Privacy Policy

LAUNCHBAY CAPITAL FZCO

a free zone company incorporated in IFZA, UAE

PRIVACY POLICY

Applicable to the LBXPro and LBXWealth

Last Updated: May 07, 2026

LaunchBay Capital FZCO, a free zone company incorporated in IFZA, Dubai, United Arab Emirates (referred to as the "Company", "we", "us" or "our") is committed to protecting our stakeholders' and customers' personal data in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"), and other applicable data protection laws including, where applicable, the European Union General Data Protection Regulation (EU) 2016/679 ("GDPR") and the UK General Data Protection Regulation ("UK GDPR").

"Personal data" means any data about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access, as more specifically defined under the UAE PDPL and other applicable data protection laws.

This Privacy Policy (the "Policy") describes how we collect, use, store and protect personal data in connection with your use of our platform.

We may from time to time update this Policy to ensure consistency with future developments, industry trends and/or any changes in legal or regulatory requirements. Such changes will be posted on the platform with an updated "Last Updated" date. Your continued use of the Platform after any update constitutes acceptance of the revised Policy.

This Policy should be read alongside the applicable platform Terms of Service.

1.  WHAT PERSONAL DATA WE COLLECT

We collect the following categories of personal data:

1.1  Account and Identity Data

●     Full name, date of birth, and nationality.

●     Government-issued identification documents (passport, national ID) — collected as part of identity verification and onboarding.

●     Email address, telephone number, and postal address.

●     Username and password (hashed) for your account.

●     For entity clients: legal entity name, jurisdiction of incorporation, company registration number, constitutional documents, and information relating to authorised signatories and ultimate beneficial owners.

1.2  Financial and Compliance Data

●     Source of funds and source of wealth declarations.

●     Bank account details for payment and account transaction processing.

●     Identity and regulatory screening records.

●     Tax identification numbers and applicable regulatory tax documentation.

1.3  Platform Usage and Technical Data

●     Login and session records, access logs, and activity on the platform.

●     Device identifiers, IP address, browser type, and operating system.

●     App usage data (LBXWealth): session duration, feature interactions, push notification preferences.

●     Cookies and similar tracking technologies (see Section 9).

1.4  Communications Data

●     Correspondence between you and us, including support enquiries, onboarding communications, and administrative messages.

1.5 Blockchain and Tokenization Data

●     Blockchain wallet addresses and public keys associated with your account.

●     Token holdings, transfer records, and on-chain transaction history recorded on the applicable distributed ledger.

2. HOW WE COLLECT YOUR DATA

We collect personal data from or relating to you in various ways, including but not limited to:

●     when you access and/or use the platform (or any part thereof);

●     when you submit onboarding or account registration forms;

●     when you upload identity documents, source-of-funds declarations, financial statements, or other documentation in connection with identity verification and onboarding;

●     when you interact with our personnel, including compliance officers and support representatives;

●     when you contact us or request that we contact you;

●     when you enter into agreements with us, including the applicable platform Terms of Service and applicable agreements;

●     when we receive references from business partners, intermediaries, or third parties (for example, where you have been referred by an introducing broker or placement agent); and/or

●     from publicly available sources, including company registries, sanctions databases, PEP databases, and other open-source intelligence tools used for identity verification and compliance purposes.

3.  HOW WE USE YOUR DATA

We process your personal data for the following purposes:

●     Account access and onboarding: creating and managing your account, verifying your identity, and providing access to the platform.

●     Regulatory compliance: performing identity verification, regulatory screening, and meeting all applicable compliance and tax reporting obligations.

●     Account and transaction administration: processing account applications, administering Golden Records, facilitating account transactions, and maintaining account records in connection with applicable agreements.

●     Platform operation and security: detecting fraud, preventing unauthorised access, monitoring for security incidents, and maintaining the technical integrity of the platform.

●     Communications: sending administrative notices and responding to enquiries

●     Legal and regulatory obligations: complying with applicable laws, responding to court orders or regulatory requests, and maintaining compliance records.

