LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
LEEM.finance Privacy Policy
Effective Date: August, 2025
Version: 1.1
Introduction
LEEM.finance (“the Platform,” “we,” “us,” or “our”) values and respects your privacy. This Privacy Policy explains in detail how we collect, process, store, and share personal and blockchain related data when you use our services, including the LEEM Token which operates on the Binance Smart Chain (BSC).
Blockchain brings unique privacy considerations. While we can control how we process user submitted data (such as names, emails, and documents), we cannot alter the public, transparent, and permanent nature of blockchain transactions. This Policy therefore explains both:
1. Off-chain data handling (data we collect and store internally or via partners). 2. On-chain transparency (data recorded permanently on BSC).
We strive to comply with the strictest global privacy frameworks such as GDPR (Europe), CCPA (California), and relevant global data protection standards.
Scope
This Policy applies to:
• Users visiting https://LEEM.finance/
• LEEM Token holders and participants on the Binance Smart Chain
• Customers undergoing KYC verification via Persona or Sumsub
• Transactions monitored through KYT tools provided by Elliptic
• All communications (support requests, compliance inquiries, etc.)
It does not apply to third-party platforms outside our control, such as decentralized exchanges or wallets unaffiliated with LEEM.finance.
Data We Collect
We may collect the following:
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
1. Identity Data
o Name, email, date of birth, government-issued identification, proof of address. o Collected via trusted verification providers (Persona or Sumsub).
2. Wallet & Transaction Data
o Public blockchain addresses, transaction details, balances, smart contract activity.
o Collected from the Binance Smart Chain network for compliance and analytics. 3. Financial Data
o Payment details for fiat conversions (if applicable).
4. Usage Data
o IP address, device identifiers, system logs, browser type, and activity on our website.
5. Cookies & Tracking Data
o Session data, analytics, and security cookies.
6. KYT Data
o Risk scores and alerts generated by Elliptic’s blockchain analytics.
Purposes of Processing
We process data to:
• Verify identity and fulfill legal KYC obligations.
• Monitor blockchain transactions for suspicious activity (KYT).
• Provide platform services, including smart contract interactions and token transfers. • Prevent fraud, cybercrime, and unauthorized activities.
• Comply with AML, sanctions, and tax regulations.
• Improve services and personalize user experiences.
Legal Basis for Processing
We rely on:
• Consent – when you provide data voluntarily (e.g., account registration). • Contract – when processing is necessary to deliver services.
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
• Legal Obligations – AML/CTF, financial reporting, sanctions checks. • Legitimate Interests – security, fraud detection, platform analytics.
Cookies & Tracking
Cookies are used for security (session tracking), analytics (understanding usage), and personalization. Users may disable cookies via browser settings, but this may affect functionality.
Data Sharing & Third Parties
We share data with trusted partners only:
• Persona / Sumsub – for KYC verification.
• Elliptic – for KYT blockchain monitoring.
• Regulators & Law Enforcement – when legally required.
• Auditors & Compliance Partners – under confidentiality agreements. We never sell personal data to marketers.
Blockchain Transparency (Binance Smart Chain)
LEEM Token transactions occur on the Binance Smart Chain, a public network. • Wallet addresses and balances are publicly visible.
• Transaction records are permanent and immutable.
• LEEM.finance cannot edit or delete blockchain data.
Users must understand that blockchain transparency is outside our control.
Data Retention
• KYC/KYT Data: retained for at least 7 years to comply with regulations. • Blockchain Data: permanent and immutable.
• Usage Data: retained as long as necessary for business and compliance needs.
User Rights
Depending on jurisdiction, you may request:
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
• Access, correction, or deletion of your data.
• Restriction or objection to processing.
• Data portability (export of personal data).
• Withdrawal of consent (where applicable).
Requests: info@LEEM.finance
Security Measures
We protect user data using:
• Encryption at rest and in transit.
• Strict access controls.
• Intrusion detection and firewalls.
• Use of vetted third-party compliance providers (Persona, Sumsub, Elliptic). No system is 100% secure, but LEEM.finance employs industry-leading safeguards.
