Privacy Policy

LELI Finance (operated by 3C Capital Inc., 4300 Biscayne Blvd, Suite 203, Miami, Florida 33137, United States — together “LELI Finance”, “we”, “us”) respects your privacy. This Privacy Policy describes what personal information we collect, how we use it, and your rights with respect to that information.

1. Information we collect

1.1 Information you provide

• Contact details: name, email address, telephone number, employer, professional title.
• Investor information: investor classification (institution, family office, high-net-worth individual), domicile, source of wealth.
• Account credentials: email, hashed password, two-factor authentication secrets.
• Communications: messages, requests, and any documents you submit to us.

1.2 Information collected automatically

• Technical data: IP address, browser type and version, operating system, language, time-zone, device identifiers.
• Usage data: pages visited, links clicked, session duration, referring URL.
• Cookies and similar technologies as further described in Section 6.

2. How we use your information

We process personal data only for purposes that are lawful, fair, and transparent. In particular:

• To respond to access requests and to assess investor suitability.
• To provide, secure, and improve our portal and services.
• To comply with anti-money-laundering (AML), know-your-customer (KYC), tax, and other legal obligations.
• To send service-related communications (e.g. account notifications, security alerts).
• With your consent, to send marketing communications you may withdraw at any time.

3. Legal basis

Where the EU or UK General Data Protection Regulation applies to your data, we rely on one or more of the following bases: (i) performance of a contract; (ii) compliance with a legal obligation; (iii) our legitimate interests in operating, securing, and developing our services; or (iv) your consent, which you may withdraw at any time.

4. Sharing of information

We share personal data only with:

• Service providers bound by confidentiality (e.g. cloud hosting, email delivery, KYC/AML providers, professional advisers).
• Affiliated entities within the LELI Finance / 3C Capital group, on a need-to-know basis.
• Authorities and regulators where required by law, court order, or to protect our rights.

We do not sell your personal data.

5. International transfers

Your data may be processed in jurisdictions outside your country of residence, including the United States. Where required, we put in place appropriate safeguards (e.g. EU Standard Contractual Clauses) to protect your data in line with applicable law.

6. Cookies

We use strictly necessary cookies to operate our portal (authentication, language preference) and, with your consent, analytics cookies that help us understand how the site is used. You can disable non-essential cookies in your browser at any time.

7. Data retention

We retain personal data only for as long as necessary for the purposes stated in this Policy and to comply with applicable retention obligations (typically 5–10 years for AML and financial-services records).

8. Your rights

Subject to applicable law, you may have the right to: access your data; rectify inaccurate data; request erasure; restrict or object to processing; data portability; and withdraw consent. To exercise these rights, contact management@leli.finance. You may also lodge a complaint with your local supervisory authority.

9. Security

We apply organizational and technical measures appropriate to the risk, including encryption in transit, hashed credentials, access controls, and audit logging. No system is perfectly secure, and we cannot guarantee the absolute security of your data.

10. Children

Our services are not directed to individuals under 18. We do not knowingly collect data from minors.

11. Changes

We may update this Policy from time to time. The effective date at the top of this page indicates when it was last revised.

12. Contact

For privacy-related questions, contact: management@leli.finance — 3C Capital Inc., 4300 Biscayne Blvd, Suite 203, Miami, Florida 33137, United States.