●     Platform improvement: analysing usage patterns to improve functionality, user experience, and security (using aggregated or anonymised data where possible).

●     Newsletter and marketing communications: where you have provided your express consent, sending you market insights, investment commentary, and platform updates by email. You may withdraw this consent at any time by using the unsubscribe link in any email or by contacting us at leo@lbx.pro.

4.  LAWFUL BASIS FOR PROCESSING

Where data protection laws require us to identify a lawful basis, we rely on the following:

●       Performance of contract — processing necessary to provide you with access to the platform.

●       Legal obligation — processing required to comply with applicable regulatory, compliance and tax requirements.

●       Legitimate interests — operating and improving the platform, preventing fraud and security threats, and maintaining compliance records, where these interests are not overridden by your rights.

●       Consent — where we rely on consent as the lawful basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. However, please note that withdrawal of consent for the collection, use or disclosure of personal data that is necessary for us to comply with regulatory obligations (including applicable regulatory, compliance and tax reporting requirements) or to fulfil our contractual obligations to you may result in our being unable to continue providing the relevant services, and may require us to suspend or terminate your access to the platform.

●       Newsletter subscription data (email address and consent record) is retained for the duration of your subscription and for a period of twelve (12) months following unsubscription or withdrawal of consent, to evidence the lawful basis for prior communications.

●       Automated Decision-Making—We do not make decisions about you that are based solely on automated processing and that produce legal or similarly significant effects, without human review. Where automated tools are used in identity verification or compliance screening, such processes are subject to human oversight.

5.  WHO WE SHARE YOUR DATA WITH

We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

●     LaunchBay Digital Assets LLC and its affiliated entities, for the purposes of administering platform records, processing account applications, and satisfying applicable compliance obligations.

●     Identity verification and regulatory compliance providers, including third-party screening and compliance platforms.

●     Technology and infrastructure service providers, including cloud hosting, platform development, and data storage providers.

●     Professional advisers, including lawyers, accountants, and auditors, bound by applicable confidentiality obligations.

●     Regulatory authorities, courts, and law enforcement, where required by applicable law or court order.

●     Business transferees, in connection with any merger, acquisition, restructuring, or sale of all or part of our business, subject to appropriate confidentiality protections.

●     Third-Party Personal Data: where you disclose personal data of other individuals to us (for example, in connection with UBO declarations, authorised signatory information, or nominee arrangements), you warrant that such individuals have been informed of, and where required by applicable law have consented to, the collection, use and disclosure of their personal data for the purposes described in this Policy.

6. DATA PROCESSING AND INTERCOMPANY ROLES

Personal data may be processed by LaunchBay Capital FZCO and LaunchBay Digital Assets LLC ("LBDA") in connection with the services. LaunchBay Capital FZCO generally acts as controller for personal data processed in relation to the operation of the LBXPro and LBXWealth platform, onboarding flows, account administration, and investor communications, while LBDA generally acts as controller for personal data processed in relation to issuer, subscription, admission, registry, and official recordkeeping functions.

The parties may share personal data with each other where necessary to operate the Services, administer investments and issuances, maintain official records, comply with legal and regulatory obligations, prevent fraud, protect security, and manage related business operations. Each party is responsible for its own compliance with applicable data protection laws in relation to the personal data it processes as controller.

7.  INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in countries outside your primary jurisdiction, including jurisdictions that may not provide the same level of data protection as your home country. Where such transfers occur, appropriate safeguards will be implemented in accordance with applicable data protection laws, including, where required, the use of standard contractual clauses or equivalent transfer mechanisms.

8.  HOW LONG WE KEEP YOUR DATA

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with our legal and regulatory obligations.  As a general rule:

●     Account and identity data is retained for the duration of your account and for a minimum of five (5) years following account closure, or such longer period as required by applicable regulatory, compliance or tax law.

●     Identity verification and compliance records are retained for a minimum of five (5) years following account closure, in accordance with applicable regulatory requirements.

●     Technical and usage data is retained for up to twelve (12) months from collection, unless a longer period is required for security or legal purposes.