Children’s Privacy
Our services are not directed to persons under 18.
If we discover that a minor has registered, the account will be suspended.
Policy Updates & User Responsibility
• LEEM.finance reviews this Privacy Policy multiple times per year.
• Updates are published at https://LEEM.finance/.
• Users are responsible for reviewing updates and ensuring their activities do not breach the latest version.
Contact
info@LEEM.finance
https://LEEM.finance/
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
LEEM.finance Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF) Policy
Effective Date: August, 2025
Version: 1.1
Purpose
LEEM.finance is committed to preventing money laundering, terrorist financing, and other illicit financial activity in the LEEM Token ecosystem. This Policy ensures compliance with international financial integrity standards.
Scope
This Policy applies to:
• LEEM.finance account holders
• LEEM Token transfers on Binance Smart Chain
• Employees, contractors, and partners
Legal & Regulatory Framework
Our AML framework is aligned with:
• FATF Recommendations
• EU AML Directives
• US OFAC & UN Sanctions
• VASP regulatory best practices
KYC (Know Your Customer)
We partner with Persona and/or Sumsub to:
• Verify user identity using official documents and biometric checks.
• Apply Enhanced Due Diligence (EDD) for high-risk users (PEPs, high-value transfers, high-risk jurisdictions).
• Prevent the use of LEEM.finance by anonymous or fraudulent actors.
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
Transaction Monitoring (AML Focus)
We use blockchain monitoring and compliance tools to:
• Flag unusual behavior (large transfers, rapid cycling, cross-border high-risk flows). • Detect links to mixers, tumblers, or sanctioned wallets.
• Escalate alerts to compliance teams.
Sanctions & Prohibited Activities
• Users are screened against OFAC, UN, and EU sanctions lists.
• LEEM.finance prohibits anonymous accounts, darknet transactions, ransomware, and use in blacklisted jurisdictions.
Record-Keeping
• KYC & AML records: retained for 7 years.
• SARs (Suspicious Activity Reports): securely logged.
• Blockchain data: immutable by design.
Suspicious Activity Reporting
Employees escalate to the AML Officer. Reports are filed with relevant Financial Intelligence Units (FIUs).
Training & Awareness
Employees receive annual AML training and specialized instruction on crypto typologies and Binance Smart Chain compliance risks.
Policy Updates & User Responsibility
This AML Policy is reviewed several times per year.
• Updates are posted on https://LEEM.finance/.
• Users must review and ensure their activities remain compliant.
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
LEEM.finance KYT (Know Your Transactions) Policy
Effective Date: August, 2025
Version: 1.1
Introduction
Beyond KYC, LEEM.finance also monitors on-chain activity through KYT (Know Your Transactions) tools. Because LEEM Token operates on the Binance Smart Chain, KYT ensures continuous compliance and fraud prevention.
KYT Provider (Elliptic)
LEEM.finance partners with Elliptic (https://www.elliptic.co/) to:
• Screen all LEEM Token transactions for exposure to high-risk wallets.
• Detect links to illicit markets, money laundering services, or sanctioned addresses. • Assign risk scores to transactions and wallets.
• Provide alerts for investigation by our compliance team.
Scope of Monitoring
Elliptic KYT applies to:
• All wallet-to-wallet transfers involving LEEM Token.
• Interactions with DeFi protocols or DEX platforms.
• Unusual transaction patterns (rapid cycling, structuring, excessive volume).
User Responsibility
• Users must ensure their transactions are lawful and policy-compliant. • Transactions flagged as high-risk may result in suspension or regulatory reporting.
Integration with AML
KYT strengthens LEEM.finance’s AML program by providing real-time blockchain intelligence that complements KYC data.
LEEM.finance – Privacy Policy & AML/CTF Policy https://LEEM.finance/
Review & Updates
The KYT Policy is reviewed several times per year. Users are responsible for reviewing updates on https://LEEM.finance/ and ensuring their activities remain compliant.
Contact
info@LEEM.finance
https://LEEM.finance/