Privacy Policy

Updated and effective: 25 June 2026

Introduction

LF Operations Inc. (“Lombard”, “the Company”, “we”, “us”, or “our”) is the controller responsible for your personal data and is committed to protecting and respecting your privacy. This Privacy Policy (the “Policy”) describes how LF Operations Inc. and its affiliates collect, use, and share your personal data when you access our websites, including lombard.finance and its sub-domains, our applications and software, and all of our other properties, products, and services (collectively, the “Services”).
For the purposes of this Policy, personal data is any data related to an identified or identifiable individual. Your use of the Services is subject to this Policy as well as our Terms of Use. If you do not agree with the terms of this Policy, please do not access or use the Services or any other aspect of our business.

What Personal Data We Collect

When you visit our websites and use our Services, we may collect the following categories of data:
Personal identifiers. Your name, email address, IP address, or other similar information you choose to provide, including when you contact us or sign up to receive communications.
Blockchain data. Publicly available blockchain data when you connect your non-custodial wallet to the Services. When you connect your wallet, we collect and log your publicly available blockchain address, together with associated transaction and balance information, in order to learn more about your use of the Services and to screen your wallet for any prior illicit activity. We screen wallets using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
Direct communications. Records of your interactions with us. Whenever you reach out to us through email, social media, or other support channels, or engage in surveys or questionnaires, we receive and may retain the data and communications you share.
Technical data. Traffic data, logs, and other communication data, including the resources that you access and use on the Services.
Device information. Device type, operating system, browser type, and diagnostic data, which are collected automatically when you use the Services.
Information from cookies and other tracking technologies. We and our third-party service providers may access and collect data from localStorage, mobile device IDs, cookies, web beacons, and other similar technologies to provide and personalize the Services and their features for you across sessions.

How We Use Your Data

As the operator of the Services, we take the protection of your personal data very seriously. We may use your personal data for the following purposes:
Maintaining and improving the Services. We use the data we collect to provide, maintain, customize, and improve our Services and their features, including in aggregated form to compile information across multiple users.
User support and communication. We use the data we collect to respond to your inquiries and support requests and to share information with you about our Services.
Product development. We use the data we collect to develop new products and features.
Security notices and important updates. We use the data we collect to send you security notices and other important updates relating to the Services.
Safety and security. We may use the data we collect to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity, to address security risks and solve potential security issues such as bugs, to enforce our agreements, and to protect our users.
Research and analysis. We use the data we collect to conduct research and analysis to better understand and improve the Services.
Legal and regulatory compliance. We may use the data we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations, and to investigate or address claims, disputes, or regulatory inquiries relating to the use of our Services.
Data anonymization and aggregation. We may aggregate or anonymize your personal data so that it no longer identifies you as an individual, and may use such data for statistical analysis, research, or other purposes.
Other purposes with your consent. If we need to use your personal data for any other purpose, we will ask for your consent and will use your data only for the purpose(s) for which you grant consent, unless we are required to do otherwise by law.
You may opt out of optional product-update or promotional communications by writing to us at the contact address below. Please note that if you do not allow us to collect or process the required personal information, or if you withdraw your consent, you may not be able to access or use the Services for which your information was sought.

How Cookies Are Used

We may use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies (such as web beacons, pixels, and scripts) (collectively, “Cookies”) to provide certain functions on our Services and to help collect data. We may use Cookies to track how you use our Services by providing usage statistics, to deliver our information and updates, and to enable authentication based on your browsing history and previous visits. We may combine the information we collect from Cookies with other personal information to learn more about how you use our Services and to improve them.

Types of Cookies

We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which remain on your device until you delete them). The Cookies we use can be grouped into the following categories:
Strictly necessary. These Cookies are necessary for the Services to work properly, including essential authentication and authorization Cookies.
Functional. These Cookies enable technical performance and allow us to remember the choices you make while browsing, including any preferences you set, as well as sign-in and authentication that enable you to return without additional sign-in.
Performance/analytics. These Cookies allow us to collect information about how you navigate the Services so we can understand which areas you use and what we can improve.
Targeting. We do not use Cookies to deliver third-party or interest-based advertising. Any preference Cookies we use are limited to remembering content you have already viewed within our Services so we can improve your experience; we do not share Cookie data with advertising networks for their own marketing.

