long as it is subject to a legal retention obligation.
9) How we protect your personal information
We use various technical and organisational measures to help protect your personal data from unauthorised access, use, disclosure, alteration or destruction.
10) Your rights
a) You are entitled to ask for details of the information we hold about you and how we process it and to receive a copy of your personal data. You may also have your data rectified or deleted, restrict our processing of that information, and object to the processing of your personal data. You may also choose to withdraw your consent. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or permitted by law. You may also lodge a complaint in relation to our processing of your personal data with a local supervisory authority.
b) We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by contacting us at the address indicated above.