●     Communications are retained for as long as necessary to resolve the matter and for a reasonable period thereafter.

On expiry of the applicable retention period, data will be securely deleted or anonymised.

9.  COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, device identifiers, analytics tools, and similar technologies to operate, maintain, and improve our platform, enhance user experience, maintain security, and understand usage patterns. These technologies may collect technical and usage-related information such as device information, session data, log information, and interaction data. You may manage certain preferences through your device settings. By using our platform, you acknowledge and agree to the use of such technologies in accordance with this Policy.

10.  YOUR RIGHTS

Subject to applicable data protection law, you may have the following rights in relation to your personal data:

●     Access: request a copy of the personal data we hold about you.

●     Rectification: request correction of inaccurate or incomplete data.

●     Restriction: request that we limit how we process your data in certain circumstances.

●     Portability: receive your data in a structured, machine-readable format (where technically feasible and legally required).

●     Objection: object to processing based on legitimate interests.

●     Withdraw consent: where processing is based on consent, withdraw that consent at any time.

●     Erasure: Request deletion of your personal data where we have no continuing legal obligation or legitimate basis to retain it. This right is subject to the following mandatory limitation: where personal data constitutes identity verification records, transaction records, or other data that we are legally required to retain under applicable anti-money laundering, counter-terrorist financing, or tax laws (including UAE Federal Decree-Law No. 20 of 2018 on AML/CTF, the applicable FATF Recommendations, and equivalent laws in other relevant jurisdictions), we are not able to comply with a deletion request in respect of such records during the applicable mandatory retention period, notwithstanding any request made under GDPR Article 17 or equivalent provisions. If you are an EEA or UK user or resident and request erasure of your personal data under GDPR Article 17, we will: (i) comply with respect to any data that is not subject to a mandatory retention obligation; (ii) notify you of the legal basis for our continued retention of any records we are unable to delete; and (iii) confirm the earliest date on which full deletion can be effected. Nothing in this clause derogates from your rights under GDPR Article 17(3).

To exercise any of these rights, please contact us at leo@lbx.pro.  We will respond to your request within one (1) month of receipt, though this period may be extended by up to two (2) further months where requests are complex or numerous; we will notify you of any such extension within the first month.  You also have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.  Relevant authorities include:  (i) for EEA residents — your national supervisory authority (see: https://edpb.europa.eu/about-edpb/about-edpb/members_en);  (ii) for UK residents — the Information Commissioner’s Office (https://ico.org.uk);  (iii) for Swiss residents — the Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch).

11.  SECURITY

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction.  These include encrypted data transmission, access controls, and periodic security reviews.  However, no transmission over the internet or electronic storage system is completely secure, and we cannot guarantee absolute security.  In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law, typically within seventy-two (72) hours of becoming aware of the breach (or, where notification to you is required, within thirty (30) days of confirming the breach).

12.  CHILDREN’S PRIVACY

The platform is not intended for use by children under the age of 13 (or 16 in certain jurisdictions, including the EEA and UK).  We do not knowingly collect personal data from children below the applicable age threshold.  If we become aware that we have collected personal data from a child below the applicable age, we will take steps to delete that information as promptly as practicable.  If you believe that a child has provided personal data to us without appropriate parental or guardian consent, please contact us at leo@lbx.pro.

13.  COMMUNICATIONS

We may send you administrative notices, service updates, and information relevant to your account and use of the platform. These communications are sent on the basis of our legitimate interests in operating the platform and keeping you informed of matters affecting your account. You may opt out of non-essential platform communications at any time by contacting leo@lbx.pro.

14. CONTACT US

For any questions about this Policy or to exercise your data protection rights, please contact:

LaunchBay Capital FZCO

Registered address: IFZA Business Park, DDP , PO Box 342001, Dubai, United Arab Emirates

Email: leo@lbx.pro

Company registration number: 15802

This Privacy Policy governs the use of the LBXPro and LBXWealth.  It does not govern account, service, or transactions matters which are addressed in the applicable platform Terms of Service.