How to Control and Delete Cookies

Cookies can be controlled, blocked, or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific, so if you use multiple browsers or devices to access the Services, you will need to manage your Cookie preferences across each environment. If you are using a mobile device, please refer to your device’s instruction manual or settings to find out how to control Cookies.
Please note that if you restrict, disable, or block any or all Cookies, the Services may not operate properly and you may not be able to access some features. We are not responsible for any inability to use our Services or any degraded functionality caused by your Cookie settings and choices. We do not use your personal data to serve third-party interest-based advertising.

We may share or disclose the data we collect in the limited circumstances described below:
Service providers and vendors. With hosting providers, auditors, consultants, and other vendors who assist us in providing, delivering, and improving the Services.
Protocol operators and validators. With protocol operators and validators, as needed for protocol operations.
Blockchain security and analytics providers. With blockchain analytics providers to ensure the safety and security of our Services and to screen your wallet for any prior illicit activity.
Regulators, government entities, and law enforcement. To comply with our legal obligations and when legally required.
Business acquirers. In connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business or assets.
To enforce our agreements. To enforce your agreements with us, including this Privacy Policy, and to respond to claims that your use of the Services violates the rights of any third party.
Where we share personal data with third parties, we require them to use it only for the purpose for which it was transferred and not to retain it for longer than is required to fulfill that purpose. We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

International Data Transfers

We, along with our affiliates, subsidiaries, and trusted third-party providers, may process your personal information in countries outside of your own. The data privacy laws in these countries may differ from, and potentially offer less protection than, those in your home country. When transferring your personal information internationally, and in accordance with applicable legal requirements, we will implement appropriate safeguards to ensure your data is adequately protected. For further details on how we manage international data transfers, please contact us using the information in the “Contact Information” section below.

Applicable Data Protection Laws and Your Rights

We process personal data in accordance with applicable data protection laws, which, depending on your location, may include the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”). Where we process your personal data, we rely on one or more lawful bases, including your consent, performance of a contract with you, compliance with our legal and regulatory obligations (such as anti-money laundering and sanctions screening), and our legitimate interests in operating and securing the Services.
Subject to applicable law and certain exceptions, you may have the following rights regarding your personal data: access to a copy of your data; rectification of inaccurate or incomplete data; erasure; restriction of processing; data portability; objection to processing based on our legitimate interests; and withdrawal of any consent you previously gave (without affecting prior processing).
We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
To exercise any of these rights, contact us at legal@lombard.finance. We may need to verify your identity before responding, and we will respond within the timeframes required by applicable law. You also have the right to lodge a complaint with your local data protection authority (for example, your EU member-state supervisory authority).

Security

The security of your data is important to us, and we take reasonable measures to prevent the loss, misuse, unauthorized access, modification, or disclosure of your personal data under our control. These measures are reviewed from time to time in line with legal and technical developments. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.

Age Limitations

The Services are not directed to, or intended for use by, anyone under the age of 18. Lombard does not knowingly collect personal data from anyone under 18. If we learn that we have collected personal data from an individual under 18 without verification of parental consent, we will delete that information promptly. If you believe we may have any information from or about a person under 18, please contact us.

Links

There may be links from our Services to other websites and resources provided by third parties. This Privacy Policy applies only to our Services. Accessing those third-party websites or resources requires you to leave our Services. We do not control those third-party sites or their content, and we are not responsible or liable for them, including their content, policies, products, services, or actions, or for any damages or losses arising from them. We encourage you to review the policies, rules, and terms, including the privacy policies, of each site that you visit.

Changes to the Policy

We may modify this Privacy Policy at any time. The revised Policy will be effective immediately upon being posted within the Services, and your continued access to or use of the Services after that time will constitute your acceptance of the revised Policy. We encourage you to review the latest version of this Privacy Policy regularly.

Retention of Personal Information

We retain the personal data we collect only for as long as necessary to fulfill the purposes for which it was collected, to provide our Services, to resolve disputes, to enforce our agreements, and to comply with legal obligations. This period may vary depending on the nature of the data and the reasons for collecting it, having regard to the purposes described in this Policy and our own legal and regulatory requirements.

Contact Information

If you have any questions, comments, or concerns regarding this Privacy Policy, or wish to exercise your data protection rights, please contact the data controller, LF Operations Inc., at legal@lombard.finance or at PH The Century Tower, Office 317, Vía Ricardo J. Alfaro, Betania, Panamá District, Panamá Province, Panama.

Acknowledgment of Risks

By using the Lombard Finance Services, you acknowledge that you have read, understood, and agree to this Privacy Policy.