Privacy and Data Retention Policy

Last Update: December, 2019

This Privacy and Data Retention Policy (the Policy) explains the way in which LOME International Co., LTD. (hereinafter referred to as “The Company”) collect, use, and protect Personal Information of Users (“you”) obtained through the (“Website“), any related applications (including without limitation the mobile one) and its exchange tools integrated into third-party services (“Services”). The terms “we,” “us,” and “our” refer to “LOME International”.

“Personal Information” is an information that identifies or can be used to identify, contact, or locate the person to whom such information pertains.

At LOME International, we are fully committed in respecting the privacy and protecting any information that our clients provide. Your privacy and security are both our highest priorities and we make every effort to ensure that all the information provided by you is protected.

We follow and comply with best practices and regulation in the sphere of privacy including but not limited to General Data Protection Regulation (GDPR).


  1. As a principle, LOME collects only what is needed and will not share the Purchaser’s Personal Information with any third parties’ other than LOME’s identity verification partner. Even within LOME, access to the Purchaser’s personal data is limited to a subset of employees who work on compliance and identity verification matters.
  2. The Purchaser will provide to LOME, immediately upon a notice of request, information that LOME, in LOME’s sole discretion, deem to be required to maintain compliance with law, regulation or policy. Such documents include, but are not limited to, passports, driver’s licenses, utility bills, and photographs of the Purchaser or government identification cards.
  3. LOME reserves its right to request documentation, described in section “General” under paragraph 5 prior to activating the Purchaser’s LOME Token account. LOME may refuse to sell LOME Token should it have doubts as to validity, authenticity and genuineness of the documents, provided by the Purchaser.
  4. LOME collects information from running the website and products, provided thereto, and uses information, provided to LOME by the Purchaser as indicated in detail in LOME Privacy Policy.
  5. In addition to the above, if the Purchaser creates an account to purchase LOME Tokens included, LOME may collect and store the following types of information: The Purchaser’s name, phone, email, nationality, id photo page scan and Ethereum wallet address. Before permitting the Purchaser to proceed with LOME Token purchase, LOME may require the Purchaser to provide additional information (such as data which can be used for personal identification purposes and that may be required to comply with applicable laws) so that LOME can verify the Purchaser’s identity or address. LOME may also obtain information about the Purchaser from third parties such as identity verification services.
  6. Throughout this document, LOME use the term “personal information” in compliance with the US General Data Protection Regulations (GDPR) if any to describe information that can be associated with a specific person and can be used to identify that person.
  7. LOME protects the Purchaser’s information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards used are firewalls and data encryption, physical access controls to data centers, and information access authorization controls. LOME also authorize access to personal information only for those employees who require it to fulfill their job responsibilities. All the physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations.
  8. LOME may be required to analyze and compare the personal data provided by the Purchaser to third party databases to verify its accuracy and confirm the Purchaser’ identity. This allows LOME to comply with USA “anti-money laundering (AML)” and “know your customer (KYC)” regulations – most notably Bank Secrecy Act along with any applicable US-CNMI AML regulations and law. LOME will not release, sell or rent the Purchaser’s personal data to third parties other than law enforcement agencies and/or public administration bodies acting upon relevant US and/or CNMI law provisions.
  9. LOME reserve the right to share the Purchaser’ personal data with:
    1. 3rd party identification services providers for fraud prevention purposes;
    2. law enforcement, government officials, or other third parties when LOME are compelled to do so by a subpoena, court order, or similar legal procedure;
  10. LOME will not provide the Purchaser’s personal information to any other LOME token holders without the Crowd funder’s consent or direction.
  11. The Purchaser may access, review, edit or request to remove his personal data by LOME. The Purchaser acknowledges that the execution of his right to be forgotten under GDPR may result in disabling his Token account.
  12. The cost of any ETH transfer operation(s) for ICO purposes i.e. "GAS" is to be calculated automatically and is to be entirely borne by the purchaser of LOME tokens.

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LOME International Co,.LTD, 2019.