Updated May 26, 2021
Land Betterment Exchange, LBX Token, Land Betterment Corporation, and Westside Advisors LLC (collectively, the “LBX”)
Please take a moment to familiarize yourself with our privacy practices, accessible via the headings below, and contact us through the contact us section of our website if you have any questions.
What Is Personal Data at LBX?
LBX believes strongly in fundamental privacy rights and that those fundamental rights do not differ depending on where you live in the world. We treat any data that relates to an identified or identifiable individual as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you such as your address or contact information.
Your Privacy Rights at LBX
LBX respects your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our user base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from LBX. LBX does not sell your data including as “sale” is defined in Nevada and California.
To exercise your privacy rights and choices, visit contact us via the contact us section of the website.
There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and LBX is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.
Personal Data LBX Collects from You
LBX believes that you can have great service and great privacy. This means that we strive to collect only the personal data that we need. The personal data we collect depends on how you interact with LBX.
When you fill out an application for LBX Tokens, Sign up to utilize our API, or register as a certified environmental contractor, download our applications, participate in an online survey, or otherwise interact with LBX, we may collect a variety of information, including:
o Account Information. Necessary information to open or create an account including email address, contact information, name, age, etc.
o Permit Information. Data from which your application is derived that could be identified, such as permit number, etc.
o Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information.
o Fraud Prevention Information. Know your customer data used to help identify and prevent fraud, including a device trust score.
o Other Information You Provide to Us. Details such as the content of your communications with LBX, including interactions with customer support and contacts through social media channels.
You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.
Personal Data LBX Receives from Other Sources
LBX may receive personal data about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.
o Individuals. LBX may collect data about you from other individuals — for example, if that individual has a legal contract with you as part of the application process.
o At Your Direction. You may direct other individuals or third parties to share data with LBX. For example, you may direct parties to share data with LBX regarding your Application and monitoring process of the Application.
o LBX Partners. We may also validate the information you provide — for example, when creating an account, with a third party for security, and for fraud-prevention purposes.
For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.
LBX’s Use of Personal Data
LBX uses personal data to enable services and audit work, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.
LBX uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, LBX may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. If you have questions about the legal basis, you can contact us through our contact us section of our website.
o Power Our Services. LBX collects personal data necessary to power our services, which may include personal data collected to process applications or open accounts, for internal purposes such as auditing or data analysis, or for troubleshooting.
o Process Your Transactions. To process transactions, LBX must collect data such as your name, purchase, and payment information.
o Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your personal data to send important notices, such as communications about any pending applications and updates to the application and token issuance process.
o Security and Fraud Prevention. To protect individuals, employees, contractors and LBX and for loss prevention and to prevent fraud, including to protect individuals, employees, and LBX for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
o Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
LBX’s Sharing of Personal Data
LBX may share personal data with service providers who act on our behalf, our partners, or others at your direction. Further, LBX does not share personal data with third parties for their own marketing purposes.
o Partners. At times, LBX may partner with third parties to provide services or other offerings. For example, our payment processors etc. LBX requires its partners to protect your personal data.
o Others. LBX may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.
Protection of Personal Data
LBX believes that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure.
Cookies and Other Technologies
LBX’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
o Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested.
o Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. LBX also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.
In addition to cookies, LBX may use other technologies that help us achieve similar objectives.
In some email messages that LBX may send to you, we might provide a “click-through URL” that links you to content, services or apps on our website or others.
Pixel tags enable us to send email messages in a format that you can read, and they tell us whether mail has been opened. We may use this data to reduce or eliminate messages sent to customers.
Ads that are delivered by LBX’s advertising platform may appear in any forum it deems necessary. If you do not choose to receive emails from LBX than you can opt out via the opt out feature or by responding with “remove” in the subject line.
LBX’s, or its affiliates, retains full and exclusive rights to use names of companies that have applied for and received tokens, their sponsor names (if any), the dollar value of the tokens issued, any photographs or videos of the reclaimed sites, and the value of the environmental surety bonds that have been released. LBX can utilize this data on any platform, public relations event, website or any other means it deems necessary.
Transfer of Personal Data Between Countries
LBX products and services connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world. LBX complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.
Our Companywide Commitment to Your Privacy
To make sure your personal data is secure, we communicate our privacy and security guidelines to LBX employees and consultants and strictly enforce privacy safeguards within the company.
LBX takes your privacy questions seriously. Our team will review your inquiry to determine how best to respond to your question or concern. In most cases, all substantive contacts receive a response within 30 days. In other cases, we may require additional information or let you know that we need more time to respond.
Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.
If you are not satisfied with LBX’s response, you may refer your complaint to the applicable regulator. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
Land Betterment Exchange, PO Box 264, Fishers IN 46038